CSV Architects’ Presentation in Support of Sustainable Kingston
Here at CSV Architects’, sustainable design is fundamental to all our work. This means it is crucial that we stay up to date with the various regulations surrounding this increasingly popular topic, in an ever-changing landscape. Because CSV has our very own expert in this field (Sustainability Consultant Stephen Pope), we really make an effort to spread our knowledge to others in the industry in hopes of promoting sustainable design and making it more accessible to all.
On September 21st, Stephen drove to Kingston, Ontario to present a lecture for members of Sustainable Kingston, a non-profit organization that strives to enhance the livability and resiliency of its city. This talk focused on the new Ontario Regulation on Large Building Energy and Water Reporting and Benchmarking (O.Reg 20/17). Stephen has quite a bit of experience in this area - in his 18-year association with Natural Resources Canada, he delivered over 120 presentations of this type!
CSV undertook this project as a way of reinforcing our own activities under our commitment to EnviroCentre’s Carbon 613, to reduce GHG emissions and energy and water consumption. Carbon 613 is one of 8 social enterprises across Ontario that assemble networks of businesses that are setting sustainability targets with the support of Sustainability CoLab. This organization aims to create a collaborative network of organizations committed to embedding sustainability into their operations and driving environmental and economic advancement in the National Capital Region.
The New Ontario Regulation on Large Building Energy and Water Reporting and Benchmarking
Ontario Regulation 20/17 is simple in concept, but quite revolutionary in attitude, and consistent with other recent changes in building regulations. In the past, building regulations only focused on health and safety, and information about building performance was the private property of the building owner.
To comply with this regulation, participants will use the Canadian version of the US EPA’s Portfolio Manager software to do the following:
· declare the location and gross floor area (in sq.ft.) of the building(s)
· provide the occupancy (with the ability to define multiple occupancies) and its percentage leased
· enter the utility bills for the year in the appropriate spots
Buildings with a gross floor area greater than 250,000 sq.ft., (with Multiple Unit Residential Buildings, MURBs, exempted) are collecting data now for reporting on July 1st, 2018. Buildings with a gross floor area of 100,000 sq.ft., will be added in 2018 with MURBs now having to report, and will deliver their first reports in 2019. Finally, buildings greater than or equal to 50,000 sq.ft., will be added in 2019, with the first report required in 2020.
Recently the Ministry of Municipal Affairs has declared that the building code will now be used as a support mechanism for the Ontario Climate Change Action Plan. This new approach has already seen the introduction of a carbon consumption declaration in building permit applications, and a dramatic increase in the thermal requirements for the building enclosure since 2011. Public reporting of energy and water consumption, and the GHG impacts of that consumption, will start for the largest building types in 2018.
The collection and analysis of energy and water consumption information is considered an essential part of provincial planning around these two commodities. This legislation describes the new requirement for data management and reporting as a win for owners, who now will have a new management tool to assist with their own planning. It is hoped that the information will lead to better management of building equipment replacement cycles, which in turn will lead to re-investment and improvement of the building stock in Ontario.
Issues for Concern
Of course, the devil is always in the details, and conversations Stephen had with the attendees of this lecture raised some significant issues. The first was very visible just from looking out of the windows of the Sustainable Kingston Office. Most of Kingston’s downtown is 2 to 4 stories high, and as 19th Century “Main Street” type buildings, they have footprints much less than would be required for the minimum 50,000 sq.ft. gross floor area of this regulation. Checking the general nature of the Canadian building stock as represented by the Natural Resources Canada 2009 Survey of Commercial / Institutional Energy Use, buildings larger than 50,000 sq.ft. represent only 6.4% of the total number of buildings, although they represent just over half of the total floor area and use just under half of the total of energy used by buildings. Most buildings will simply be under the radar.
There was also some questioning about the requirements as expressed in the legislation for the utilities to give the information to owners, when most owners receive regular utility bills. No explanatory clauses responding to the question are in the regulation, which is quite short. The speculative response was that some buildings in older cities are still not metered and the owner has an agreement with the utility on a pre-rated bill based on total floor area and bulk metering for a specific area. It was further speculated that requiring the utility to release the data addressed previous challenges in access to information on the part of other authorities.
Finally, while using Portfolio Manager to track and analyze consumption is simple enough, and the reporting obligation is clearly established, no details were provided regarding to whom an owner would report the details. It may simply be the case that the Ministry of Municipal Affairs would access the Portfolio Manager database, but the details remain obscure.
While this regulation is indeed a step in the right direction, it seems that building owners will need to be on the lookout for future announcements related to this regulation.