Energy and Water Reporting and Benchmarking
Regulation - LGIC
Bill or Act:
Electricity Act, 1998
Summary of Decision:
O. Reg. 506/18 requirements were to be phased in over three years (2018-2020) based on building type and size. In phase 1, designated buildings over 250,000 sq. ft. were required to report by July 1, 2018. In phase 2, designated buildings over 100,000 sq. ft. were required to report by July 1, 2019. As part of phase 3, designated buildings over 50,000 sq. ft. would have been required to report by July 1, 2020. The Ministry received policy approval through the Fall 2019 Red Tape Reduction Package to end the roll-out of the Energy and Water Reporting and Benchmarking (EWRB) program requirements (phase 3) to buildings that are less than 100,000 sq. ft.
Following this direction, on October 28, 2019, the Ministry posted a proposed amendment to O. Reg. 506/18 on the Regulatory Registry, proposing to stop further roll-out of the EWRB program to buildings under 100,000 sq. ft.
The majority of the comments received through the Regulatory Registry posting opposed the proposed amendment, noting concerns about the negative impacts on potential energy savings resulting from stopping further roll-out of the program. The Ministry also considered informal feedback it received from building owners, property managers and other stakeholders regarding this proposal.
Support for continuing with the roll-out of the program came from commercial building sector organizations, a large condominium management company, municipalities, organizations focused on environmental issues and architects. Some comments also suggested that a delay to the roll-out could be considered as an alternative to ending the roll-out.
Based on the comments received, the Ministry amended O. Reg. 506/18 to delay the roll-out of the EWRB program requirements to buildings less than 100,000 sq. ft. until 2023, as opposed to completely ending the roll-out. If owners of buildings between 50,000 and 100,000 sq. ft. wish to report before 2023, they may report on a voluntary basis.
Analysis of Regulatory Impact:
This amendment will provide small building owners three additional years to prepare for reporting and allow the Ministry to develop effective outreach strategies and supporting resources targeted to small building owners. The Ministry will also continue to explore strategies to streamline the reporting process to help minimize costs of future reporting.
Summary of Proposal:
O. Reg. 506/18, Reporting of Energy Consumption and Water Use under the Electricity Act, 1998, requires owners of large commercial, multi-unit residential, industrial, and other prescribed building types that are 50,000 sq. ft. or larger to report their building's energy and water consumption and greenhouse gas (GHG) emissions data by July 1st each year to the Ministry of Energy, Northern Development and Mines ('the Ministry").
77 Grenville Street 5th Floor, Toronto, M7A 2C1
June 12, 2020