BACKGROUNDER - Environmental Commissioner of Ontario Annual Energy Conservation Progress Report - 2011 (Volume One)
Tuesday, June 5th 2012 10:30:52am
Restoring Balance, A Review of the First Three Years of the Green Energy Act
Annual Energy Conservation Progress Report - 2011
Under the Environmental Bill of Rights, 1993, the Environmental Commissioner of Ontario (ECO) reports annually to the Legislative Assembly of Ontario on the province’s progress in energy conservation.
This report is Volume One of the 2011 annual energy report and reviews policy development. It has been three years since the Green Energy Act, 2009 (GEA) took effect in May 2009. There has been much activity since then related to the renewable generation provisions of the Act, as is evident by the creation and refinement of the province’s Feed-in Tariff (FIT). In the ECO’s view, much less effort has been directed at the conservation-related provisions and policies of the Act.
The report focuses on four key energy conservation policy commitments made to develop a culture of conservation, which accompanied the government’s release of the GEA. Overall, three years in, the ECO believes that the conservation promises of the GEA remain unfulfilled and possibly still years away from completion.
Commitment One “North American leading energy efficiency standards (Energy Star) for household appliances, including efficient use of water”
There is little evidence that the Ontario government has given product energy efficiency standards a high priority since 2009. Energy efficiency standards set a minimum energy efficiency level that a product must meet to be legally sold. Over time, as technology improves and products become more energy-efficient, the bar is typically raised by increasing minimum efficiency standards. None of the regulatory changes Ontario has proposed to date would set efficiency levels for major appliances that are higher than Canadian or U.S. requirements.
The ECO believes that minimum efficiency standards can and should play an important role in reducing energy consumption and greenhouse gas emissions in Ontario, complementing conservation programs. The ECO believes that the Ministry of Energy missed an opportunity to save Ontarians energy and money, shortly after passage of the GEA, by not acting to implement the ENERGY STAR® standard as the minimum performance standard for certain products. The Ministry of Energy should lead an analysis to identify which products offer the most promising opportunities for saving energy in Ontario. For these products, Ontario should work with the federal government to strengthen national standards. If unsuccessful, the province should act alone.
The ECO recommends that the Ministry of Energy set North American-leading energy efficiency standards for key products with the greatest potential for Ontario to save energy.
Commitment Two “Mandatory home energy audits prior to sale of homes”
The intent of this commitment was to make the energy efficiency of a home transparent through a rating provided prior to the sale. This helps buyers understand a home’s energy use and on-going operating costs - what is sometimes referred to as the “second bill” of a home purchase. During consultation, both strong support and opposition for this commitment was expressed by stakeholders, and the Act was amended prior to passage to accommodate the diverse views. Although the Green Energy Act was passed in May 2009, the section related to mandatory home energy efficiency disclosure has not yet been proclaimed into force, and no action appears forthcoming.
The ECO believes that the public interest is being harmed by the government’s inaction on mandatory home energy audits. Society no longer tolerates a lack of disclosure for the energy performance of products, such as vehicles and appliances, and it should be no different for home ownership - the largest economic commitment most people make in their lives.
The ECO recommends that the government proclaim and implement the provision for mandatory home energy efficiency disclosure in the Green Energy Act, 2009.
Commitment Three “Making energy efficiency a central tenet of Ontario’s Building Code”
Ontario’s Building Code is a regulation that sets mandatory requirements that must be met by all new buildings and certain types of renovations. The Code’s primary and original purpose was to ensure public health and safety, but it has also been used to advance other social priorities, including barrier-free access for Ontarians with disabilities and conservation of resources. The Code is one of the most important conservation tools available to the Ontario government because it affects the energy consumption of all new buildings.
Since the passage of the GEA, the government has established an advisory committee on energy efficiency in buildings, successfully implemented higher efficiency requirements in 2012, and proposed even higher standards for the next edition of the Code (although these changes have not been finalized). The ECO believes the government has met the original intent of its commitment. However, the ECO is concerned that the five-year review of the Code’s energy efficiency provisions is inadequate given the pace of development occurring in some parts of the province.
The ECO recommends that the Ministry of Municipal Affairs and Housing review energy conservation amendments to the Ontario Building Code more frequently than the current five-year cycle.
Commitment Four “Green Ontario government and broader public sector buildings; including the development of conservation plans”
Public sector buildings are large users of electricity and natural gas, and greening these buildings can reduce energy consumption of both fuels. Commendably, the government passed a regulation requiring annual reporting of energy consumption, as well as the creation of energy conservation plans by municipalities, municipal service boards, post-secondary educational institutions, public hospitals, and school boards. The ECO believes that the annual reporting template (which has yet to be finalized) should allow other energy use information, such as fleets and street lighting, to be voluntarily submitted by public agencies. Tracking and reporting on these forms of energy consumption would drive additional conservation efforts.
The ECO recommends that the Ministry of Energy expand the annual energy reporting requirements for the Broader Public Sector to include fleets and other key energy-consuming operations.
The ECO urges the government, through its directive power, to require comparable action for Ontario government facilities. A strong conservation plan could make the government a leader and serve as a model for the Broader Public Sector.
The ECO recommends that the Minister of Infrastructure issue a directive requiring annual, public reports of energy consumption for all government ministries and an energy conservation plan for the Ontario government by the end of 2012.
To aid the public sector with estimating its carbon footprint, the ECO also believes the greenhouse gas emissions factors for Ontario’s electricity generation should be made available on an hourly basis. This promotes electricity use when demand is lower, thereby avoiding construction and use of fossil-fueled peaking power plants.
The ECO recommends that the Independent Electricity System Operator make publicly available the estimated greenhouse gas emissions factors for Ontario’s electricity consumption on an hourly basis.
Download the report: Restoring Balance, A Review of the First Three Years of the Green Energy Act: Annual Energy Conservation Progress Report 2011 (Volume One) at www.eco.on.ca
For more information and interviews, contact:
Communications and Outreach Coordinator
Environmental Commissioner of Ontario
For French language release and bilingual support, please contact Jean-Marc Filion, 705-476-9665.
The Environmental Commissioner of Ontario is appointed by the Legislative Assembly to be the province's independent environmental watchdog, and report publicly on the government's environmental decision-making.
Aussi disponible en français.