Introduction

As the Chief Energy Conservation Officer of Ontario, I call upon the Government of Ontario to substantially increase the minimum energy efficiency standards in the Ontario Building Code (the “Code”) and make Ontario a North American leader of energy efficient building.

We are very pleased that the government has begun a process to increase the energy efficiency requirements in the Code, and that this has been done in an expeditious manner. This was one of the recommendations in the first Annual Report of the Chief Energy Conservation Officer, Our Conservation Challenge (the “Annual Report”) .

The Annual Report identified the great potential for energy conservation that lies in improvements to the Code, and made a number of recommendations, including:

• Incorporating higher minimum energy efficiency standards for buildings; 
• Increasing the minimum energy efficiency standards for electrically-heated houses; and 
• Making “Energy Star” windows the minimum standard for windows.

Ontario faces a growing gap in electricity supply over the next 20 years. This gap flows from increasing electricity demand and decreasing supply due to aging plants and infrastructure, and well recognized concerns regarding greenhouse gas emissions.

The province also faces challenges regarding peak demand, i.e. the amount of electricity required at any given moment in time. Ontario has historically been a winter-peaking jurisdiction. However, with the increase in air-conditioning use in all sectors of the economy and other factors, Ontario has become a summer-peaking jurisdiction.

Conservation and demand management are needed to ensure that the Province’s electricity system will continue to meet Ontarians’ needs in a reliable, cost-effective and environmentally sustainable manner today and in the future.

In recognition of the need for conservation, the provincial government has called for the creation of a “Culture of Conservation”, and established the Conservation Bureau to champion conservation and demand management. Improving the energy efficiency requirements of codes and standards so that we ‘build better’-- in an energy efficient way – is a cost-effective and proven way to address our energy challenges and to create a Culture of Conservation.

The technology exists and the market is ready to ‘build better’. Investing in energy efficient buildings makes economic sense. As the price of electricity increases, the economics of building better will only improve.

The power of building better was recognised by the Conservation Action Team (the “CAT”), a committee of Parliamentary Assistants from eight ministries. In its 2005 Report , the CAT recommended improving the energy efficiency requirements of the Code as one important way of conserving electricity. The government needs to lead the way on energy efficiency; if we all work together, Ontario’s residents, businesses and institutions will all benefit.

Summary of Recommendations

The Ministry of Municipal Affairs and Housing (the “MMAH”) has issued a consultation paper to explore increasing the energy efficiency of the Code.

In response to this call for submissions, we make the following recommendations:

• All new homes (Part 9) built under the Ontario Building Code shall meet or exceed 80 on the EnerGuide for Houses scale for energy efficiency.
• All new homes shall be built with high efficiency heating and cooling systems, and programmable thermostats.
• All new windows shall have an energy rating of at least -10 ER. 
• All cooling systems shall at least meet the EER 11.5 standard.
• All other non-residential new buildings (Part 2) not covered by Part 9 shall be built to a standard of 25% better than the Model National Energy Code for Buildings. 
• Ontario should work with the Federal Government to update the Model National Energy Code for Buildings in an expeditious manner.
• A labelling system for all buildings that is based on existing Natural Resources Canada systems should be adopted in the Energy Conservation Responsibility Act, 2006 , and phased-in over time.
• The green technologies listed in the consultation document should be included in the Ontario Building Code.
• A process should be established to ensure that the Code facilitates the adoption of viable green technologies.
• Energy efficiency should be actively encouraged through amendments to the Code and education of the market.

The full report can be downloaded by clicking the link below.

This submission was drafted with the assistance of Christian Cianfrone, M.A.Sc. candidate, and Professor K.D. Pressnail of the Department of Civil Engineering, University of Toronto. Background information was also obtained from Natural Resources Canada.