British Columbia’s forthcoming Clean Growth Strategy consists of three intentions papers that aim to integrate the Province’s goals for climate action and sustainable economic growth. The focus of these papers is transportation, building and economic growth in the industry.
Community Power, part of the Kambo Energy Group has identified a number of actions which, if incorporated into the Clean Efficient Buildings Paper would support a sustainable and more equitable transition in BC’s energy efficiency sector.
The actions are summarized below.
1. Professionalization of the energy efficiency industry
We see the professionalization of the energy efficiency industry as a much-needed step towards full accountability of the industry as well as the delivery of energy savings that are meaningful to recipients. Mechanisms for organizational accreditation that support end-to-end services, and a professional standard for monitoring and evaluating results are crucial in developing a robust, effective and sustainable industry. We hope the Province a) supports creating accreditation systems, and b) fosters the design of energy efficiency programs by the industry which respond to the needs of different markets.
2. Holistic approach vs prescriptive programs
We recognize that for large parts of the market, the main barriers to energy efficiency remain unaddressed if prescriptive programs and financial incentives are the only tools deployed. Community Power acts as a one-stop shop for energy efficiency as we make the process accessible for clients so they don’t have to source and manage multiple professionals and trades people during the course of an energy retrofit. If one organization is not responsible for estimating, delivering and achieving energy savings it lacks any effective accountability.
3. Flexible incentive structures
There is an urgent requirement to design incentive structures that are equitable, inclusive and flexible to meet the specific needs of diverse communities.
In addition to our broader recommendations, we see significant opportunity for transformation in the areas of building performance, financial incentives, stronger codes, and standards as well as in training and certification.
1. BUILDING PERFORMANCE
The province is proposing a building energy performance rating or labelling system so renters and buyers can compare operating and upgrade costs. We support the development of a labelling requirement, but believe it must include the following considerations:
A. Labelling Methodology
A rating system to compare buildings must provide enough useable data for building owners to take action on energy efficiency improvement.
Comprehensive and actionable data can be acquired using a robust energy audit, such as Natural Resources Canada’s EnerGuide, however this is costly. In addition, EnerGuide prohibits service organizations from delivering energy retrofits which diminishes overall accountability for achieving savings. We know from our experience that a one-stop-shop approach with builtin measurement and verification protocols motivates clients and achieves real results.
B. Energy Data Access
Labelling programs can generate robust ratings only if they analyze current building energyconsumption data. Government leadership is needed to create systems to easily access energy data while respecting privacy concerns.
C. Pathways to Improvement
We believe building labelling can spark meaningful action on energy efficiency only if there are strong energy performance standards for existing buildings and clear actions for building owners to take. On its own, building energy performance may not be a priority in the expensive B.C. lower mainland and Vancouver Island markets or in rural locations where many renters and buyers struggle to cover basic housing needs.
2. FINANCIAL INCENTIVES
Our decades of experience designing and delivering energy efficiency programs have shown us that financial incentives are crucial in the development of an energy efficiency industry. However, they must be consistent and longer term, so industry and consumers can plan ahead.
A. Measure-Based Incentives
Measure-based incentives promote the installation of particular technologies and which may not be the most cost effective and impactful approach to improve efficiency and reduce emissions. For example, buildings with very poor envelopes should only be fitted with heat pumps after the envelope issues are addressed. Incentives must address these matters holistically to ensure the most effective use of resources.
Our preference is to see a change towards performance-based financial incentives to ensure that appropriately prioritized and targeted measures are actioned.
B. Coordination of In-market Incentives
We would like to see greater coordination of financial incentives offered from different levels of government, to help consumers and industry in terms of application process, application deadlines and requirements for eligibility.
C. Free-Ridership and Equity
Too often financial incentives for energy efficiency are accessed by affluent people who tend not to occupy the least efficient buildings and would invest in the particular technology regardless of the incentives. We recommend pairing incentive access with ratings from the labelling program, ensuring that buildings with the lowest ratings qualify for the most incentives, as least efficient buildings are often occupied by less affluent people.
3. STRONGER CODES AND STANDARDS
We strongly support the development of stronger codes and standards for building performance and would like to highlight the following important factors:
A. BC Energy Step Code
We welcome the use of the Step Code as a performance standard but have found that Northern communities that want to adopt it feel ill-prepared for the transition. We would like to see more government funding support for Northern communities, builders and developers (particularly for zones 7A&B and 8).
B. Codes and Standards for Older Buildings
The Canadian Federal Government is developing a building code for existing buildings in the next 4 years, and the Province of BC intends to produce a similar provincial code in the 2 years following its release. This will equal 6 years of inaction on requiring energy efficiency improvements in existing buildings undergoing retrofitting. We urge the government to work with municipalities to require compliance with newer codes at time of retrofit, so that the province doesn’t miss out on opportunities to reduce the majority of its buildings’ energy consumption.
C. Enforcement of Codes and Standards
Even buildings built to the highest energy performance standards rarely perform as designed upon completion, so new building codes should be rated and enforced with regards to energy performance and when commissioning of new buildings.
4. TRAINING AND CERTIFICATION
Training and certification are crucial components of the professionalization of the energy efficiency industry. We would like to stress the following in the design of any certification process:
A. Organization-Level Certification
Training and certification for energy retrofit professionals is better if it happens at an organizational level rather than at trade-level, as this would address the existing siloing between various trades and the lack of accountability on the delivery of energy savings.
To sum up, we are enthusiastic about the opportunities to improve and innovate in BC’s energy efficiency sector that may be brought on by a Clean Growth Strategy that includes mechanisms for professionalization of the industry, encouraging holistic approaches to energy efficiency and inclusion of equitable, flexible incentive structures. We will follow the process closely and look forward to a pathway for the Province that includes both significant action on climate change and sustainable economic development.