Submission in Response to the Clean Growth Intentions Papers

(Clean, Efficient Buildings)

August 24th, 2018

Kambo Energy Group | kambogroup.ca | info@kambogroup.ca

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About Us

Kambo Energy Group is an energy efficiency collective that delivers turn-key solutions for commercial buildings and residential communities. With the mission to use business as a tool to do good, Kambo Energy Group builds holistic energy efficiency programs with a focus on the end user realizing real and measurable energy savings. Kambo Energy Solutions, Community Power and Empower Me are the core client-centric brands that operate as divisions of Kambo Energy Group.

• Empower Me delivers energy efficiency education and services to underserved residential clients

• Community Power delivers energy efficiency services to indigenous communities • Kambo Energy Solutions delivers energy efficiency services to commercial clients

General Comments As an organization at the forefront of energy efficiency market innovation, we have three key concerns and comments with regards to the future of the energy efficiency industry in BC. We outline these core concerns below, then discuss their specific application to the Province’s Intentions Paper in the following section.

Firstly, we see the professionalization of the energy efficiency industry as a necessary step towards better accountability and the delivery of meaningful energy savings. In this regard, we see organizational accreditation, and an insistence on monitoring and evaluation work as crucial to the creation of robust and effective industry. We hope the Province supports this key transition in BC’s energy efficiency industry by creating incentive structures and accreditation systems in ways that enable the industry to creatively organize itself and design energy efficiency programs that respond to the needs of different market segments.

Secondly, we recognize that for large parts of the market, the main barriers to energy efficiency action remain unaddressed when prescriptive programs and financial incentives are the only tools deployed. As an organization we address some key barriers in the implementation of energy efficiency measures by offering turn-key solutions to our customers. By functioning as a one-stop-shop for energy efficiency we make the process simple for clients so they don’t have to manage multiple professionals from auditors, to general contractors and HVAC trades, during the course of an energy retrofit. Furthermore, by combining these various steps, we make one organization responsible for delivering projected energy savings, creating accountability in an industry that has seriously lacked it.

Thirdly, as an organization focused on delivering energy efficiency services to underserved markets, we recognize the need for designing incentive structures that are equitable, inclusive and flexible so that communities and the industry can collaborate on the design of programs that address their specific needs.

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Specific Comments in Response to the Province’s Intentions Paper (Clean, Efficient Buildings)

LABELLING REQUIREMENTS The province proposes introducing a requirement for buildings to disclose an energy performance rating at point of sale/rent. This requirement is being proposed with the intention of allowing renters and buyers to compare buildings and their full operating costs as well as consider the value of energy efficiency upgrades. The province also sees the approach as valuable in collecting data that can be used in estimating the energy performance of the current building stock and the design of future programs.

We support the development of a labelling requirement, but consider the following considerations important for the design of an effective labelling program:

1. Labelling Methodology The province cites the example of Scotland’s rating system in its Intentions Paper but does not define what methodology it might consider for the labelling program. We see the methodology ultimately chosen as the crucial determinant of the success of such a program. Scotland’s rating system is known in the industry for the creation of comparable ratings among buildings and informing economy-wide policy decision. However, this methodology does not provide comprehensive and useable data for building owners for taking action on energy efficiency improvement. More comprehensive data can be acquired using a more robust and comprehensive energy audit, such as those used in Natural Resources Canada’s EnerGuide evaluation and rating system. However, these more comprehensive audits tend to be costlier. Furthermore, EnerGuide audits can currently only be delivered by service organizations which are forbidden from also delivering energy retrofits. As an organization committed to the delivery of turn-key solutions that remove key barriers to taking action on energy efficiency improvement, we consider it very important to be able to carry out audits and analysis as well as deliver recommended measures, creating one-stop-shop solutions for our customers. We believe that the requirement for separation of the analysis and implementation steps of energy efficiency work in the EnerGuide system is detrimental to the creation of an energy efficiency industry and market innovation in the residential energy efficiency sector, and as such

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would urge the government to consider only using the EnerGuide methodology for their labelling program if this requirement is removed and any conflict of interest is, instead, managed through monitoring, evaluation and performance standards for the industry.

2. Energy Data Access Labelling programs can generate robust ratings only if they analyze current energy consumption data for the buildings that they label. However, accessing energy consumption data for our customers is currently quite onerous – this is particularly true for access to BC Hydro data for residential accounts, due to privacy requirements. Government leadership is particularly needed to create systems for accessing energy data across multiple utilities that, while respecting privacy concerns, enable easy and secure access to energy data for analysts in the industry.

3. Pathways to Improvement We believe building labelling is likely to spark meaningful action on energy efficiency, only if it is tied to pathways for improvement made available to building owners and/or strong energy performance standards for existing buildings. On its own, particularly in real estate and rental markets such as those in the B.C. lower mainland and Vancouver Island, building energy performance is not likely to be seriously entertained by potential renters and buyers who are often navigating availability and affordability challenges. As a result, the availability of energy performance information may not spark market transformation, unless strong performance standards are introduced for existing buildings and/or financial incentives are made available to the lowest performing buildings (please see the sections below for more on this idea).

FINANCIAL INCENTIVES In our decades of experiencing designing and delivering energy efficiency programs in the UK and Canada, we have come to regard consistency in terms of availability of financial incentives as a crucial factor in the development of an energy efficiency industry. The introduction of financial incentives for particular measures have known to help create particular services and industries which then disappear once the incentive is removed. For this reason, we prefer seeing consistency in the availability of incentives so both the industry and consumers can plan for implementing energy efficiency measures.

1. Measure-Based Incentives Measure-based incentives promote the installation of particular technologies, rather than creating an incentive to invest in the most appropriate energy efficiency measure for the particular building. For example, all too often we see buildings with poor

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envelopes outfitted with heat pumps, because a financial incentive for the installation of heat pumps has been available. In the energy efficiency industry we aim to understand buildings as a system and develop holistic solutions that consider the entire system. Measure-based incentives, in our experience, discourage this kind of holistic problem solving and promote the installation of, at times, ineffective and inappropriate measures. For this reason, we would like to strongly encourage the government to consider implementing performance-based financial incentives, so the most appropriate measures for every context can be considered. Performance based incentives, in our view, promote not only more effective solutions, but also promote the creation of an energy efficiency industry that is invested in delivering meaningful results.

2. Integration of Financial Incentives Across Different Jurisdictions Where multiple jurisdictions such as municipalities and Provincial and Federal governments offer financial incentives for energy efficiency investment, we would like to see greater coordination between these jurisdictions in terms of application process, application deadlines and requirements for eligibility.

3. Free-Ridership and Equity Too often financial incentives for energy efficiency are accessed by affluent people who do not occupy the least efficient buildings and would invest in the particular technology regardless of the availability of incentives. In fact, the literature on energy efficiency incentives documents high rates of free ridership in such programs. In order to achieve meaningful energy savings through the financial incentives program, we would recommend pairing incentive access with ratings from the labelling program, ensuring that buildings with the lowest ratings qualify for the most incentives. Not only will such program design elements ensure the realization of the energy savings desired by incentive programs, they will also ensure equitability concerns are addressed, since least efficient buildings are often occupied by less affluent people.

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 with regards to this work:

1. BC Energy Step Code The transition from voluntary use of the Step Code to its use as performance standard for new buildings is a welcomed one. However, while there is much enthusiasm and work on its adoption in southern BC, in our work with Northern communities we have found that communities that want to adopt the ESC feel ill-prepared for the transition.

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We would like to encourage the government to pay special attention to creating funding support for northern communities, builders and developers (particularly for zones 7A&B and 8) in this transition.

2. Codes and Standards for Older Buildings Waiting for the release of the Federal government’s existing building code amounts to inaction on this important opportunity to reduce energy consumption and GHG emissions in the province for six years. We urge the government to work with municipalities to find opportunities to require compliance with newer codes at time of retrofit, as condition for access to retrofit funding, etc. so that the province does not miss out on the opportunity to reduce the majority of its buildings' energy consumption for six years.

3. Enforcement of Codes and Standards and Building Commissioning The introduction of energy performance metrics as part of the building code, in our opinion, should be paired with mechanisms for code enforcement with regards to energy performance and the commissioning of new buildings. Buildings, including those built to the highest energy performance standards, rarely perform as designed upon completion. This is particularly true for buildings with innovative and complex technological systems. Appropriate building commissioning is, therefore, an important step in realizing the savings projected in the design of codes and standards.

TRAINING AND CERTIFICATION We consider training and certification as crucial components of the professionalization of the energy efficiency industry. We would like to stress the following in the design of any certification process:

1. Organization-Level Certification While better certification and training for individual trades involved in the implementation of energy efficiency measures can go some ways towards the professionalization of the industry, we worry that trade-level certification will not address the siloing between various trades and the lack of accountability on the delivery of energy savings. To address this siloing effect and manage the ever-changing landscape of trades involved, and to encourage greater accountability in the industry in terms of delivering energy savings, we prefer organizational-level certification for energy retrofit professionals.