Living In Toronto

Energy Reporting and Benchmarking



Update #5: EWRB regulation now official

The Ministry of Energy has enacted the Energy and Water Reporting and Benchmarking (EWRB) requirement for large buildings (i.e. greater than 50,000 square feet).

Starting in 2018, privately owned commercial, multi-unit residential and some industrial buildings will report annual energy and water consumption and performance data using ENERGY STAR Portfolio Manager. 

More information about covered buildings and reporting deadlines can be found by visiting Ontario's Ministry of Energy website.

 Update #4: Notice of Proposed Regulation

The Ministry of Energy is proposing to implement an Energy and Water Reporting and Benchmarking (EWRB) regulatory requirement for large buildings. The proposed regulation would proceed pending passage of proposed legislative amendments to the Green Energy Act, 2009 (Bill 135) introduced by the government on October 28, 2015 to enable the implementation of an EWRB initiative.

Stakeholders can provide comments on the proposal by April 10, 2016.

Details about the proposed regulation and how to provide comments can be accessed by visiting Ontario's Environmental Registry.

Update #3: Notice of Public Hearings

The Province of Ontario is hosting public hearings on February 22nd & 24th with regards to Bill 135, Energy Statute Law Amendment Act. The Act seeks to amend, amongst other things, the Green Energy Act to enable a future Energy Reporting and Benchmarking regulation in Ontario.

Interested stakeholders can make an oral presentation or provide a written submissions to the General Government Committee. More information can be found here.

The City of Toronto continues to work alongside the Ministry of Energy as it develops an ERB regulation. At this time, a Toronto-specific ERB requirement is not being proposed.

Update #2: City Council Direction

On June 22, City of Toronto staff presented to the Parks & Environment Committee an update on research and stakeholder activities completed as well as potential ERB policy considerations.  While a Toronto specific by-law was not recommended,  the City will continue to be engaged with the Ontario Ministry of Energy as it considers a province-wide regulation and holds additional consultations.

After receiving the staff presentation for information, the Parks and Environment Committee recommended that:

1.  City Council maintain its commitment to an energy reporting and benchmarking requirement for large commercial and multi-residential buildings, as a strategy for achieving the City's energy conservation and greenhouse gas emission reduction goals, as previously adopted by City Council on November 30, 2009 with The Power to Live Green: Toronto's Sustainable Energy Strategy [EX36.9.]

2.  City Council direct the Chief Corporate Officer to report to the Parks and Environment Committee on the City's plan to support the implementation of a Provincial energy reporting and benchmarking regulation, or alternatively, on the City's own energy reporting and benchmarking by-law and implementation plan, should the Province not proceed with a regulation by December 31, 2015.

City Council will consider this item and recommendations at its July 7, 2015 meeting.


Update #1: Stakeholder Consultations

Policy Development Consultations: Summary Report (Integral Group)

The Province of Ontario and the City of Toronto undertook a series of consultation activities in January through April of 2015, soliciting stakeholder feedback for a proposed energy benchmarking and reporting requirement. Integral Group was retained to facilitate the consultation effort on behalf of the Province and the City. This report summarizes the three phases of the consultation, and stakeholder feedback from each session, along with written comments received via e-mail between January and May 2015. This report is limited to the specified period, and excludes the outcomes of any further discussion with stakeholders that may take place as the proposed policy framework evolves over time.

ERB Best Practices Summit

On March 24, 2015, the Province of Ontario and City of Toronto hosted the Energy Benchmarking and Reporting Best Practices Summit, with sponsorship from BOMA Toronto.

The purpose of the summit was to provide information to stakeholders, about the different elements, impacts and benefits of energy benchmarking programs and policies as experienced by other jurisdictions and agencies.

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The Province of Ontario and the City of Toronto are jointly consulting on a potential mandatory energy reporting and benchmarking requirement for large commercial and multi-unit residential buildings, where owners could be required to annually report on their building’s energy and water consumption and greenhouse gas (GHG) emissions.

The initiative is aligned with the Province’s and the City’s objectives to reduce energy use and GHG emissions.

Energy Reporting and Benchmarking (ERB) would facilitate the review of a building’s energy use against its own past performance, and the performance of similar buildings. With this knowledge, building owners and managers may be motivated to improve the energy efficiency of their buildings. 

The Province and the City would also have a clearer picture of how buildings use energy and which building sectors offer the most opportunity for improvement. This information could be used to target incentives and retrofit initiatives toward the areas of greatest potential benefit.

The Province and the City are working together to consult with stakeholders. If the Province should decide to proceed with a regulation, the City will re-evaluate the need to continue its efforts to develop a by-law.  Building owners and managers would not be subject to duplicate reporting requirements.

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In its 2013 Long Term Energy Plan, the Province committed to putting conservation first before building new generation and transmission infrastructure, where cost-effective.

Ontario’s Long-Term Energy Plan

In the Province’s July 2013 Conservation First White Paper it is noted  that rating systems for buildings could allow consumers to benchmark the relative energy efficiency of various properties and inform their investment decisions.

Conservation First: A Renewed Vision for Energy Conservation in Ontario

The City's Parks & Environment Committee adopted Item PE26.3 which directed City staff to investigate establishing a mandatory 'Annual Energy and Water Utilization Reporting Requirement' for large buildings.

City of Toronto Parks & Environment Committee Agenda Item PE26.3: Energy Reporting Requirement for Large Commercial and Multi-Residential Buildings

An interim status report was received by Parks & Environment Committee and City Council in August 2014.

City of Toronto Agenda Item PE29.2 Update - Energy Reporting Requirement for Large Buildings

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How would an Energy Reporting and Benchmarking requirement work?

The two main components of a potential ERB initiative would be:

  1. Reporting and benchmarking: Owners of affected buildings could be required to report building characteristic and resource utilization data to the Province or City in a prescribed format. The parameters for reporting might include: address, year built, gross floor area, energy and water consumption, GHG emissions, and an efficiency rating or score.  To facilitate the benchmarking process, building owners/managers could use a tool such as the Energy Star Portfolio Manager to achieve a score or rating.
  2.  Disclosure: Building data and benchmarking results could be disclosed on an annual basis. The extent of disclosure can vary – from limited disclosure, for example, the names of the building owners subject to the reporting requirement, to full disclosure of a building's energy intensity rating on a public website.  Another approach could be to disclose energy reports on a transactional basis only, for example, to a prospective buyer at the time of sale.

Related policy documents and directives

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Phases of the Review

Phase 1: Research & Analysis – April 2014 to November 2014
Phase 2: Joint Stakeholder Consultations - December 2014 to April 2015
Phase 3: City of Toronto to Report to Council – Summer 2015
Phase 1: Research & Analysis
April to November 2014
During this phase, an Opportunity Screening Study was conducted to determine the potential of ERB requirements in Toronto. This phase included a scan of ERB requirements in other jurisdictions and modelling of the potential environmental, energy and economic impacts of an ERB requirement in Toronto here.
Phase 2:  Joint Stakeholder Consultations
December 2014 to April 2015

Stakeholders and the public were engaged to identify issues and opportunities in Ontario and Toronto for ERB requirements.  The types of policy questions under review include: What is an appropriate inclusion threshold based on building size? Would a phased approach to implementation achieve higher compliance rates? What training and capacity building would be needed to support an ERB requirement?

Stakeholder input was received through consultations, interviews, and policy workshops. Additionally, a summit was held on March 25 as an information sharing opportunity to learn of best practices in U.S. jurisdications. A link to the summit video can be found here.

A final report was produced on the outcomes of stakeholder consultation which highlights the key policy findings.

Phase 3: City of Toronto to Report to Council
June 22, 2015

City staff will provide an update presentation to the City's Parks & Environment Committee. The presentation will highlight research and engagement activities completed as well as potential ERB policy considerations.

At this time, City staff is not recommending an ERB by-law for Toronto. The City will continue to be engaged with the Ontario Ministry of Energy as it considers a province-wide regulation and holds additional consultations.

Written submissions and deputations can be made by the public on the agenda item PE4.2, available here

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Key Terms

Benchmarking: Energy benchmarking compares a building’s energy performance in several ways:
  1. Against past energy performance
  2. Against similar buildings within a portfolio
  3. Against an external data set of comparable buildings
  4. Against areas in the same building

The purpose is to evaluate or compare performance against past performance or against peers to identify high performance buildings and opportunities to save energy.

Reporting: Benchmarking policies often require building owners to share their energy, and water consumption and GHG emissions with a city, province or state. Most policies allow this data to be shared electronically to make reporting easier for owners.

Disclosure: The sharing of building energy, water and GHG emission benchmarking data with the public. Disclosure can be managed in different ways to achieve different outcomes and address potential concerns.

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