September 14, 2015

Canada Green Building Council Climate Leadership Plan Discussion Paper Submission Introduction The Government of British Columbia has demonstrated strong leadership in addressing climate change by committing to reductions in carbon emissions. In particular, the carbon tax, clean energy requirements and the low-carbon fuel standard were introduced under Climate Action Plan. The BC Government also has been recognized as a national and international leader in green building policy and development as all provincially-funded projects need to achieve LEED® Gold certification. This has contributed to the path towards sustainability with over 400 projects certified – the equivalent of 4,271,508 square metres. At this point in time, British Columbia has the opportunity to champion new initiatives to curb greenhouse gas emissions and mitigate the impacts of climate change. The Canada Green Building Council (CaGBC) is a not-for-profit, national organization that has been working since 2002 to advance green building and sustainable community development practices in Canada through market-based solutions. We are an industry-led organization providing value-added solutions that benefit the environment, economy and public health. We manage the Leadership in Energy and Environmental Design (LEED) rating system in Canada which is recognized as the international mark of excellence for new and existing green building in over 200 countries. Our reach is enhanced by the work of eight provincial Chapters that provide regionally tailored market education and advocacy. What follows are the CaGBC’s recommendations related to the built environment which can be found in two of the areas of the Climate Leadership Plan Discussion Paper: ‘the way we live’ and ‘the way we work’.

‘The way we live’ National and international organizations (e.g. UNEP SBCI, World Economic Forum, World GBC), have recognized for some time that buildings offer some of the greatest potential for achieving significant energy and GHG emission reductions, at the least cost and significant return on investment.1 Heating, cooling and lighting buildings accounts for 11 per cent of the province’s carbon emissions. At the municipal level, cities like Vancouver attribute 55 per cent of their emissions to the built environment. Making large structures – office towers, institutions, and apartment buildings  more energy efficient is one of the most cost-effective and readily available means of addressing climate change.

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The Business Case for Green Building. See: http://www.worldgbc.org/files/1513/6608/0674/Business_Case_For_Green_Building_Report_WEB_2013-04-11.pdf

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Recommendations Introduce a mandatory energy benchmarking and disclosure program. The Government of British Columbia is already committed to reducing energy consumption and eliminating greenhouse gas emissions that result from operations of its own buildings. While there is a good deal of momentum toward energy conservation, lack of data and data transparency is a consistent challenge that can inhibit the success of conservation programs. We lack information about how buildings are performing, which ones perform badly and why. Benchmarking and reporting is a critical first step in operating and/or retrofitting existing buildings to higher, more efficient standards. Energy benchmarking, reporting and disclosure requirements help overcome the data transparency challenge. Building owners use a common tool to calculate energy use and compare their building’s consumption against other buildings, and against themselves over time. Reporting energy use to a government body ensures that policy makers have the information they need to develop programs which address inefficiencies. Public disclosure of data provides information to owners and tenants, incentives to take action and can help guide investment decisions. CaGBC is proposing a province-wide approach to benchmarking, reporting and disclosure that builds upon ‘lessons learned’ from the United States and Europe. A province-wide benchmarking initiative would provide uniformity to requirements to building owners across British Columbia and aid in implementation by local governments. British Columbian cities range significantly in size and capacity to develop and deliver complex environmental policies. A province-wide initiative would provide that much needed impetus and capacity to participating communities as well as remove barriers to engaging local building owners to follow these requirements. The CaGBC also encourages the province to look beyond its borders and consider harmonizing its program nationally with efforts in other jurisdictions (e.g. Toronto, Ontario). This will allow owners with portfolios in many cities across the country to benefit from a consistent approach to managing energy use across portfolios. The CaGBC is leading a consultation process to develop principles for energy benchmarking and reporting that can be applied nationally. We would like to encourage the participation of the provincial government. The results will be shared through a suite of activities (including a White Paper in 2016) that would be valuable resources to the BC Government as it shapes a provincial benchmarking initiative. Prioritize a pathway (beyond energy consumption) to low impact buildings. The Government of BC should consider policies, research and practices for all new building construction in BC to meet the highest energy efficiency standards and lowest carbon footprint. The movement to minimize the consumption of energy in new residential and non-residential buildings is a priority. However, holistic approaches to building design and construction including water efficiency, waste recycling and material selection are also vital in creating low carbon, healthy buildings and communities. With regard to energy efficiency, we encourage the government to pursue key policy levers such as the building code. We support provincial multi-tiered performance-based stretch codes that local governments can adopt. 2

However, a reminder that this is about more than energy efficiency: consider the depth and breadth of options available to reduce carbon emissions. Carbon is embedded in decisions regarding materials, water and waste. According to Architecture 2030, up to 15-18 per cent of a building’s carbon footprint is associated with construction materials.2 The government should leverage existing programs that produce low impact buildings. For example, the LEED program in British Columbia has demonstrated what is possible when it comes to the development of low carbon intensive buildings. This has resulted in some of the most advanced and globally recognized sustainable buildings and communities in the world (e.g. 2010 Olympic Village, Dockside Green, UBC CIRS, Telus Garden). Create incentives to increase energy-efficiency upgrades and retrofits While new construction is important to reduce future environmental impacts, the biggest current challenge and opportunity exists in the retrofit market and improving existing building stock. As such, there has been a growing focus on improving the operation and management of existing buildings for reducing energy consumption and GHG emissions. Programs such as LEED for Existing Buildings Operations and Maintenance (EB:O&M) are helping to drive activities in this space, particularly in the non-residential sectors. LEED EB:O&M requires owners to apply advanced building operation, maintenance and retrofit practices to improve the performance of buildings. Minimum requirements for and measurement of energy is a key requirement for a LEED designation. Recertification is required every five years to ensure performance is maintained or enhanced. In addition, building codes and various incentive programs are increasingly focusing on the retrofit opportunity for existing buildings. As one example, the Toronto Atmospheric Fund’s green loan program has helped encourage energy efficiency retrofits in Ontario.3 While improvements in technology can lead to lower energy use, it is critical that new technology improvements are accompanied by benchmarking, commissioning, training for operations staff and tenant engagement programs.

‘The way we work’ The global green and sustainable building industry is forecast to grow at an annual rate of 23 per cent between 2014 and 2017.4 Countries around the world are actively supporting and investing in their green building sectors, knowing that developing domestic leadership can help to position them for greater economic development, job creation, and for capitalizing on the export market growth opportunities. British Columbia has a particular opportunity to retain its place as a leader among Canadian provinces with regard to green building. In 2014, 2.5 per cent of the labour force in the province was employed in the green building sector. (This is the equivalent of 61,000 jobs.) Additionally, over $4.750 billion dollars in green building construction can be attributed to the GDP.

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Architecture 2030. Roadmap to Zero Emissions. http://architecture2030.org/files/roadmap_web.pdf Toronto Atmospheric Fund. TAF makes Sustainability Affordable. http://www.c40.org/case_studies/toronto%E2%80%99satmospheric-fund-makes-sustainability-affordable 4 Dodge SmartMarket Report. World Green Building Trends Smart Market Report. http://construction.com/about-us/press/worldgreen-building-trends-smartmarket-report.asp 3

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British Columbia has an enormous opportunity to do more in order to grow its green building sector, become an international leader, and further seize the strategic opportunities tied to investments, job creation, and exports. The building and housing market remains the biggest untapped opportunity for economic development and job creation. What will be required is a strategic approach at the provincial level that involves investing in innovation and industry development as well as training the new workforce with the skills they need to propel the green building sector forward. Recommendations Invest in research and development for the green building sector. The construction sector in general (particularly in North America), has a poor record for investing in research and development (R&D). In Canada, construction ranks at the bottom of all industries in terms of its R&D expenditures. Productivity levels have also suffered due to the lack of innovation over time. Not only does construction lag behind other sectors in Canada, but when compared against international competitors, Canada ranks quite low and the amount of R&D investment in construction has been stagnant since 2001.5 The circular economy, cradle-to-cradle, and biomimicry concepts show potential for being integrated into practice in order to optimize resources and minimize waste. Room to innovate on the materials side is a key opportunity for BC as the industry shifts to a lifecycle assessmentdriven approach in sustainable building design. For example, wood-related structural technologies (e.g. cross laminated timber (CLT)) and products (e.g. windows, insulation) represent a unique opportunity for BC. Enhance training for trades and operations staff. Green building requires more professional expertise and a better trained workforce. Research in 2012 by the BC Institute of Technology (BCIT), British Columbia’s largest educational institutional for construction trades training, identified approximately 20 learning outcomes related to green building that are currently missing from the training curricula of most construction trades. For some trades such as plumbing and electricians, the number of missing learning outcomes added up to more than 50. What is currently lacking is a multi-pronged approach to training that supports all of the different programs to help the industry understand, design and build greener buildings. Beyond these, there are two significant areas where gaps in education and training currently exist as it relates to green buildings: The first one is building operations. The evolution of green, smart and connected buildings means that structures are increasingly becoming sophisticated computers. Currently, there is a dearth of qualified building operators; essentially someone with a hybrid set of skills with experience on both the mechanical side of building maintenance and the operational side that includes ICT and software systems. Firms such as Bentall Kennedy and Manulife Real Estate have taken the initiative to develop their own “apprenticeship” program for bright young technical 5

Delphi Group. Green Building in Canada: Assessing the Economic Impacts and Opportunities. (Draft form and not available online till November 2015.)

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folks as opposed to trying to re-educate traditional operators that have moved up from managing a multitude of services. More is needed in this space to support structured and modernized internship, mentorship, or apprenticeship programs for skilled building operators. The second area where training is required is in the area of building permitting and inspections. Quality assurance of sustainable design and construction practices and technologies that improve building performance is typically out of the realm of permit officials and building inspectors; as they are exclusively focused on health and safety issues. Code interpretations can be challenging because building inspectors will usually only allow explicit technologies and solutions described in the building code and may not be knowledgeable on more advanced or higher performing solutions as they relate to green buildings. This gap is currently being filled by green building rating standards and certification programs where qualified professionals review and verify advanced practices and technologies. As such, there is a need for training of officials consistent with current improvements to the provincial Building Code and growth of green building construction in the commercial and institutional real estate sector.

Conclusion In the global context, urban environments (cities) are responsible for over 70 per cent of global GHG emissions.6 British Columbia has an opportunity to set the tone for Canada’s action on climate change on the world stage and at home by creating an ambitious, impactful and economically resilient plan for the build environment. As experts in Canada on sustainable building practices and policies, the CaGBC welcomes further opportunities to assist the government with its strategy for existing and new commercial, institutional and residential construction.

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United Nations. World Urbanization Prospects . 03 2012. http://esa.un.org/unup/pdf/WUP2011_Highlights.pdf (accessed 01 15, 2014).

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