Comment
I work with a government agency responsible for the operational control of buildings and facilities on behalf of a wide range of ministries in Ontario.
1)
I think the definition of "energy" all inclusive enough so as not to exclude any form of energy like water.
2)
Combining the complex ownership and management structures with the GHG reporting protocols would give some problems with data accessibility for building owners
For example: Entity A owns 500 buildings, but the day-to-day management of these facilities are subcontracted to several service providers (Entities B-H) who are responsible for the payment of utilities and are reimbursed by Entity A
The account holders in this case will be Entities B - H, but as per some leading GHG reporting protocols, the owner of the building is responsible for GHG reporting.
Defining the “account holder” as a person or entity who has an account with an energy provider, might make it difficult for the building owner to get access to their energy data.
I understand there is a process already in place for providing third-party access to a buildings utility consumption data, but this might be quite cumbersome for an owner with multiple assets spread across the province with several utility service providers.
3)
Data should also be available at hourly,daily and monthly intervals, depending on the type of energy data analysis required.
[Original Comment ID: 211416]
Submitted February 15, 2018 3:02 PM
Comment on
Regulatory proposal for province-wide implementation of Green Button
ERO number
013-1874
Comment ID
2696
Commenting on behalf of
Comment status