Senior Policy Advisor
Ministry of Energy
77 Grenville Street
Re: Regulatory Proposal for Province-Wide Implementation of Green Button (EBR 013-1874)
Please accept the following as the joint submission by The Atmospheric Fund (TAF) and the Building Energy Innovators Council (BEIC).
Overall, we are excited to see the development of a policy supporting the expansion of Green Button throughout Ontario. Implementing the Green Button program across the province will help increase energy efficiency and thereby reduce greenhouse gas emissions for all types of homes and buildings. TAF and BEIC would like to make the following recommendations regarding the regulatory proposal supporting the implementation of Green Button within the province:
Under the current proposed regulation, utilities are allowed to recover Green Button implementation costs through utility rate increases, subject to the OEB’s existing requirements regarding economic prudence and cost-effectiveness. The proposal also grants the OEB permission to extend the compliance deadline to utility companies upon request. We are concerned that the combination of the rate increase and extension requests will lead to unintended consequences and delay the implementation of Green Button. For instance, should a utility company request a rate increase to recover compliance costs and should the request be rejected by the OEB, the utility could then counter by asking for a compliance extension, which would most likely be granted given the previous rate increase rejection.
TAF and BEIC recognize the difficult balance of protecting consumers from unreasonable rate increases while facilitating Green Button compliance. There are several potential solutions that could mitigate the unintended consequence outlined above.
First, we encourage the Ministry of Energy to implement a ban on compliance extensions for large utility companies. The top ten largest electricity utility companies in the province serve approximately 73% of the buildings/homes in the province . Many of these largest utility companies already have the ability to comply with the Green Button policy, while smaller companies may require extra time to implement the required changes. By requiring the largest companies to comply with the Green Button program by the 2020 deadline, the Ministry will be able to ensure that the vast majority of Ontario’s buildings are provided with their valuable energy data in an easily accessible and timely manner.
Second, we recommend that the Ministry of Energy set up an implementation working group to establish best practices and facilitate collaboration to reduce the cost of implementation for utility companies. By organizing information sharing and facilitating the establishment of best practices, the working group could help prevent excessive compliance costs and reduce cost recovery rate increases passed onto consumers. The working group could also facilitate the integration of Green Button data into the market place and uptake by third party applications.
TAF and BEIC believe that, if implemented effectively, the proposed Green Button Regulation will be able to facilitate greener operation of homes and buildings. A key part of this is ensuring successful roll out of the program. As such, we have developed several recommendations that will support widespread uptake of Green Button data use:
First, we recommend that the Ministry champion granular and short interval data submissions from utility companies. We understand that there likely exist technological feasibility challenges for smaller utility companies and differences between gas and electricity utilities. However, the closer customers are to real-time granular data, the more control they have over their home’s/building’s energy consumption.
Second, we recommend that the Ministry of Energy collaborate with other ministries to ensure promotion and support for Green Button and the development of programs and applications that use it. The success of the Green Button program hinges on the development of accessible and affordable applications and programs that use Green Button Data. To ensure the Green Button program achieves significant energy reductions, it is important that the data provide insights that, when communicated to the customers, spark meaningful changes whether through home retrofits or behavioural changes. We see several opportunities to engage with the civic tech community, such as through hosting hackathons or providing educational outreach programs for home and building owners to support behaviour changes and retrofits.
When it comes to Green Button Connect My Data, we recommend making the data sharing authorization processes and documents as customer centric and user-friendly as possible. Customers should be able to easily and quickly authorize the sharing of their home or building energy data in a few simple steps. This would increase the likelihood of utility customers sharing their data with third party companies, an important component for Green Button’s success. If the process of granting data sharing to third parties is too complex, customers will likely opt for the default and easier option: to not share their energy data.
Another important factor in the success of Green Button will be the price at which third party companies sell their products and services to help customers achieve energy savings. We recommend that the Ministry collaborate with third party companies early on regarding roll out plans for Connect my Data in order to facilitate quick uptake and ensure cost effectiveness. By reducing their operating costs, third party companies are able to sell their products and services at more affordable prices to utility customers. If the price is too high, customers will not benefit from third party recommendations on how to improve their energy efficiency and reduce energy consumption. This behaviour was observed during some of the Green Button pilot studies. Keeping third party offerings affordable is a critical component in ensuring broad uptake of the Green Button program.
Finally, while TAF and BEIC recognize the implementation and cost challenges associated with the inclusion of water utilities in the Green Button proposed regulation, we recommend the inclusion of large water utilities at a later date. Including water data in the Green Button program would allow building owners to have one consolidated data source to comply with the incoming Reporting of Energy Consumption and Water Use regulation. This would ease compliance by reducing the amount of effort required by building owners. Additionally, it would ensure consistent data reporting as the Green Button data methodology would be the same among gas, electricity, and water.
TAF and BEIC would like to thank the Ministry for the opportunity to provide comments regarding the regulatory proposal for the implementation of Green Button and would welcome the opportunity for further collaboration to ensure the successful rollout of the Green Button Program.
Director of Policy & Programs
The Atmospheric Fund
Chair of the BEIC
Building Energy Innovators Council
About The Atmospheric Fund:
The Atmospheric Fund (TAF) is a public agency established in 1991 by the City of Toronto and endowed by the City and the Province of Ontario. TAF works closely with stakeholders across the Greater Toronto and Hamilton Area (GTHA) to test and advance innovative programs to reduce greenhouse gas (GHG) emissions and air pollution. However, the views expressed in this submission do not necessarily represent those of the City of Toronto, the Province of Ontario or other GTHA stakeholders.
About the Building Energy Innovators Council:
The Building Energy Innovators Council (BEIC) is a membership organisation that was founded by a diverse group of Real Estate and Corporate leaders. The BEIC is an industry driven council working together with stakeholders to accelerate innovation and adoption of clean building technologies in Canada. This includes energy efficiency products and services as well as renewable power solutions that will transform the built environment while developing world class clean tech companies, creating jobs, and enabling economic prosperity in a future low carbon era.
[Original Comment ID: 212195]
Submitted February 15, 2018 3:08 PM