Thank you for the…

Thank you for the opportunity to comment on the proposed changes to O.Reg.506/18, Ontario’s Energy and Water Reporting and Benchmarking program. However, I would suggest that future notices, even those that are “voluntary”, contain a link to information on the regulation and program proposed to be altered.
It was surprising that after five years of the regulation being in place, no data are presented in this notice (or as an attachment to the notice) to establish the need for this change. How many facilities now comply with the regulation? What proportion of those subject to the regulation seek an exemption on an annual basis? How many of those have complained about the process of getting an exemption as being “too onerous”? Is there really a need to make this change?
The proposal to require no documentation to support an exemption request seems absurd. The next time I renew a car registration, perhaps I will simply ask the Provincial official to believe me about having insurance rather than providing proof. If no documentation is required, all the subject facilities could apply for an exemption simply to avoid reporting, resulting in the Province having no data with which to predict trends, plan or develop energy programs.
With energy prices these days, any owner/operator of a large facility should be very interested in the energy performance of their buildings. They should be encouraged and supported to carry out energy audits. It is to their advantage to understand these costs and make efforts to better manage or reduce them. If they are trying to appeal to their customers as a sustainable company, then this information and showing progress to greater energy and water use efficiency are key bases for making those claims.
The information collected in the reporting and benchmarking program is (or should be) essential knowledge for Ontario in reaching GHG emissions reduction goals. Heating and cooling of buildings produces 25% of Ontario’s emissions and thus are critical areas for emissions reductions - “what gets measured, gets done”. If we have no data and no benchmark, we won't know how to target actions and can’t measure progress.
One could speculate that the current government is changing this regulation to avoid having a reporting system that will clearly demonstrate their lack of meaningful action on energy conservation and climate change. In the context of their planned expansion of gas-fired generation, rigorous conservation measures might be the one hope of keeping Ontario on a downward GHG emissions trend.
After five years in operation, it may be timely for the Ministry to explore improvements to the reporting tool that support the continuity and quality of information collected. The public sector has been developing conservation plans in parallel that may offer advice or examples from which to learn. Perhaps supports for understanding facility energy and water efficiency should be incorporated into the program with incentives that link data tracking and potential operational improvements. All of the companies should be encouraged to identify ways to reduce their carbon footprints and operating costs. This is benchmarking program, should be opening the door to energy-saving possibilities for these facilities. The companies would save money and we all will benefit from reduced emissions. It's a win/win.
In case you missed the daily news all summer, Canada is in the midst of the climate crisis. This is no time to drop the ball on something as basic as proper reporting of emissions in the key sector of facility operations. Instead of offering an exemption from reporting, the ministry should be supporting companies and facilities to report and use the data to find energy savings.