As of today, April 1, 2019, the Environmental Commissioner of Ontario’s (ECO) website reads:
From 1994 to 2019, the Environmental Commissioner of Ontario (ECO), an independent officer of the Legislature, reported on government progress on climate change, energy and other environmental issues. As of April 1, 2019, the ECO became a part of the Office of the Auditor General of Ontario. This change occurred under Schedule 15 of the Restoring Trust, Transparency and Accountability Act, 2018.
The last report of the ECO’s office was released on March 27, 2019. It is the ECO’s 2019 Energy Conservation Progress Report, titled, A Healthy, Happy, Prosperous Ontario: Why we need more energy conservation (the “Report”).
The Report focuses on 4 primary topic areas: (1) making the case for greater energy conservation; (2) specifically advocating for utility-funded conservation programs; (3) incentivizing energy-efficiency targets in home renovations; and (4) a continued emphasis on decreasing urban sprawl in land use planning.
The report leads off by establishing some basic facts, for example: “Ontario’s economy is still 75% dependent on fossil fuels, mostly petroleum products and natural gas” (page 5). This becomes the key to understanding the majority focus of the Report: building heating fuels (largely, natural gas) and transportation fuels (gasoline and diesel).
The Report highlights that the government’s November 2018 draft Environment Plan’s emphasis on expansion of utility-led natural gas conservation programs is a positive step but cautions that electricity conservation programs are likely still needed to meet the target of reducing Ontario’s annual greenhouse gas emissions by 3.2 Mt by 2030.
The Report also takes a deep dive into energy waste in existing buildings, reporting that 13% (20 Mt CO2e per year) of Ontario’s emissions come from residential energy use (mostly from natural gas fired space and water heating) (page 98). The Report indicates that building envelope improvements in existing housing stock is fundamental to greater energy efficiency, but recognizes that “homeowners often see deeper energy efficiency renovations, such as envelope improvements and insulation, as unnecessary, inconvenient, and/or too costly” (page 105).
Finally, the Report makes the link between the way we plan and build our communities and the consumption of transportation fuels. The Report takes direct aim at the province’s Growth Plan for Greater Golden Horseshoe (the “Growth Plan”) which was intended to ensure that this region’s rapidly growing population can be accommodated in compact, complete communities with sufficient density to support public transit. The claim is that the Growth Plan has actually “increased costly urban sprawl, by directing hundreds of thousands of people to new, distant suburbs with high servicing costs, few employment opportunities” (page 128).
At 268 pages long, this Report is meticulous in making the case for increased energy conservation, and results in 4 categories of recommended law and policy changes. These can be summarized as:
- Set targets for reducing Ontario’s use of each fossil fuel, then track and report progress.
- Implement natural gas conservation programs, but include other heating fuels and retain a focus on electricity conservation programs.
- Require higher minimum levels of energy efficiency for renovation permits under the Building Code.
- Mandate higher residential density in existing communities and limit development of new suburbs by revising population allocations in the Growth Plan and freezing urban boundary expansion.
It remains to be seen whether the Ontario government’s draft Environment Plan will respond to or incorporate any of these recommendations, but perhaps the more interesting thing to watch will be whether a new Commissioner of the Environment in the Office of the Auditor General, will continue to advance these themes.