Public disclosure of energy use and GHG intensity holds little appeal for building owners concerned about uninformed scrutiny

Public disclosure could foil energy reporting

BOMA Manitoba concerned that transparency will lack needed context
Thursday, June 18, 2020
By Barbara Carss

Winnipeg’s call for voluntary disclosure of energy use and greenhouse gas (GHG) emissions could attract a disproportionate share of high-performance buildings. City officials have invited commercial building owners and institutional facility managers to affix their Energy Star Portfolio Manager results on a publicly accessible map, but the spectre of uninformed scrutiny may hold little appeal for some of the sought-after participants.

To begin, public sector buildings are a large majority on the newly unveiled energy disclosure map, which divulges each building’s name and address; size, year of construction, energy use intensity in gigajoules per square metre (GJ/m2), GHG emissions in kilograms of carbon dioxide equivalent per square metre (kgCO2e/m2) and Energy Star score, if available. In turn, the Building Owners and Managers Association (BOMA) of Manitoba cautions that such transparency needs context.

“In our opinion, the public disclosure element will lead to a lot of building comparisons that are not ‘apples-to-apples’ comparisons,” says Tom Thiessen, executive director of BOMA Manitoba. “Comparing data for two buildings that are used very differently is not a useful exercise, and we wouldn’t want that type of information to be misinterpreted.”

BOMA Manitoba’s sister chapter in Toronto voiced a similar argument in 2015 when the Ontario government of the day first moved to mandate energy and water use reporting and benchmarking (EWRB). The association endorsed the practice as a means to identify where efficiency could be improved, while alerting against exposing members to undue criticism. “It will be very disruptive to publicly disclose performance that creates apples-to-pears-to-oranges comparisons,” BOMA Toronto predicted at the time.

Ontario is now the only Canadian jurisdiction where energy/water benchmarking and reporting are compulsory. As per the enabling regulation, data from the first phase of enrollees — commercial buildings of 250,000 square feet or greater — is due to be released this year. However, the provincial government recently extended the deadline for the final group of designated buildings to join the exercise. The first reporting period for commercial and multifamily buildings in the range of 50,000 to 99,999 square feet has been pushed to 2022, with data to be submitted by July 1, 2023.

“Benchmarking is the right thing to do, but it can be much more difficult than people might think,” reflects Scott Rouse, managing partner of the consulting firm Energy@Work, who has been working with Ontario building owners/managers to fulfill reporting obligations. “And there will be resistance.”

Winnipeg’s newly launched Building Energy Disclosure Project augments a few similar voluntary initiatives across Canada, including the Canada Green Building Council’s (CaGBC) national challenge, a province-wide impetus in British Columbia and two other programs with civic parameters in Toronto and Edmonton. Looking to the United States, New York City enforces one of the most stringent mandatory disclosure programs and there are several voluntary options.

“In terms of uptake, the sustainability leaders are usually the first to join,” observes Kristopher Kolenc, manager of research and sustainability with REALPAC, which counts many of those early joiners among its membership of large commercial landlords, property funds and institutional investors. “Larger owners are more likely to have their own sustainability teams and the resources to participate in such programs. Smaller owners may need more support and tools to understand why they should report and how to report.”

More discreet benchmarking options already draw wide participation

Winnipeg’s voluntary program is open to buildings of at least 20,000 square feet. The new effort aligns with the municipal climate change action plan and is supported with funding from the federal Ministry of Natural Resources. The Manitoba CaGBC chapter is partnering with the city to provide free workshops and assistance in registering for Energy Star Portfolio Manager and/or applying for Energy Star certification. Participants are also promised civic recognition for making the commitment to benchmarking and transparency.

“With the Building Energy Disclosure Project, we hope to enable building owners to better understand the energy performance of their buildings, while supporting overall reductions in GHG emissions in our community,” maintains Councillor Cindy Gilroy, chair of the city’s standing policy committee on water and waste, riverbank management and the environment.

However, there are already opportunities to do that more discreetly. Notably, Energy Star Portfolio Manager, which is the platform for Winnipeg’s public disclosure initiative, provides the same personalized scorecard and comparisons with similar-sized buildings, but keeps the details private.

Although guidance for prospective registrants in Winnipeg’s program promises: “Each participant will be given an opportunity to summarize the nature and extent of their building information; the efforts undertaken to improve energy efficiency and reduce GHG emissions, and providing a greater level of data transparency”, Thiessen expresses concern that casual map viewers won’t look beyond the easily found numbers.

“Energy usage is dependent on a number of factors, and building usage is a key factor,” he says. “The numbers can be misinterpreted. Has the data been normalized for vacancies, for example? Or reduced hours? Or what about for hybrid uses of office space like data centres? Data centres can use a lot of servers, computing power and cooling power. Will those types of uses be accounted for?”

Buildings that boast above-average performance will have a opportunity to enjoy some positive attention. Winnipeg officials are highlighting the “showcase” aspect of the program, which could give the general public more insight into and appreciation for commercial real estate’s sustainability profile, although Thiessen suggests programs like BOMA BEST provide a more well-rounded picture of a greater number of environmental management issues.

“If participants end up providing data only for buildings that ‘show’ favourably — buildings that are relatively new, with tenants that are low-intensity energy users — then that defeats the purpose of the program, in our opinion,” he asserts. “It will also create unrealistic expectations for owners of older buildings, many of whom are already doing their best to improve their buildings from an energy usage and sustainability standpoint.”

Nevertheless, consumers’ expectations are always a factor in the marketplace regardless of whether they can be deemed realistic. Kolenc frames energy reporting in the context of competing in a transitioning economy, and in light of Canada’s targets to reduce GHG emissions to 30 per cent below 2005 levels by 2030, with all newly constructed buildings to be net-zero-energy-ready (NZER) by that year.

“We may eventually see some jurisdictions transition to a mandatory (reporting) program or this could even be the case at a national level some day,” he notes. “Going public shows a commitment to sustainability and willingness to improve. Owners who participate are more likely to be aided by the program’s tools and they can also publicly demonstrate improved performance over the years.”

Barbara Carss is editor-in-chief of Canadian Property Management.

1 thought on “Public disclosure could foil energy reporting

  1. Thanks for this article highlighting the Winnipeg benchmarking and disclosure initiative. I worked on the CaGBC national Disclosure Challenge that involved five large property owners and managers, and have supported the development of City of Winnipeg program, so I have some knowledge in this area. I would like to simply point out that I believe Tom Thiessen’s concerns about issues with building comparisons are not well founded. It is accurate that public disclosure of energy performance for buildings would allow for some “apples to oranges” comparison between seemingly like buildings, that are not. To continue the analogy however, at this point in the real-estate industry from a data transparency stand point, stakeholders don’t even know if they are looking at fruit or vegetables. Being able to compare different buildings knowing that they are both “fruit” would be an improvement.

    When it comes to shopping for cars, it would not be helpful to consumers to go back to hiding fuel mileage information if you were comparing a Hummer vs an old Mini, because it’s not fair to the Hummer. Benchmarking and public disclosure of building energy performance is information that is neither good or bad, it just supports the needs of consumers and property managers, and helps all stakeholders make more informed choices.

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