The purpose of the amendments to the regulation is to address comments made by some agencies regarding the resources required to report buildings that have multiple operations and water/sewage pumps that are not adequately metered for energy consumption, usage or flow rates. In addition, the proposed amendments would change the reporting date for annual energy consumption and greenhouse gas emission reports and conservation and demand management plans. Some agencies have advised that the current date of July 1st conflicts with summer schedules and senior management approval processes.
Reporting on Multi-use Operations
The regulation requires public agencies with multi-operation buildings to make a reasonable allocation of the energy used in each of the operations listed in table 1 of the regulation. Public agencies noted they had difficulty in identifying and allocating floor space to each operation and that the resulting energy consumption reports for those operations were not accurate.
The Ministry is proposing to amend the regulation to require public agencies with multiple operations in a building to report energy use for the building by its primary operation type by square footage. The proposed amendment would reduce the resources required to report energy use for multi-operation buildings and improve data quality by allocating energy to the buildings primary operation type.
Reporting on Water/Sewage Pumps
The regulation requires municipalities and municipal service boards to report the energy use and flow rates for water/sewage pumps. Those organizations noted that in many cases pumps were not metered for energy use, flow rates or how long the pump was in use. As a result organizations had to estimate the energy use and or flow rate. Upon review, the resulting reports do not provide accurate energy data.
The Ministry is proposing to amend the regulation to remove the requirement for municipalities and municipal service boards to report the energy use and flow rates for water/sewage pumps. The proposed amendments would reduce the resources required by organizations to estimate the information.
Changing the Reporting Deadline
The regulation requires public agencies to submit their annual energy consumption and greenhouse gas emission reports to the Ministry and make them available on their websites by July 1 every year. In addition, public agencies are also required to post their 5-year energy conservation and demand management plan on their website by July 1 every five years. Public agencies must obtain senior management approval of conservation and demand management plans. Obtaining senior management approval for the July 1 deadline is an issue for municipalities and school boards, as municipal councils and school board officials meet less frequently in the summer to approve materials. In some cases municipalities cannot get their reports approved in time to meet the deadline.
The Ministry is proposing changing the deadline from reporting by July 1 to June 1. The change would help public agencies get their reports approved in a more timely manner.