Appendix A: Analysis and Assessment of Individual Measures

1.5 ecoENERGY for Buildings and Houses

Table 8: Summary of Analysis for ecoENERGY for Buildings and Houses

Summary of the Initiative

The ecoENERGY for Buildings and Houses program is an information-based initiative offering training, labelling, and rating of houses and buildings. The estimates for this program are unchanged from 2008.

Analysis

The bulk of forecasted emissions reductions attributed to this program come through assumed changes in commercial building codes driven through the adoption of a non-binding Updated Model National Energy Code for Buildings (MNECB) and through the impacts of disseminating energy-efficient home building practices through labelling.

The current National Model Energy Code for Buildings was published in 1997. Since then, provinces or municipalities have adopted measures that are recommended in this publication. In documentation supporting the 2009 Plan, NRCan stipulates that the emissions reductions attributed to the building code amendments require all provinces and jurisdictions in Canada to adopt the Updated MNECB by 2010/2011 or to amend the National Model Energy Code. According to the NRCan website for the National Model Energy Code, "the next edition of the MNECB is scheduled to be released in 2011." On an NRCan website devoted to the adoption of national building, fire, and plumbing codes, it is clear that the Model Energy Code was not directly adopted on a wide scale.[42] In fact, the National Model Energy Code is only mentioned once on the site, in a phrase that says, "Ontario also references the Model National Energy Code for Buildings in its building code."

However, evidence does exist that provinces may actually be ahead of the national code. In the 2008 Plan, details were provided indicating that four provinces are currently running pilot projects relating to the building code, while six have announced changes to the building code to require an EnerGuide rating of 80 — the EnerGuide labelling standard recommended in the Updated Model National Energy Code for Buildings that will only be published in 2011. Some provinces are enacting building code changes as part of their climate-change policies. For example, in Nova Scotia, new homes would be required to display an EnerGuide rating by 2008, while minimum standards would require a rating of 72 by 2009, 77 by 2010, and 80 by 2011.

This analysis raises some concerns with respect to the attribution of emissions reductions. First, major changes to the building code requiring an immediate implementation of EnerGuide 80 ratings are not likely to be in place in all jurisdictions by 2008 —2012, and so the assumptions underlying the analysis are likely optimistic. Second, even if the regulatory changes were to be made, it would be difficult to directly attribute the emissions reductions resulting from these changes to a program that provides guidance, but does not enforce the regulation, especially as evidence suggests that the National Code may follow provincial action, rather than the other way around. Finally, impacts resulting from provincial-level policy changes should also be omitted from policy-by-policy analysis of a federal program.

A second source of emissions reductions in the calculation is subject to concerns of additionality. Labelling of houses with respect both the R-2000 Standard and EnerGuide Rating System is handled under this program. Information provided to the NRTEE by NRCan states that in order to calculate energy savings from the aspect of the program, "the expected energy savings per house are calculated by comparing the energy consumption of code-compliant average new construction with the energy consumption of rated houses under the two categories of labelling for energy efficient new homes (i.e., R-2000 and EnerGuide Rating System). Data...show that a basic EnerGuide-labelled new house saves an average 33 GJ per year over conventional new construction …and an R-2000-labelled house (average EnerGuide rating 82) saves 60 GJ per year compared to conventional new construction. To obtain the total energy savings, the savings per house described above is then multiplied by the number of houses expected to be built."[43]

This approach implicitly assumes that, absent the administration of the labelling program, no houses would be built to higher levels of energy efficiency. Attributing the effect of all new, energy efficient construction to a program that provides a particular label and standard is likely to overestimate the induced emissions reductions.

Conclusions

The assumptions made by NRCan for evaluation of this program are likely to lead to an overestimate of the program's impact. While the program provides information and labelling, the estimated emissions reductions are based in part on significant changes to building codes being implemented in all provinces. Some provinces have changed or will change current building codes to include more stringent requirements based on the EnerGuide labelling system; however, the existence of the labels and associated information has not necessarily led to all of these changes. Further, the program attributes energy savings from all new homes built to R-2000 standards to the program, which does not account for the possibility that some houses are built to higher standards of energy efficiency due to other factors such as high energy prices. The estimated impacts thus likely overestimate the impact of this labelling, training, and information program.

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42 See http://www.nationalcodes.ca/ncd_model-code_e.shtml

43 Canada, 2009a.