Insights

Get into Aegent's thoughts. Search Aegent's insights and thinking by keyword or category.

Categories:

Green Energy Act Conservation Plan, Ontario Regulation 397/11: A Rare Government Gift

September 2013

  • Ontario Regulation 397/11 under the Green Energy Act calls for energy conservation and demand management plans comprised of a summary of a public agency’s annual energy consumption and GHG emissions as well as a description of measures for conserving and managing its energy.
  • If the public agency takes a “to do” list approach to developing its plan, then there is a huge missed opportunity.
  • For those who know that there’s too much energy wasted and want to do something meaningful about it, the plan required by Regulation 397/11 is a rare opportunity to align people’s motivations and management practices to achieve the level of savings on a portfolio scale that most have only dreamed of.

For Ontario public agency energy practitioners who really want to address some of the systemic challenges with making energy efficiency an essential part of their organization’s daily activities, Ontario Regulation 397/11 under the Green Energy Act is a rare opportunity. The regulation calls for energy conservation and demand management plans comprised of a summary of the public agency’s annual energy consumption and GHG emissions as well as a description of previous, current and proposed measures for conserving and managing its energy, including a forecast of the expected results of these measures.

Some might approach this from the bottom up, arranging a series of energy audits on their buildings and creating a laundry list of energy conservation measures with the potential costs and savings. The conservation plan becomes a “to do” list. If this is the approach, then there is a huge missed opportunity – to engage the relevant people and enjoy much greater success.

The government’s longer term planning horizon actually encourages a more unified approach in an ongoing march toward lower and lower consumption, instead of a series of piecemeal isolated interventions from a list of measures.

Looking deeper at the reporting structure, the first plan is for 5 years with another 5-year plan cycle set for 2019. The subsequent plan would report on the progress made in the first 5 years. Is this not describing an ongoing process that is looking to build in continuous improvement?  

We have worked with dozens of public sector institutions from school boards to municipalities to hospitals helping them reduce energy consumption. One of the overwhelming wishes we hear is for more senior management support to move faster and go deeper for savings, and for more operator and occupant engagement.

We have also found that the successful organizations have energy managers who find ways to work within an environment that is endorsed by their management and gives them sufficient freedom to take action without always going to management for approvals. These same managers have brought their facility operations staff (whether or not they were in the same department) onto the same page, to work together in eliminating energy waste in their buildings. They analyze consumption data and benchmark buildings to set priorities. They use the power of thoughtful energy management plans, which are broad in scope, to allow them to act within a structure that is goal-oriented, rather than measure-by-measure specific. So when new discoveries of improperly working equipment or new operating practices are found, they can make decisions and allocate budgets without seeking approvals every time.

The City of Hamilton and their Office of Energy Initiatives offers a great example of this approach. The energy office went to council to establish a Corporate Energy Policy in 2007. Under this framework, they set out concrete energy reductions and energy intensity targets, provided for continuing energy monitoring and targeting, defined policies on capital investments for city-wide energy systems as well as policies regarding energy procurement. The corporate policy provides the right guidance in which to establish and manage budgets, assess project priorities and viability, and give discretion to the energy office to deal with changes and issues as they arise. As a result, since 2006, the city has taken a leading role in energy efficiency with efficiency savings and cost avoidance of over $27 million on the foundation of their Corporate Energy Policy.

An empowering plan would describe an overall vision or policy of energy management throughout an organization, establish reporting systems to show stakeholders how they are progressing, enable the right decisions to be made, and address alignment of departmental silos such as the creation of a motivated multi-department energy efficiency team to seek out energy waste. It would give those managers the mandate and lateral to take the right actions as they arise, rather than just following a pre-defined static prescriptive list. The plan would validate and pave the way for the efforts of energy managers and the energy community. In effect, it would affirm and recognize that they are doing great work, important work and rewarding work.

Such a plan is not difficult or complex to create. It is simply a matter of getting organized and putting common sense into good practice.

What the Ministry of Energy has provided each energy manager in the conservation plan regulations is a golden opportunity to achieve what they’ve long sought – deeper and more energy reductions with engaged stakeholders. A well-conceived plan will:

  • win support of senior management through the right vision and right actions;
  • have reduction goals/objectives that everyone – management, operations staff and occupants -can get behind as stakeholders in an energy community;
  • provide critical flexibility for energy managers to act and react to inevitable changing conditions over the 5-year timeframes;
  • support a data management system to monitor and regularly report on energy consumption across a portfolio;
  • support a consumption data-driven decision-making process that sets priorities and standards for activity like operational optimization, recommissioning, audits, and higher efficiency practices and projects across a portfolio;
  • establish a mindset of continuous improvement, always looking for more reductions;  
  • establish a practice of timely performance feedback for all players to learn from their actions and apply to the next activity; and
  • enable recognition initiatives.

The temptation is to make a list of isolated measures from audits or other interventions, write it into the plan and be done with
it. But for those who know that there’s too much energy wasted and want to do something meaningful about it, the plan now required by Ontario Regulation 397/11 is a unique opportunity to align people’s motivations and management practices to achieve the level of savings on a portfolio scale that most have only dreamed of. This rare gift from our government today is one we must fully seize for all of our benefit.

Accurate Energy Consumption Data to Become a Public Sector Must Read more »

Ontario Regulation 397/11 Read more »