February 13th, 2024

As noted in previous UDI newsletters, as part of its Clean Air Plan and Climate 2050, Metro Vancouver was considering regulating Greenhouse Gases (GHGs) from existing buildings.

It released a Discussion Paper in June 2022, and UDI wrote a joint letter with the Building Owners and Managers Association of British Columbia and LandlordBC on November 30th, 2022 responding to the initiative. The associations raised several concerns, including:

• Having multiple governments regulating in the same field, because as noted in previous newsletters -
  • The City of Vancouver is seeking to engage with stakeholders regarding a similar approach to report and limit GHGs in large commercial and multi-family buildings; and
  • The Province is planning on introducing an Alterations Code to Existing Buildings, and is consulting on Highest Efficiency Equipment Standards for water and space heating;

• It being unclear whether Metro Vancouver has the authority through its Air Quality Management By-law to regulate GHGs; and
• Metro Vancouver not having the necessary power and resources to properly implement the requirements, as this type of policy is better overseen by Province.

In August 2023, Metro Vancouver released an Emissions Reduction Requirements for Existing Large Buildings (LBER) Phase 1 Engagement Summary, and at the January 26th, 2024 Metro Vancouver Board meeting, staff brought forward proposals to conduct a second phase of consultations on a Proposed Regulatory Approach to Reduce Greenhouse Gas Emissions from Existing Large Buildings.

In the report, staff proposed establishing “… GHG reporting and reduction requirements for existing large buildings over 2,322 m2 (25,000 ft2) in gross floor area.” The reporting requirements would have begun for buildings greater than 100,000 ft2 in 2026, and then be expanded to all large buildings by 2029. Initial GHG intensity limits would have been implemented in 2028 for buildings over 100,000 ft2. The GHG intensity limits would then have been expanded to other larger buildings, and the limit would have eventually been reduced to “… 0 kg CO2e/m2 for all regulated building types over 2,322 m2 (25,000 ft2) by 2045.” They were also proposing a $350/tonne CO2e charge for a building’s emissions beyond the GHG intensity limit.

At their January 26th, 2024 meeting, the Metro Vancouver Board instructed staff not to proceed with the Phase 2 engagement, which acknowledges the concerns raised by UDI and other industry associations.