A submission to Nova Scotia's consultation on the Sustainable Development Goals Act and the Climate Change Plan for Clean Growth

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July 12, 2021
Clean Future
Attention: Engagement Coordinator
126 Portland Street Dartmouth, NS B2Y 1H8
RE: Nova Scotia Sustainable Development Goals Act and the Climate Change Plan for
Clean Growth
Recently, Efficiency Canada released a report entitled “Canada’s Climate Retrofit Mission.”
This report determined that 47% of Nova Scotia’s greenhouse gas emissions come from its
building sector. This is an astonishingly high number that is supported by the findings of
several municipal GHG inventories done in the past few years. Halifax’s recent GHG
inventory found that 70% of its GHG emissions come from the building sector. This is largely
due to Nova Scotia’s carbon intensive energy grid and the use of furnace oil to heat a
majority of homes. Some homes in Cape Breton still use coal furnaces to stay warm in the
winter. Efficiency Canada’s Retrofit Mission report also finds that undertaking aggressive
deep energy retrofits could actually reduce total electricity consumption of existing buildings
by up to 17%, thus freeing up electricity capacity.
In addition to extremely high greenhouse gas emissions, our heating systems and inefficient
buildings lead to Nova Scotia having one of the highest rates of energy poverty in the
country. Efficiency Canada’s 2020 Scorecard notes that 37% of Nova Scotian households
experience energy poverty.1
Thus, we will not reach our climate goals without specific
strategies to retrofit low-income households, and equitable strategies need to place priority
on lower income populations as well as those with specific barriers due to historic injustices,
in particular African Nova Scotian and Mi’kmaw communities.
Reducing the carbon impact of Nova Scotia’s buildings must be central to the province’s
climate plan. It will help reduce financial strain within Nova Scotian families, create
thousands of jobs, and create a boost in the economy. Achieving this goal will require a
fundamental shift in how we think about building renovations. Rather than being in the
purview of individual homeowners or landlords, we must treat buildings as public
infrastructure and deploy infrastructure-scale investments. In doing so, our province will
enjoy the benefits of massive GHG emissions reductions and energy savings. To create a
framework to enable this essential transition, we urgently recommend that you to put in place
the following strategic policies:
1) Starting in 2023, no new residential or commercial construction in Nova Scotia will
use on-site fossil fuels.
This will need to be introduced along with higher energy efficiency standards for buildings.
For liability and long-term asset planning purposes, installing oil or natural gas furnaces does
not make sense.
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Energy poverty is defined as a household that spends 6% of its income on household energy costs
(excluding transportation), double the average Canadian household which spends 3% of their income
on energy.

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2) By 2025, eliminate on-site fossil fuels from 20% of existing buildings, and by 2030,
eliminate on-site fossil fuels from 100% of existing buildings.
This would require a carefully planned deep energy retrofit and electrification
strategy, as outlined in Efficiency Canada’s report to ensure that no person’s
well-being suffers from high retrofit costs or inadequate heat sources. Creating a
clear strategy in advance of 2025 will stimulate the market transformation that will
facilitate widespread retrofits. Nova Scotia has the right conditions for this to succeed
as it is a small jurisdiction with a strong background in energy efficiency and the high
costs of fuel oil make it unattractive.
We suggest that this strategy should prioritize Mi’kmaw communities and low-income
communities. This can be done through an increase in funding to existing programs
to ensure deeper efficiency retrofits on more homes, and the creation of additional
funding opportunities to pair these retrofits with clean energy in both Mi'kmaw
communities and public housing. Oil tanks are a liability to property-owners, and this
can be leveraged to make the energy source switch easier.
3) Carbon reduction programming specific to band–owned building stock, including
Certificates of Possession (CP)
Mi'kmaw communities in Nova Scotia face a specific and unique set of challenges in
their building stock. A significant portion of the investment into eliminating the carbon
from the building stock in Nova Scotia should be allocated to enable Mi’kmaw
communities to upgrade their buildings, create jobs within their communities, and to
promote engagement and education. Existing programs that work in partnership with
Mi’kmaw organizations can be built upon to provide quality, high performance, and
affordable homes and buildings for the communities.
4) Leverage existing institutions to apply a net zero and greenhouse gas reduction lens
Several institutions exist within Nova Scotia that could help Nova Scotia achieve its
climate goals. Nova Scotia has shown leadership in energy efficiency and energy
savings for over a decade. It’s time for these institutions to make achieving net-zero
emissions their main priority and for provincial regulation to make significant carbon
reductions possible and essential.
This will require a shift to a ‘whole home’ perspective that focuses on carbon
reduction -- not only measure-level energy consumption -- as the primary goal. In
particular, the efficiency utility could revise its targets to focus on greenhouse gas
reductions and deep retrofits consistent with a net-zero emissions economy.
5) Data collection and analysis
Designing a deep efficiency / clean energy retrofit strategy and eliminating fossil fuel
consumption in buildings will require data and measurement. An effective climate
plan will include mandatory energy labeling of buildings, and a provincial database,
broken down by municipality or region, of the building stock by age, square footage,

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and energy consumption. Progress should also be measured and evaluated on an
ongoing basis, to ensure that we are achieving carbon reductions and adjusting the
implementation as needed.
6) Adoption of a net-zero energy ready building code by 2022 that includes air-tightness
testing to ensure the safety and health of building occupants. Enforce this code
provincially by 2030 with the option for municipalities to enforce net zero ready
buildings before 2030.
This includes a robust compliance framework to ensure our intended energy and
emissions reductions are achieved. While the Canadian Commission on Building and
Fire Codes is developing a tiered code system there is no assurance that the
outcomes delivered will match the urgency of our 2030 climate objectives or that the
tiered code will be adequate or delivered in good time.
These recommendations are ambitious, but achievable and, most notably, necessary if we
intend to maintain a liveable climate on our planet. There is no time for delay. These
recommendations also make economic sense, creating long-term green jobs, helping future
generations know they have both an economic and environmental future here, and leading
the shift to an inclusive, green economy. The signatories to this letter include environmental
advocates, builders, energy specialists, community leaders, and more, who have come
together to voice our support for a net zero carbon building sector. We are ready to support
the province in developing and implementing a roadmap to eliminating carbon emissions
from our buildings. Our future must include safe, comfortable, and resilient buildings for all -
and the Sustainable Development Goals Act is an opportunity to make it happen.
Sincerely,
(Signatures will be added here)