The building blocks of minimum energy performance standards

Plugging the gaps, Part 2:  How to regulate retrofits in existing buildings

Kevin Lockhart

Efficient Buildings Lead, Efficiency Canada

September 24, 2021

Blogs | Buildings | News

  • Effective minimum energy performance standards are typically aligned with specific policy outcomes. In Canada, this means both energy use intensity and greenhouse gas emissions targets for existing buildings.
  • Building labelling and benchmarking informs the development and implementation of minimum energy performance standards. In Canada, we can leverage our existing EnerGuide and Energy Star Portfolio programs.
  • If we want to see sharp reduction in greenhouse gas emissions, absolute performance metrics offer a simple approach to setting and achieving energy and emissions targets.
  • Canada needs to find ways to quickly implement MEPS. We can take advantage of new technologies and tools and learn from other jurisdictions.

Part 1 of this series introduced Minimum Energy Performance Standards (MEPS) as regulated standards that set limits on energy use or carbon emissions for existing buildings. Developed as progressive tiers and aligned with Canada’s climate and energy objectives, MEPS use building performance benchmarks to identify those buildings with below-average performance – individually or in aggregate – and bring them up to a standard consistent with our national net-zero emission goals.

But first, much like a building itself, MEPS require a solid foundation upon which a sound structure can be built. In this article, we look at some of the core considerations for policymakers as they seek to design and implement the building blocks of an effective MEPS.  

Set a defined outcome, then collaborate on how to reach that goal

Identifying and articulating clearly stated goals is the first building block upon which effective MEPS are based. These can include reductions in levels of energy poverty, reductions in energy use and emissions from existing buildings, or improved health outcomes.

Setting specific outcomes early, individually or together, has the benefit of minimizing potential ambiguity regarding the desired policy outcome and allows government, industry and civil society to shape the long-term regulatory path. Complete with incremental increases in performance along a clearly established timeline, and well-defined checkpoints that offer opportunities for adjustments if needed, MEPS set clear expectations, both in terms of timelines and performance.

In Canada, the transition to a net-zero emissions economy is a primary policy goal and to reach that outcome, we need both energy use intensity and emissions standards for our buildings sector. Emission intensity standards lead to more certain emission reductions and support the switch to zero-carbon fuel sources. But we shouldn’t also forget about energy use intensity standards, which recognize that energy efficiency can free up Canada’s abundant stocks of clean electricity, manage peak demands, and capture the comfort and health benefits that matter to Canadians.  

Building labelling lays the foundation for improving building performance

The success of a MEPS depends largely on the confidence building owners, industry and supply chain actors, and financial institutions have in the standard’s benchmarking and assessments. For this reason building labelling and benchmarking programs are considered another core building block of the MEPS framework.

Under the European Building Performance Directive (EBPD), building labelling has played a role in helping to gather a comprehensive picture of how a building, or set of buildings, are performing; both in absolute terms and relative to buildings within the same market segments. Data collected through assessments and benchmarking has helped inform the design of Energy Performance Certificates (EPC). Based on a physical assessment of a building, EPCs offer building owners an energy performance rating for their building, as well as suggested steps to improve its performance. Issued for 10-year intervals, EPCs act as a compliance tool and typically assign a building grade ranging from “A” (best) through “G” (worst). In the UK, for example, EPCs are issued for private rental units. Triggered by a change in ownership or tenancy, each building is required to reach at least an “E” rating to be considered an eligible rental unit.

Benchmarking and labelling programs play an important role in contributing to the development of well-designed policies and supports while also moving the market towards increasingly cost-effective retrofits. As more buildings are collected within building labelling and benchmarking programs, the increasing volume of data collected is leveraged to craft a menu of high-impact, cost-effective energy conservation measures for specific archetypes that minimize both the costs associated with future retrofits, as well as any potential unintended consequences of certain measures.

Building labelling and benchmarking was an important aspect of the 2016 Pan-Canadian Framework on Clean Growth and Climate Change which sought to require “labelling of building energy use by as early as 2019.” While we have yet to see this commitment realized, there is now in place a patchwork of efforts at the provincial, territorial, and municipal levels. Programs like Ontario’s 2016 initiative for the mandatory reporting of energy consumption in large buildings, municipal building energy benchmarking programs, or industry efforts to create dynamic tools to benchmark, and disclose energy use and building energy performance are already helping us understand how energy and emissions performance varies between different segments of the building stock.

In Canada, we have two existing and nationally recognized programs used to measure building performance that have the potential to quickly enable MEPS: the EnerGuide Rating System, and Energy Star Portfolio Manager. With these two energy rating programs, are Canadian governments already well-positioned to implement MEPS for existing buildings? This is a worthy question that we’ll revisit in later articles.

Options by which to measure improvements in building performance

In the jurisdictions that have implemented MEPs we see a variety of different objectives, triggers, and metrics to assess and improve the energy performance of existing buildings, as shown in Table 1. Typically, most jurisdictions lean towards Energy Use Intensity (EUI) Greenhouse Gas Intensity (GHGI). These two metrics give policymakers the greatest confidence that the policy will actually meet the desired targets and place every building on the right track towards net-zero. Two approaches can be taken to apply these metrics, a reference approach or absolute performance approach.

Table 1: Leading Minimum Energy Performance Standards

Jurisdiction (implementation date)Objective(s) and building typeTriggerMetric
United Kingdom (2018)Increase private residential and commercial rental property standards and reduce energy and emissions.Point of sale, major renovation.Health-based metrics that include minimum energy standards, based on EPC.
France (2015)Overall reduction in final energy consumption, reduce energy poverty in private rental and owner occupied residential.Point of sale, change in tenancy.Based on an EPC that includes EUI and minimum decent living requirements such as minimum floor area and free of pests.
Washington, D.C (2018)Reduce energy and emissions from commercial and multi-family buildings (>50,000 sq. ft),.Triggered by set timelines according to building size.
Based on benchmarked performance.
Uses the Energy Star assessment to identify buildings. Buildings must meet the median ENERGY STAR score for that building type or reduce energy use 20%
New York City (2019)Reduce emissions from commercial and multi-family buildings (>50,000 sq. ft.) based on an emissions rate/square foot multiplied by the building’s footprint.Captures highest emitting buildings between 2024-2029.
Second compliance period between 2030–34 will affect approx. 75% of covered buildings (>50,000 sq. ft.).
GHG intensity limits, expressed in CO2 eq. / sq. ft for 10 building categories.
Reno, Nevada (2019)Reduce energy and water use in commercial and multi-family buildings (> 30,000 sq. ft).Triggered by size threshold and by year for specific archetypes.Energy Star score or EUI as compared to all covered buildings.
Water use intensity.
Vancouver (June 2021 - commercial/multifamily and 2022 - detached homes.Reduce fossil fuels use in building operations, including space and water heating. Applies to each major building type.Performance requirements increase in roughly 5-year intervals until all buildings achieve zero emissions by 2030, and for many building types, by 2025.GHGI limits and Thermal Energy Demand Intensity (TEDI).

The reference approach, also known as the percent better approach, establishes a typical reference building archetype based on the performance of existing buildings. Performance data is collected through benchmarking programs to establish a reference building based on attributes such as building age, size, type of use and occupancy, and typical building envelope measures and mechanical systems. The building’s performance is then expected to be improved above the average or median performance of the stock for that building type. This approach demands accurate reference building modeling to ensure the targets set from this data are feasible, achievable, and avoid disproportionately burdening building owners, while also ensuring each building is put on a path towards net-zero.

The reference approach can be helpful in defining an approximate representation of the energy and emission profiles of a typical building in a specific category. Nonetheless, the final impact of the reference approach can be uncertain; the baseline can be gamed and a percentage reduction doesn’t provide certainty that a building is hitting a standard consistent with net-zero emissions. Instead, an absolute performance approach is preferable given the simplicity of setting and achieving clear energy and emissions targets. Like the reference approach, an average standard of building performance is established for specific archetypes. All buildings then receive a limit based on a set total energy or emissions metric per square metre of floor area. Absolute performance criteria have the advantage of making compliance a clear and straightforward affair, and can better ensure we actually meet our energy efficiency and GHG reduction goals.

How can Canada implement MEPS more quickly?  

MEPS have been used by national and sub-national governments around the world and, while MEPS have typically taken between 4 and 10 years to develop and implement, we can shortcut this process to quickly cut energy waste and emissions from our built environment. First and foremost, we can take advantage of statistical data on national building stocks gathered from existing benchmarking programs, a precondition for setting MEPS that was not available in other locales where MEPS were first introduced. We can also leverage new technology and processes such as virtual energy audits, as well as tools to identify poor performing buildings such as energy heatmapping. Finally, we have the advantage of looking at numerous jurisdictions that have already implemented MEPS and heed the lessons learned to significantly reduce the time needed to scale up MEPS at any level of government.


In Canada, we have the opportunity to quickly develop and implement MEPS as a key tool in our efforts to drive sharp reductions in energy use and emissions in existing buildings and provide certainty that buildings sector on track to achieving net-zero emission objectives. Using a combined approach that sets limits on energy use intensity and emissions, MEPS can serve to free our abundant sources of clean electricity to decarbonize other areas of our economy, while making the places we live, work, gather and play more comfortable and healthier. And, through widespread building labelling and benchmarking programs, potentially including EnerGuide and the Energy Star Portfolio Manager programs, we can accelerate the design and implementation of a MEPS and ensure fair and equitable absolute performance measures. Informed by the experience of other jurisdictions and the advantage of new tools and technologies on the market, we can leverage MEPS to ensure every building is on the path to net-zero.


You have Successfully Subscribed!


You have Successfully Subscribed!


Sign-up to get the latest in energy efficiency news! 

You have Successfully Subscribed!


Thank you!

Get Involved!

You have Successfully Subscribed!


Thank you!