Yes.
Now, our tenants are not all teenagers—some of them are 18, 19, and 20 years old—but by the same token, any of us, if we are faced with a free good, will tend to waste it.
We want to use submetering. We want to use it for electricity. We also want to use it for heat. But under the Weights and Measures Act, it is illegal for us to submeter for heat. Section 8 provides that no one in Canada can submeter for anything, including heat, unless they use an approved meter. However, Industry Canada and the government have not approved any meters. The EU has approved meters. The U.S. has approved meters. But in Canada, we do not have approved meters. This is a barrier to an improvement in energy usage and technology.
We also face barriers in terms of the tax system. The paper I provided sets out an illustration where it makes economic sense for a landlord to replace mid-efficiency boilers with mid-efficiency boilers. The tax treatment is such that the landlords are worse off, even though they save more energy down the line, because it costs more up front. And because of the way the tax system treats that, they are better off financially to go mid-efficiency to mid-efficiency, rather than mid-efficiency to high-efficiency. This is a barrier that could be overcome, although I realize that is primarily a matter for the finance committee to address.
We would like those barriers to be fixed. There are other similar barriers, but let me focus on those two. Let me refer to a third element.
A third thing that concerns us significantly is there is a tendency by government to regulate, to impose higher conditions, to require people to use, say, high-efficiency boilers rather than mid-efficiency boilers. For our sector, that is a serious problem because our buildings are not built to take high-efficiency boilers. For us to put them in sometimes requires major capital expenditures, and really, it is not economical. It is not sound from a resource utilization point of view to force us to use high-efficiency equipment.
That is one of the examples within the regulatory field in which matters have come forward in the past. They were turned down, the regulatory changes I'm thinking of. I'm glad, but I'm concerned that they may come forward again. Within our sector, we need to see value in improvements, value to the bottom line, value to the services given to tenants, and we want to keep housing affordable.
Because of all those factors, we would ask the government to pay close attention, when it is bringing in mandatory regulations, to what those impacts are, to make sure they don't in fact raise costs to the sector. We also need government either to get out of the way in the case of these heat meters or at least to approve some heat meters so we can go down that path. Certainly, we would appreciate incentives. We would appreciate the tax system and the other systems being structured so that they reinforce our desire to use higher efficiency equipment rather than making us choose between whether we do the environmentally sound thing or whether we do the economically sound thing. Do we do the thing that will let us continue to provide low-cost housing, or lower cost housing, I should say, for people.
Those are basically my three pitches for you today. Thank you very much.