Thank you.
Good afternoon, committee members, and thank you for the opportunity to address you today.
My name is Gabriella Kalapos, and I'm the Executive Director of the Clean Air Partnership. We're a charitable environmental organization that works with municipalities and their partners to help them become sustainable, resilient, vibrant communities where resources are used efficiently, the air is clean to breathe and greenhouse gas emissions are minimized. We achieve this mission through research and knowledge transfer, and by fostering collaboration among all orders of government, academia, NGOs and others as well.
The Clean Air Partnership is well positioned to speak to the economic opportunities for energy efficiency in Canada and its contributions to Canada's climate change commitments. While we've been delivering a broad range of programs and research related to greenhouse gas emissions, today I'd like to speak to the importance of a comprehensive home energy efficiency retrofit program to deliver on these commitments.
More specifically, I'd like to speak to the importance of local improvement charges, or LICs, as a possible financing mechanism and what the Government of Canada can do to increase the use of this financing mechanism.
LIC financing is enabled by provincial legislation that is used in Canadian municipalities. It has been used for decades, and mostly it has been used historically for block-level improvements like sidewalks, sewers and other types of infrastructure. More recently, we witnessed provinces enacting enabling legislation allowing for LICs at the single home level for energy efficiency improvements.
The LIC charge is associated with the property and not the owner, so if a home with a LIC is sold before the energy efficiency loan is fully recovered, the next owner continues paying the charge on a property tax bill until the full loan is recovered. This allows the costs and benefits of the energy efficiency improvement to stay and to be shared between current and future owners. Because some families cannot access financing at attractive rates, the LIC program removes up-front capital cost barriers that often impede energy efficiency retrofits. LIC financing also has the advantage of offering longer repayment time frames at fixed rates, making payments more affordable and allowing for greater equity in the home energy efficiency retrofit market.
Possible measures covered by LICs can include thermal envelope upgrades, HVAC systems, water efficiency and water quality upgrades, and renewable energy systems, as well as other measures such as climate change resilience and flood protection measures.
Supporting energy efficiency in all sectors is the cheapest and fastest way to ease energy demand and help offset the need for costly energy infrastructure development. As this committee understands, energy use in homes and buildings accounts for a significant portion of our greenhouse gas emissions. People who invest in home energy upgrades reduce their energy bills and protect against energy price increases. In fact, participating home owners in the federal eco-energy retrofit homes program saw an average energy savings of 20% after upgrades. These savings strengthen the local economy by creating local employment and spending.
Energy efficiency upgrades, especially in older housing, can significantly improve the quality of the local building stock, and LIC financing can fill a gap in public support for energy efficiency upgrades. Over time, the aim is to have program costs supported by the participants, not the general taxpayer, so the program moves towards paying for itself. Regulatory amendments permit the municipality to recover administrative, marketing and other program costs directly from participants on a pro rata basis. However, it does need to be kept in mind that allocating all the administrative costs to initial program set-up and delivery would undermine the business case for early adopters of such a program.
However, efficiencies of scale over time present a financially sustainable model for delivering such a program. Energy efficiency upgrades are labour-intensive and provide a significant economic stimulus when carried out on a large scale. The American Council for an Energy-Efficient Economy notes that in the construction industry there are about 20 jobs created per $1 million spent on energy upgrades, compared to half as many in power generation and distribution.
Many municipalities are considering creating their own energy efficiency programs to fill the gap left by the withdrawal of the provincial and federal governments from incentive-based programs. Building on this desire, since 2012 the Clean Air Partnership has been working with the CHEERIO program—collaboration on home energy efficiency retrofits in Ontario. Through our experience with the CHEERIO program, we have a keen understanding that the greenhouse gas reductions associated with LICs are only achieved when carried out at scale.
However, a number of barriers exist in Canada preventing the scale-up of LIC programs. There are three key areas where the Government of Canada could intervene to facilitate the rapid uptake of residential GHG reduction measures: The first is access to capital; the second is credit enhancements; and the third is addressing mortgage lender and insurer concerns.
With regard to access to capital, a key barrier associated with LIC program scale-up relates to the upfront capital required to finance the actions that will lead to significant energy and greenhouse gas savings over time. Until now, municipalities have largely considered programs that would rely on public funds to provide initial capital, which are limited and compete with other municipal needs. Municipalities must respect provincial requirements concerning debt load, where they can maintain specific maximum debt-to-revenue ratios.
There is a timely opportunity for the Government of Canada to provide capital to initial LIC programs, reducing the need for municipalities to find it in their own budgets or to qualify for third party lender programs. This would address the upfront capital cost barrier and achieve more significant greenhouse gas reduction in a manner that would, over the longer term, enable those public funds to leverage increased private capital.
On the issue of assisting in addressing mortgage lender concerns, not all LIC/PACE programs require mortgage lender consent. However, LIC programs where there is that requirement have found this to be a major stumbling block resulting in massive potential participant dropout. There are two areas of concern, those of the mortgage lenders—the banks themselves—and those of the mortgage insurers, such as CMHC.
Banks have concerns around threats to the liquidity of mortgages in secondary markets, potential for increased losses associated with mortgage defaults, and concerns around consumer protections.
The second area of concern is from mortgage insurers. The vast majority of Canadian mortgages are insured by the CMHC, and the CMHC has yet to issue a formal position on LIC programs, so homeowners with CMHC-insured mortgages are ineligible to participate in LICs where program design requires lender consent. Natural Resources Canada and the Government of Canada can mitigate some of the aspects of this barrier by leveraging their position to engage in discussions with CMHC and financial institutions.
Credit enhancement is another area where the government could play a key role in accelerating energy efficiency retrofit financing programs. For municipalities that are able to access capital for LIC program development, a second issue relates to the credit enhancement to de-risk the LIC. There is a very small but still possible financial risk to municipalities and/or financial entities providing mortgages for the property associated with the LIC mechanism. The financial risk relates to the loan repayments between the time when a property goes into default and the time when that property and the LIC are taken on by the new owner.
To address this unlikely but possible financial risk, loan loss reserves are currently provided to PACE programs in California, Vermont and other jurisdictions. For example, in California, in June 2014, the California Alternative Energy and Advanced Transportation Financing Authority enrolled eight PACE programs for a total of over 56,000 residential PACE financings valued at over $1.2 billion under the PACE loss reserve program. As of December 2017, they have not received any claims on the loss reserve.
The Government of Canada could create a loan loss reserve to backstop municipal LICs in the unlikely case of default. This provision of a loan loss reserve fund would go a long way toward de-risking the LIC for the municipality and would be instrumental in increasing LIC offerings from municipalities. It would also address financial concerns on the part of the financial institutions providing mortgages, as well as the insurers. It would also make securitized/bundled LIC loans appealing and secure investments from private financial institutions, thereby enabling public investments to be shared and transferred to the private sector, and it would provide a mechanism that would be able to recapitalize those public funds to be reinvested in energy efficiency. In addition, it would send the message to municipalities that Canada wants to help and support municipalities to provide LICs for a variety of energy efficiency programs.
While there are many areas where provinces and municipalities must work together to develop comprehensive home energy efficiency retrofit programs, these three key areas represent opportunities for the federal government to facilitate the development and rollout of these programs nationally.
Given how integral this work is to our mandate and to our greenhouse gas reduction goals, we would be happy to work with Canada, the provinces and Canadian municipalities to advance this mechanism and ensure a more sustainable future for all Canadians.
I am happy to answer any questions that you may have at this time.