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Toronto Prepares Green Roof By-law Compulsory, Costly Element Could Complicate Integrated Design
September, 2007
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NEW AVENUE FOR ENERGY EFFICIENCY INCENTIVES
A recently approved community improvement plan (CIP) in Welland provides the first example of incentives for energy efficiency and sustainability that Ontario municipalities are now allowed to offer to the private sector. Welland's Brownfield CIP uses LEED (Leadership in Energy and Environmental Design) benchmarks as a basis for grants, permit/planning fee reductions and development charge exemptions.
In recent years, several Ontario municipalities have adopted CIPs as a means to encourage downtown redevelopment or the cleanup and redevelopment of derelict lands known as brownfields. Amendments to the Ontario Planning Act passed earlier this year have broadened the range of development eligible for incentives to include "the provision of energy efficient uses, buildings, structures, works, improvements or facilities."
Although Welland's CIP is targeted to brownfield lands, the provincial legislation would allow a municipality to provide incentives for energy efficiency on greenfield lands or on a citywide basis if the approach for doing so was defined in a CIP.
"We were just finishing work on our CIP as the Planning Act changed so the timing worked out to our benefit," says Don Thorpe, General Manager of Planning and Development Services for the City of Welland. "I think the critical component of what we've done is including the costs associated with LEED as an eligible cost for the rehabilitation grant program."
That program is funded through the tax increment, which is the increased property tax revenue arising from the owner/developer's investment in upgrading the property. Eligible recipients are rebated a sliding portion of that increment over a number of years to help recover their costs for environmental remediation, infrastructure investment and/or LEED construction.
Grant amounts are scaled to the LEED level achieved. Developers/owners of projects that do not achieve LEED certification would be eligible for a rebate equivalent to 70% of the tax increment in the first year of the 10-year program, with rebates dropping off to 20% by the 10th year. Rebates increase with each level of LEED so, for example, a LEED gold project would recoup 80% of the tax increment in each of the 10 years of the program. (For more information, see www.city.welland.on.ca/Development/BF-Presentation.pdf)
Projects attaining any level of LEED would collect discernibly better returns than non-certified projects. The performance-based criteria for grants could also help make the economic case for extra or bigger ticket items that could move a project up to the next level of certification. "If a green roof is part of the LEED certification on a Welland brownfield site, the extra cost of the green roof can be included as an eligible cost and rebated in the form of a grant from the City," notes Luciano Piccioni, President of RCI Consulting, a firm specializing in municipal financial incentive programs and brownfield redevelopment, and the consultant who prepared Welland's CIP.
The City of Toronto has not yet explored options for a CIP to support initiatives in the recently adopted Climate Change, Clean Air and Sustainable Action Plan, which includes plans to institute a by-law requiring and governing green roofs.
"I wouldn't want to speculate on that," says Joe D'Abramo, Manager of Policy & Research with Toronto City Planning. "We have the [green roof pilot] incentive program now and that's what we are going to rely on."
That incentive provides $5 per square foot to a maximum of $100,000 toward the construction of a green roof.
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By Barbara Carss
Green roofs are an optional and relatively rare element of LEED (Leadership in Energy and Environmental Design) certified development, but they could soon become mandatory for some new construction projects in Toronto. A draft by-law to establish conditions for requiring and governing green roofs should be ready for the Planning and Growth Management Committee's consideration later this fall.
No other Ontario municipality could adopt such a by-law. Toronto's unparalleled authority to do so is set out in Section 108 of the City of Toronto Act, 2006. This allows Toronto to mandate green roofs even though such a requirement exceeds the standards of the Ontario Building Code.
"The City of Toronto has this very unique circumstance. We are actually allowed to determine a whole standard for construction," says Joe D'Abramo, Manager of Policy & Research with Toronto City Planning.
Toronto's voluntary Green Development Standard (featured in Canadian Property Management, October 2006) lists three alternatives for reducing urban heat island effect: 1) a green roof covering 50% of the roof's surface area; 2) light coloured, highly-reflective roofing materials (also known as high-albedo or white roofs) on at least 50% of the surface area; or 3) a combination green roof/white roof covering at least 75% of the roof's surface. More recently, though, the new Climate Change, Clean Air and Sustainable Action Plan, which City Council unanimously endorsed in July, calls for a reexamination of the Green Development Standard, including making green roofs compulsory in some situations.
Just prior to instructing City staff to begin work on a by-law that would make green roofs a requirement of all new "large residential and community developments," Council agreed to increase the incentives offered through Toronto's green roof pilot program. It was launched in 2006 and initially provided about $1 per square foot toward the construction of green roofs in the city. That incentive has now been increased to $5 per square foot to a maximum of $100,000 for commercial, industrial and multi-residential construction projects.
Proponents point to a green roof's multifold capacity to: reduce urban heat island effect; mitigate storm water runoff; provide insulation that lowers cooling and heating loads and associated greenhouse gas emissions; and potentially extend the service life of roofing membranes. However, many green building advocates maintain that there are ways to achieve similar outcomes with less capital expense and a quicker payback.
"We do support the idea of putting green roofs on buildings, but we much prefer the idea of choice to provide what could be the equivalent to green roofs. I'm not sure if putting a green roof on a 33- or a 54-storey building makes a lot of sense when you could be doing something like a white roof and rainwater harvesting to provide the same benefit," says
Andrew Pride, Vice President with Minto Energy Management and a LEED accredited professional.
"One of the things that we've found is that green roofs tend to be the 'poster boy' for sustainability, but they don't necessarily go together," observes Klaas Rodenburg, Design Coordinator with Stantec's Building Engineering Group and the President of the Alberta chapter of the Canada Green Building Council. "A building could have a green roof and not be that sustainable, or it could be quite sustainable without a green roof."
For example, a new fire and ambulance station in Vaughan recently achieved LEED gold certification - surpassing the LEED silver target that City of Vaughan and York Region originally set as the goal for the development - but it does not have a green roof. Rather, it delivers approximately 35% better energy performance than the standards of the Model National Energy Code for Buildings and a 55% reduction in indoor potable water consumption.
ECONOMICS DISCOURAGE INDUSTRIAL PARTICIPATION
City officials were disappointed that there were no low-rise industrial buildings among the 16 applicants to take advantage of the funding in the first phase of Toronto's green roof pilot program in 2006. "Those are the ones we'd love to get," D'Abramo says.
Industry insiders suggest that remains highly unlikely given current construction and operational cost structures. Green roofs generally cost upwards of $15 per square foot so a $5 incentive represents less than half of the differential between a green and conventional roof, while the $100,000 cap means that available incentives could apply to no more than 20,000 square feet per project.
"Most of the new industrial buildings are well over 100,000 square feet," notes Keith Major, a Senior Vice President of Property Management with Bentall Capital, which manages more than 30 million square feet of industrial space across Canada. "The industrial market is very tight and very cost conscious. In an office/commercial market where capital costs typically exceed $250 per square foot, the extra cost of a green roof might be more easily absorbed, but with industrial, when costs are around $60 to $70 per square foot, adding another $10 to $12 per square foot is a big cost factor."
New industrial development is already occurring primarily in the 905 regions surrounding Toronto and a mandatory requirement for green roofs would do little to reverse that trend. Nor are the operational paybacks there. Since industrial buildings typically aren't air conditioned, green roofs provide no bonus in reduced cooling loads.
"It doesn't do much for reduction of utility costs. The only value is possibly a little bit more insulation in the winter," Major adds. "They're billed as not needing to be watered, but in a summer like this one, you probably would have killed your green roof if you hadn't watered it."
MORE LEEWAY IN LEED
In contrast, most property owners and managers do recognize and endorse the economic and environmental payback from LEED development, which covers a broader range of sustainable building design and construction practices. It provides developers with options for compliance relating to: sustainable sites; water efficiency; energy and atmosphere; materials and resources; indoor air quality; and innovation in design. "The LEED approach is achieving quality buildings," Major asserts.
Through the integrated design approach that LEED encourages, designers could find ways to better balance the extra capital cost of a green roof against the costs of other building systems. A green roof should mean a reduced need for HVAC in commercial/residential development, for example.
However, designers typically begin with a goal for energy savings and building performance rather than a commitment to any single element. Compelling green roofs from the outset could limit flexibility and/or the budget for other kinds of innovation. "If we could find something that is more cost-effective than a green roof or something that is equally costly but with even more benefit, I think developers should be given that opportunity," Pride submits.
"It's a process and it's unique to each project," Rodenburg explains. "A green roof will get you a couple of [LEED] credits, but you can get the same thing by having a high-albedo roof that is very reflective. There are different ways of achieving the same intent and we will try to get the best value for our clients depending on what makes sense for the project."
ATTENTION-GRABBING ATTRIBUTES
A green roof could make more economic sense if the payback goes beyond operational savings. A green roof could contribute to attracting and retaining tenants. Owners could also see marketing perks from promoting sustainability - although they would not be able to position themselves as voluntarily "green" if a municipal by-law compels them to invest in a green roof.
Costs will vary depending on the type of green roof. Extensive roofs have lower capital costs because they require a layer of soil only about 100 to 150 millimetres in depth, but this design generally doesn't allow for public access. Intensive green roofs are heavy and expensive to build, but create a gardenlike environment that might draw commercial tenants or residential condominium purchasers.
"The question becomes: what would people pay extra for that would provide the return on investment for the developer?" Rodenburg notes. "Do condo purchasers want a green roof, or do they want a more energy-efficient unit that will save them money in the long-term, or do they want other kinds of upgrades and amenities?"
Most prospective purchasers and casual observers would consider green roofs prettier than a HRV fan coil, which combines ventilation with heat recovery to significantly reduce energy consumption in multi-residential buildings. "Probably that's why green roofs are a popular thing, particularly from a political perspective, because you can easily see and grasp what they do. Whereas, if you look at the building where I work, which is LEED silver, you don't notice that many things that are different from a conventional building because a lot of it is hidden out of sight," Rodenburg muses.
"To me, it seems like the City is focused on one thing that has a big visual impact when there are a lot of other more effective things that can be done," Major says. "Admittedly, though, a more efficient HVAC system doesn't offer as much cache as green roof."
UNIQUE POWER
Some municipalities outside of Toronto are now introducing incentives to encourage LEED development. "These are the kind of policies that can be carried out by carrot or stick, but municipalities don't really have the stick. It's the Ontario Building Code that prevails over building requirements to the greatest extent," reflects Bruce Macgregor, Chief Administrative Officer for York Region, where incentives will be available within designated Regional growth and intensification areas.
Toronto's authority to supersede the Building Code to mandate green roofs is a new power emanating from the City of Toronto Act that seems to have received little scrutiny prior to the passing of the legislation. "I think it went a little bit unannounced," D'Abramo observes. "It kind of surprised a lot of people."
Adoption of an actual by-law is still some time off. City staff is currently consulting with stakeholders in advance of preparing a draft by-law. The Planning and Growth Management Committee will likely get a first look at that draft at its November 2007 meeting. From there, there will be more public consultation before anything is forwarded to City Council for a decision.
"This is a new field for us," D'Abramo acknowledges. "We've never really done anything like this."
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