Large Buildings in Montréal: Is Your Co-ownership Required to Report Its Energy Consumption?

Montréal co-ownerships with 25 or more dwelling units, or buildings with a floor area of 2,000 m² or more, are subject to the By-law concerning the disclosure and rating of greenhouse gas (GHG) emissions from large buildings. Each year, the owners concerned must provide the City with certain data on their building's energy consumption.

Adopted in 2021 as part of the City of Montréal's Climate Plan, By-law 21-042 aims to provide a better understanding of the energy consumption and GHG emissions of large buildings in Montréal. The data collected is intended, among other things, to enable the City to compare building performance and develop measures to reduce emissions.

For syndicates of co-ownership concerned by the by-law, this primarily means an annual obligation to disclose the building's energy consumption data.

Which co-ownerships are subject to the by-law?

The by-law applies to existing residential, commercial and institutional buildings located within the territory of the City of Montréal that meet at least one of the following two criteria:

• a floor area of 2,000 m² (21,528 sq. ft.) or more;
• 25 dwelling units or more.

A co-ownership with 25 or more units may therefore be subject to the by-law even if its floor area is less than 2,000 m². Conversely, a building with fewer than 25 units may also be subject to the by-law if it meets the floor-area threshold.

Certain exceptions apply, including buildings whose predominant use, as listed on the property assessment roll, includes an industrial use, as well as certain buildings already subject to provincial GHG emissions reporting requirements.

The City publishes a list of buildings it considers subject to the by-law. However, the absence of a building from this list does not automatically exempt its owner from complying with the by-law if the building meets the applicable criteria.

A declaration to be submitted every year

Owners of buildings subject to the by-law must provide the City, no later than June 30 of each year, with monthly energy consumption data for the entire building covering the period from January 1 to December 31 of the previous year.

For a co-ownership, it is therefore important for the syndicate and its manager, where applicable, to determine whether the building is subject to the by-law and ensure that the necessary information is available for the annual declaration.

How are the data submitted?

Disclosure is primarily carried out using ENERGY STAR Portfolio Manager (ESPM).

The process includes the following steps:

1. Identify the building using the Montréal Disclosure Standard ID assigned by the City;
2. Create or use an ENERGY STAR Portfolio Manager account and add the building;
3. Provide the required information, including the address, type of use, floor area and energy consumption data;
4. Submit the data to the City before the annual June 30 deadline.

It is also possible to enable the automatic transfer of consumption data from Hydro-Québec and Énergir to ENERGY STAR Portfolio Manager, which can simplify the collection of the information required for the declaration.

Why are these data collected?

The objective goes beyond the production of an administrative declaration. The City aims to establish a more accurate picture of GHG emissions from large buildings in Montréal in order to compare their performance and identify measures that can improve their energy efficiency.

The by-law also provides for a GHG emissions performance rating system for buildings. Ultimately, this approach is intended to make it possible to assess a building's performance in comparison with similar buildings and support efforts to reduce emissions.

For syndicates of co-ownership, monitoring energy consumption can also become a useful tool for better understanding a building's performance and identifying measures that could reduce its energy consumption and energy costs.

An obligation to integrate into co-ownership management

For Montréal co-ownerships subject to the by-law, annual disclosure should be incorporated into the syndicate's management calendar, alongside other recurring obligations related to the administration and maintenance of the building.

In particular, syndicates should verify whether their building is subject to the by-law, retain the information required for the declaration and allow sufficient time before the June 30 deadline to validate and submit the data.

The City of Montréal provides owners and managers with several guides and resources to assist them with the process, including detailed information on the application of the by-law and resources on the use of ENERGY STAR Portfolio Manager.

To learn more about the requirements, determine whether your building is subject to the by-law and consult the available resources, visit the City of Montréal's webpage on the By-law concerning the disclosure and rating of greenhouse gas emissions from large buildings.