Pre-Budget Consultations

Written Submission

for the

Pre-Budget Consultations

in advance of the

Upcoming Federal Budget

by

The Heating, Refrigeration and Air Conditioning Institute of Canada

August 2023 1

HRAI Recommendations

1. The Government of Canada should invest $25 million over five years in a workforce development and adjustment plan to assist the residential HVACR industry in retraining and re-deploying personnel to meet the mounting challenges of the low carbon economy in a timely fashion.

2. Drawing on the expertise of the HVACR sector, the Government of Canada should introduce targeted financial incentive programs that will encourage investments in upgrading heating, ventilation and air-conditioning systems in industrial, commercial and institutional (ICI) buildings to reduce GHG emissions and energy use while improving indoor air quality, occupant comfort and health.

3. The Government of Canada should work with the HVACR industry and relevant building science and health experts to establish a professional workforce capable of identifying and addressing indoor air quality (IAQ) problems in homes and buildings, with a view to minimizing health risks and creating healthy indoor environments. Relying on guidance from existing authorities (e.g. ASHRAE) this initiative would include professional standards, identification of testing equipping and setting standards for training and certification of IAQ professionals.

4. The Government of Canada should partner with the HVACR industry to develop and implement a communications program that seeks to educate Canadians about the health benefits of investing in improved indoor air quality (IAQ), relying on proven technologies and practices.

INTRODUCTION

Steering the Canadian economy and society through an unprecedented energy transition in the pursuit of reduced carbon emissions has become an increasingly urgent priority for Canadians and their governments. The growing sense of urgency is tempered by concerns that we minimize negative impacts on Canadian families and businesses.

Meanwhile, in the wake of the COVID pandemic, Canadians are more mindful than ever before about the quality of their indoor environments. There is a growing expectation that homes and workplaces should be healthy and supportive of productive lives.

C_a_n_a_d_a_’s_ _HVACR industry has important solutions to offer as we collectively work to address these important priorities. The Heating, Refrigeration and Air Conditioning Institute of Canada (HRAI) and its members possess the technology and the know-how needed to lead the way both towards meeting C_a_n_a_d_a_’s_ _net zero goals and towards making our indoor environments healthier and more comfortable.

As Canadian and global policy makers contemplate the most appropriate pathways to reducing greenhouse gas (GHG) e_m_i_s_s_i_o_n_s_ _i_n_ _t_h_e_ _b_u_i_l_t_ _e_n_v_i_r_o_n_m_e_n_t_,_ _H_R_A_I_’s_ _m_e_m_b_e_r_s_ _represent an essential source of expertise, ingenuity, and entrepreneurial leadership. Having invented central air conditioning and continually refined and improved heating, cooling, ventilation, IAQ and refrigeration technologies, our industry has more than 100 years of experience and expertise in the product solutions and techniques needed to help Canada transition to a low carbon economy.

The HVACR industry in Canada is uniquely positioned to support the Government of Canada in meeting its climate goals. And, as it happens, strategic investments in building retrofits and upgrades will not only reduce GHG emissions from the built environment; they will create important employment opportunities across the country while generally improving the health, comfort, and well-being of Canadians. With appropriate policy directions and support – _most notably supports for workforce preparation -- the HVACR industry is prepared to lead the way for Canadians.

While shepherding this important transition to a decarbonized built environment, the federal government must also, in the wake of a deadly pandemic, ensure that workplaces, schools and other institutional buildings are adequately supported in efforts to keep occupants safe and healthy. There is a new interest from Canadians in healthy indoor environments and the HVACR industry has the technology and know-how to create and maintain healthy, sustainable conditions through proper treatment of air (ventilation, filtration, humidity control, air cleaning).

ABOUT HRAI

T_h_e_ _H_e_a_t_i_n_g_,_ _R_e_f_r_i_g_e_r_a_t_i_o_n_,_ _a_n_d_ _A_i_r_ _C_o_n_d_i_t_i_o_n_i_n_g_ _I_n_s_t_i_t_u_t_e_ _o_f_ _C_a_n_a_d_a_ _(_H_R_A_I_)_ _i_s_ _C_a_n_a_d_a_’s_ _n_a_t_i_o_n_a_l_ _non-profit trade association for the heating, ventilation, air conditioning and refrigeration (HVACR) industry, representing over 1,250 member companies across the country. Our members include manufacturers, wholesalers and contractors who collectively employ tens of thousands of skilled trade professionals across the country and contribute more than $12B annually to the Canadian economy. HRAI members are playing an increasingly important role in realizing the aims of governments to address the climate emergency. 3

INVESTING IN THE HVACR WORKFORCE OF TOMORROW

Like many other buildings trades, the HVACR workforce is aging, and the rate of replacement is not keeping up with increased demands for the services of this industry. In addition to the challenge of an aging and declining workforce, the HVACR industry – _most notably the residential sector -- needs specific retraining and upskilling, as technicians (installers, servicepersons) struggle with new technologies like heat pumps that can deliver significant carbon reduction b_e_n_e_f_i_t_s_ _b_u_t_ _a_r_e_n_’t_ _w_e_l_l_ _k_n_o_w_n_._ _T_h_e_ _i_ndustry is busy keeping up with the conventional demands of a market that remains dominated by natural gas. Without strategic investments in training on new technologies, and the skills needed to work with these technologies, as well as financial incentives to pursue such training, there is a serious risk that the pace of adoption and adaptation will severely lag what the market needs, and what government targets demand.

The HVACR industry will play a critical role in the transition to a low-carbon economy. To realize the full potential will require three workforce development elements, and these will require various forms of support from government:

  • • _Supporting a smooth transition: The HVACR sector will eventually navigate to where the market is going but, without a shift in business culture, it will not do so at the pace that meets government targets. HRAI proposes to partner with governments to educate the HVACR sector about the need for change and the opportunities it will bring -- to ensure the energy transition proceeds smoothly and efficiently with industry leading the way.
  • • _Development of standardized formal training and certification standards across provinces and territories: There is a growing need for training on residential heat pumps that is not currently being met. The explosion of demand for heat pumps is being accelerated by de-carbonization support programs. Adoption of a uniform residential trade certification across the country will ensure these systems are installed consistently and safely, with clearer performance, efficiency and carbon-reduction outcomes. It will improve installation quality, protect consumers, enhance labour mobility (via Red Seal designation), aid industry recruitment and serve as a quality standard for incentive programs. While trade programs are regulated and delivered by provinces, there is a role for the federal government in guiding and supporting adoption of relevant programs.
  • • _Upskilling and re-skilling: There are deficits in the availability of the skills training required to support net-zero emissions in buildings. Existing workers need upgraded training and certification to install more sophisticated and advanced low-carbon technologies safely and properly. In addition to meeting the upskilling needs of existing industry personnel, training can be deployed for re-skilling by creating new employment pathways for displaced workers from other sectors.

Recommendation

HRAI recommends that the Government of Canada invest $25 million over five years in a workforce development and adjustment plan specifically to assist the HVACR industry in retraining and re-deploying personnel to meet the mounting challenges of the low carbon economy in a timely fashion. 4

NATIONAL RETROFIT INCENTIVE PROGRAM FOR INDUSTRIAL, COMMERCIAL AND INSTITUTIONAL (ICI) BUILDINGS

The Canada Greener Homes program is aiding Canadian homeowners to invest in home energy retrofits and to adopt energy efficient, low-carbon technologies. There is enormous potential for similar gains to be made in the industrial, commercial, and institutional sector through strategic and well-timed program investments. In addition to significantly reducing carbon emissions, lower energy costs and better performing heating and cooling systems will benefit businesses in nearly all sectors.

Driving down costs for business owners and institutions should be an important part of the economic recovery. It is one of the most compelling reasons to invest in the performance of C_a_n_a_d_a_’s_ _b_u_i_l_t_ _e_n_v_i_r_o_n_m_e_n_t_._ _An even more compelling reason is the potential progress that improved performance will make toward reaching C_a_n_a_d_a_’s_ _a_m_b_i_t_i_o_u_s_ _climate goals.

Ca_n_a_d_a_’s_ _built environment contributes 18% of total GHG emissions in the country1 -- the equivalent of 111 million tonnes of greenhouse gases per year. One of the most significant barriers to investments in new equipment and more efficient systems are initial costs and lack of awareness. Simply put, it is harder to sell upgraded, more energy efficient, low-carbon heating, cooling and ventilation systems to businesses when conventional, lower cost alternatives are available. The case is compelling but the challenge to move decision-makers from fossil fuels like natural gas in favour of low carbon technologies persists.

1 https://www.nrcan.gc.ca/energy-efficiency/green-buildings/24572

Industrial, commercial and institutional property owners would benefit from significant cost savings over the long-term if they could be incentivized to overcome the higher up-front costs of more efficient and lower carbon systems. The tax incentives proposed in the 2023 budget will help, but targeted incentive programs are also needed to achieve a lasting impact across the country.

Readying the marketplace is critical, and our members – _HVACR contractors and their suppliers -- are prepared to deliver significant improvements to buildings and facilities. We are asking the federal government to support making investments that will help them overcome these up-front barriers for the benefit of workers, residents, families and the environment. The returns to businesses would be significant while creating jobs and reducing emissions.

Recommendation

Drawing on the expertise of the HVACR sector, the Government of Canada should introduce targeted financial incentive programs that will encourage investments in upgrading heating, ventilation and air-conditioning systems in industrial, commercial and institutional (ICI) buildings to reduce GHG emissions and energy use while improving indoor air quality, occupant comfort and health. 5

IMPROVING INDOOR AIR QUALITY IN CANADIAN HOMES AND BUILDINGS

The pandemic put a new light on the importance of maintaining healthy indoor environments. Ventilation, humidity control, air cleaning, and filtration can provide important indoor environmental protections against the spread of harmful airborne contaminants, including the potential transmission of viruses. Measures to improve indoor air quality are among the key mitigation actions that Canadians can take in the environments where they live, work, learn and play to reduce the spread of the virus and other harmful pathogens.

HRAI members are prepared to do more to provide needed expertise and guidance for minimizing the risk of aerosolized virus transmission while optimizing indoor air quality and improving the health, productivity and well-being of Canadians. But there is a need to establish/adopt professional standards to guide activities and a need to raise public awareness about the need for acting on sound advice.

The challenge is that, while there is good information available to guide Canadians towards making sound investments in the indoor air quality (IAQ) of their homes and buildings, there are also many self-proclaimed experts who will act opportunistically to take advantage of exaggerated indoor air quality concerns. The difficulty is in separating scientifically supported solutions from those that make promises they cannot deliver. Canadians would benefit from better and more clearly communicated standards in this area.

Recommendations

To assist in creating effective indoor air quality solutions for homes and business, HRAI recommends that the Government of Canada:

  • A) Work with the HVACR industry and relevant building science and health experts to establish a professional workforce capable of identifying and addressing indoor air quality (IAQ) problems in homes and buildings, with a view to minimizing health risks and creating healthy indoor environments. Relying on guidance from existing authorities (e.g. ASHRAE) this initiative would include professional standards, identification of testing equipping and setting standards for training and certification of IAQ professionals.
  • B) Work with the HVACR industry to develop and implement a communications program that seeks to educate Canadians about the health benefits of investing in improved indoor air quality (IAQ), relying on proven technologies and practices.

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