CleanBC Feedback - A letter

Recently, the Government of British Columbia launched an independent review of CleanBC program with the goal of ensuring "they are effectively reducing emissions, making life more affordable, and supporting a strong economy.”

More details on the review process can be found here.

A copy of the letter written by myself, Councillor Lubik and Mayor Lahti is reproduced below. We submitted this by email on July 18, 2025.

Submission to CleanBC

Dear reviewers,

We are writing to provide feedback on CleanBC as a health professional, a professional engineer, and a mayor working on climate mitigation and adaptation. In addition to our professional experience, we are all municipal elected officials. Our submission reflects the broad depth of experiences and perspectives we hold.

Note that we speak only for ourselves, and our opinions may not reflect the opinion of the city we are elected to represent.

Policies enabling or encouraging emission reduction

The government’s work to bring in the Energy Step Code (ESC) has been game-changing, and encouraging local governments to expedite the process is an important piece of meeting our collective goals. The Zero Carbon Step Code (ZCSC) adds another tool in the municipal toolbox, enabling local governments to further act on their climate goals while avoiding future emissions and expensive retrofits. However, further support from the Province is needed to combat misinformation on cost, effectiveness and availability of these technologies and systems. 

In addition to energy conserving and emission reduction measures, a greater focus on indoor air quality, especially in existing buildings, is needed to ensure safe and healthy homes for all British Columbians. Increasing summer daytime and nighttime temperatures are consistently coinciding with poor air quality events due to forest fires and pollution. There is a significant amount of literature that demonstrates emission reduction measures positively impact both internal and external air quality, which has the co-benefit of keeping our residents out of the Emergency Departments and doctors’ clinics with air quality-related illness, lowering health system use and costs.

As elected officials, we have seen significant misinformation and misunderstanding on what the ZCSC is and what it means for residents despite the city’s best efforts to educate. Common misunderstandings include thinking that BC Hydro lacks the capacity for buildings to electrify, that gas will be banned in existing buildings, and that electrical outages will mean people freezing to death. There is also a misunderstanding that there are significant costs as opposed to 0-2% and the power cost savings for residents. We recognize that these fears are unfounded; however, they remain points of fear-mongering.

Recommendations:

• Improve public education on the benefits of zero carbon energy systems and provide assurances on BC Hydro’s capacity.

• Ensure BC Hydro can respond to requests for electrical service upgrades more rapidly.

• Improve trades education on air sealing and ventilation in new and existing buildings.

• Consider advancing timelines for ESC and ZCSC highest levels.

CleanBC’s programs and other government spending

While the new BC Building Code requires cooling to be included in new construction, many British Columbians live in existing buildings, especially multi-unit residential buildings (MURBs). CleanBC programs have only recently extended to condos and apartments. Many residents, renters and owners, and strata councils lack the capacity and knowledge to effectively access these programs without assistance. Navigating strata bylaws adds another layer of complexity as some stratas decline to permit window-mounted air conditioning or heat pump installation.

Continued funding programs such as ZEIC’s Strata Energy Advisor and BC Retrofit Accelerator are key to addressing GHG emissions from existing buildings, while improving occupant comfort. In addition, continuing to provide education on these programs and benefits to strata managers that manage over 34,000 strata corporations in BC will provide significant health benefits and financial savings to the more than 1 million people who reside in these buildings. Funding for expansion of on-the-ground outreach to lower income and vulnerable residents, such as through the Youth Climate Corps, is also critical to ensure uptake by those most in need.

The BC Hydro free A/C program was a great initiative to keep our residents safe in high temperatures, particularly the most vulnerable. This program should be restarted and expanded to reach those most in need, particularly those who are not connected to the healthcare system. While portable air conditioners may increase energy use, it is also imperative to coordinate with all levels of government on tree planting, external shading, low albedo roofing/green roof retrofits in older affordable buildings, and ensure bylaws and policies support thermal comfort. Portable air conditioners should be viewed as temporary measures meant to protect the health and safety of residents while completing climate-smart building and unit retrofits (e.g., installation of heat pumps).

Passive measures, such as those described above, can decrease the need for energy and cooling use, while understanding that mechanical cooling will still be necessary. Similarly, there is a need to have retrofits and programs that promote external shading, such as awnings and films, and shutters. These programs also need to be evaluated to understand if they are reaching the most vulnerable community members, and if not, what can be done to support them. 

Bills 44 and 47 are well-intended to advance the construction of much-needed housing, but may have the unintended consequence of harming urban tree canopy and creating urban heat islands. In rural communities, it may be prudent to understand the pressure that may be put on already-strained aquifers and water sources. This could be amended to allow local governments to show how they will meet targets, but not necessarily by meeting the densities currently set out.

A key factor in urban heat islands and GHG emissions is transportation. It is imperative to continue to provide funding for expanded transit and cycling infrastructure. Public transit and cycling, along with other active modes of transportation, will help reduce GHG emissions and strain on road infrastructure. Equitable investment in getting people out of their cars and onto transit or bicycles is imperative. It is far more important to provide incentives for e-bikes than electric vehicles.

Recommendations:

• Increase available incentives for ventilation when combined with ductless heat pumps.

• Amend the Strata Property Act to make it easier for owners to install heat pumps, similar to the changes made to allow EV charging in strata properties. 

• Consider providing alternate pathways for meeting the conditions set by Bills 44 and 47 to minimize urban heat island effects.

• Continue incentives for e-bikes and other micro-mobility devices.

Funding opportunities for CleanBC programs

There are many opportunities to create funding sources for CleanBC programs, including:

1. Implement congestion pricing, similar to New York, Stockholm and London, or provide legislative authority to regional and local governments. Congestion pricing revenues can be reinvested in public transit and active transportation.

2. Reduce subsidies and tax credits provided to fossil fuel companies, similar to the tobacco industry; reform fossil fuel royalties and redirect revenue (and savings) to CleanBC programs.

3. Increase tax on larger corporations (include review of corporate tax structure to make the tax structure more progressive).

4. Explore providing cities with legislative authority to assess alternative forms of taxation, including income tax and land value tax. A report by the Canadian Centre for Policy Alternatives suggests that if the City of Vancouver imposed a one per cent municipal tax on incomes over $246,000 that it could raise $48 million.

5. Develop a fund that is resourced by climate dividends from industrial carbon pricing or royalties from resource extraction, similar to Alaska’s Permanent Fund. This could be a source of funding if dividends and resource royalties were dedicated to climate and CleanBC programs.

6. Develop a Clean Jobs Transition Levy; similar to the Employer Health Tax, a modest payroll levy on large polluters to support clean job retraining and local green economy projects. This could be designed to exempt small BC-based businesses.

7. Digital Carbon footprint tools and voluntary offsets.

8. Climate-aligned consumption taxes that introduce small surcharges on high-carbon luxury goods (e.g., private jets, yachts, high emission vehicles with retail prices above a benchmark). 

Recommendation:

• Consider alternate funding models (beyond the current status quo) to support climate action by local governments and through CleanBC.

Barriers to CleanBC Implementation

The Province missed an opportunity to upskill or reskill workers during the pandemic concerning indoor air quality and ventilation. This opportunity still exists, and government programs need to urgently address indoor air quality, not only from an airborne viral transmission perspective but also from a climate adaptation perspective. The 2021 heat dome tragically demonstrated the consequences of inadequate ventilation and a lack of cooling in existing buildings, especially older multi-unit buildings.

Existing multi-unit residential buildings are poorly represented in CleanBC policies and programs. While we recognize the challenges of stratified MURBs, incentive programs for condo/apartments are challenging for owners to access. In addition, some strata councils do not permit heat pumps to be installed as they lack bylaws that would enable approval. Strata councils and property management companies are not all equipped with the knowledge or desire to rectify this oversight, leaving owners and tenants vulnerable to heat and poor indoor air quality. While the new ZEIC program for stratas is appreciated and important, this program and other incentives for MURBs still rely upon strata councils or volunteer organizers to access the program. If this is not a priority or organizational capacity is lacking, unit owners will not benefit. 

Outreach and education of strata property managers are desperately needed, and programs that guide or assist property managers would be beneficial, in conjunction with a concierge or expert.

Note: Engineers and Geoscientists of BC published a practice advisory in 2022, Overheating Considerations for Existing Multi-Unit Residential Buildings, that provides guidance related to overheating, addresses indoor air quality, and minimizes GHG emissions. This guidance document takes a holistic approach to overheating, identifies both passive and active strategies to improve thermal comfort, recognizing that some measures, such as improving insulation and air sealing, may inadvertently increase the risk of overheating. 

In 2024, at the annual UBCM convention, the City of Port Moody brought forward Resolution EB55, calling on the Province to expand the Youth Climate Corps. We did this because the impacts of climate change — including wildfires, floods, and deadly heat waves — are no longer theoretical. They are damaging infrastructure, threatening public safety, and taking lives in communities across B.C. Convention delegates endorsed this resolution.

At the same time, governments at all levels are looking for ways to better engage youth — and to train the next generation of workers for the low-carbon economy we know we need. In a time of rising unemployment, especially among young people, the Youth Climate Corps offers a clear win: living-wage, green jobs that support climate adaptation and mitigation projects in communities across the province. That includes wildfire mitigation, building retrofits, ecosystem restoration, and public engagement.

Youth Climate Corps directly addresses three urgent provincial priorities: the climate crisis, youth unemployment, and the skilled labour gap.

Recommendations:

• Adequately resource and expand funding for StrongerBC: Future Ready plan. 

• Continue to work with ZEIC and CHOA to improve knowledge of strata managers and access to incentive programs for MURBs.

• Provide sustainable and ambitious multi-year funding for the provincial Youth Climate Corps, to grow green jobs across BC.

Alignment with provincial policies and programs

Poverty reduction needs to be woven with mitigation and adaptation. Programs need to be assessed to understand how they are meeting the needs or harming the most vulnerable. The climate crisis is exacerbating divisions in society; some folks are becoming anti-government because they are feeling the effects of the current economic climate (this means retraining resources sector folks and helping communities evolve in a bottom-up fashion away from extraction).

Investment in public health, including social determinants of health such as housing, is critical. People living in encampments are at the mercy of extreme heat, smoke, and cold; we are seeing more extreme weather-related emergency department visits (though this is not always easy to measure). Provision of housing is cost-effective (there are many meta-analyses) and reduces economic and health care system pressures, but would also require an upfront investment.

Recommendations:

• Review existing poverty reduction programs with a climate lens. 

• Incorporate equity and accessibility metrics into CleanBC programs. 

Other innovative and effective approaches

Though it may not seem like it, electoral reform goes a long way to making sure our priorities are not constantly flipping; consensus can be reached, and residents can vote on the issues that matter to them, including climate adaptation and mitigation. A FairVote Canada report notes that jurisdictions with proportional representation tend to have better and more consistent climate policies. Polls show that the majority of BC residents care about the environment and climate change; however, in recent elections, those concerns are often put aside if voters feel the need for strategic voting. Several studies show that jurisdictions with Proportional Representation lead to better environmental outcomes, as summarized in a 2012 study of 26 democracies over 55 years.

Recommendation:

• Reform the electoral system.

Other indicators of progress

There are several indicators of progress that could be used to measure the success of CleanBC and the progress of the province, including the UN Sustainable Development Goals, UNDP’s Human Development Index and Doughnut Economic indicators. Measuring investment, GDP, or GHG emissions per capita, in the absence of consideration of other important factors (resilience, equity), does not provide the full context of the social, environmental, and economic situation. 

Additionally, BCIT’s Centre for Ecocities has done significant work to develop consumption-based emission inventories. Consumption-Based Emissions Inventories (CBEIs) assess the full lifecycle emissions of all goods and services consumed by residents, regardless of where in the world they are produced. This approach captures emissions from food, out-of-boundary travel, embodied materials in buildings, consumable goods, and fuels, especially those generated during extraction, processing, and transportation. Supporting local governments with tools and guidance to develop, assess, and act on CBEIs is another important step to reducing emissions and our environmental impact both within our borders and across the globe.

Recommendations:

• Consider incorporating indicators of success that measure the full impacts of climate change.

• Provide additional support and guidance to municipalities, such as investing in a consumption-based approach to emission inventories as developed by the Centre for Ecocities.

Thank you for considering our input and the opportunity to provide our unique perspectives as local elected officials and professionals working in this space.

Sincerely,

Samantha Agtarap, P.Eng
Dr Amy Lubik
Meghan Lahti, Mayor of Port Moody