1.
Members of the Nova Scotia Affordable Housing Commission,
The signatories to this letter applaud the Minister of Municipal Affairs and Housing for
recognizing affordable housing as a critical issue facing Nova Scotians, and to this end
launching the Affordable Housing Commission in November 2020.
The Nova Scotia Affordable Housing Commission has been mandated to identify sustainable,
and actionable long-term solutions to increase the supply of, and access to affordable housing.
The community of environmental activists, energy efficiency practitioners and social justice
leaders who have signed on to this letter are writing to urge the commission to take a holistic
view of affordability that goes beyond rent to include something often left out of this conversation
-- our energy costs.
CUSP defines energy poverty as spending 6% or more of one's after-tax income on energy
needs, which is double the national median of 3%. According to this definition, 37% of Nova
Scotians experience energy poverty -- meaning they are spending 6% or more of their after-tax
income on energy costs alone. This is the third highest rate of energy poverty in the country.
Many tenants in Nova Scotia are responsible for their own energy costs, meaning that in an
“affordable” unit under the existing Canada Mortgage and Housing Corporation definition (less
than 30% of before-tax income) energy costs could use as much as 20% of the housing budget.
The higher the energy costs, the more challenging it becomes to find rents low enough to stay
below the threshold of affordability.
Electricity in Nova Scotia is 17.1¢/kWh, in contrast to the national average (for the provinces
only) of 13.8¢/kWh. In addition to the higher electricity costs, many existing rental units are
heated with oil - an inefficient and carbon intensive fuel source.
Not only should these costs be factored in when designing supports for folks in housing need,
but the government must work actively to reduce them. Energy efficiency is an intersectional
solution that brings costs down in the existing rental stock, while simultaneously accelerating
Nova Scotia toward it’s emissions reduction and climate change commitments. A barrier to
energy efficiency retrofits in current rental stock is misplaced/split incentives: tenants don't have
the permission to make structural upgrades or take advantage of retrofit programs, while
landlords aren't inclined to make improvements because the tenant bears the utility costs. If we
include energy costs in a regulated definition of affordability, we can encourage landlords to
make upgrades that will benefit their tenants and the environment simultaneously.

2.
For new builds, the province should consider applying more ambitious energy standards rather
than simply meeting the current building and energy codes. Multi-unit residential buildings are
being built across the country to near net zero and passive standards -- meaning that tenants in
these buildings, or the building operators, will have little-to-no energy costs for the life of the
building. Applying forward-looking energy standards to new builds now not only ensures energy
affordability for decades to come, but it preemptively brings buildings to the near net-zero
energy standards that the Government of Canada is seeking to have adopted in 2030. The
National Housing Strategy outlines energy efficiency standards for funded projects, and this
model could be used as a starting point for Nova Scotia.
There are additional benefits to applying an energy efficiency lens to the affordable housing
conversation. Heat waves have become an all-to-common impact of climate change, and this
extreme weather forces tenants to choose between purchasing an air conditioner or struggling
with the health impacts of extreme heat. While new construction is required to follow guidelines
for thermal environmental conditions, similar standards do not apply to the existing building
stock. This is an equity issue, forcing the most vulnerable to sacrifice their physiological health
to avoid taking on an even bigger energy burden. There is innovative and industry-leading work
happening here in Nova Scotia, such as the ReCover Initiative and Efficiency Nova Scotia, that
should be leveraged at scale to improve the thermal performance and energy efficiency of
existing buildings.
The connection between affordable housing and energy costs has also been clearly outlined in
legislation tabled this week in the U.S. Nova Scotia can build on the policy momentum in
Canada and south of the border, and be a leader in solving this complex challenge. We urge
you to consider the impacts of energy costs and the health and safety benefits of improved
thermal comfort as part of the Commission’s recommendations to the Minister. Failure to do so
will result in us missing an opportunity to support Nova Scotia’s most vulnerable, while
simultaneously advancing our climate and economic goals.
Thank you again for your work on this important topic.
Jesse Hitchcock
Nova Scotia Regional Champion for Efficiency Canada
And
Signatories to be added here.