UNA’s Response to Proposed Changes to REAP
The Residential Environmental Assessment Program (REAP) is the regulatory mechanism for achieving UBC’s climate, sustainability, and ecological goals for development in the UNA neighbourhoods. It does this through a combination of mandates and incentives (involving a certification system akin to LEED). The UNA’s Land Use Advisory Committee (LUAC) offers the following feedback on the proposed updates to REAP.
In sum, the proposed REAP 3.3 amendments do not fully reflect UBC’s Climate Action Plan goals and need further revision. UBC should complete a Neighbourhood Climate Action Plan (NCAP) first, in order to set specific climate, sustainability, and ecological targets for neighbourhood development. UBC should then update REAP to calibrate the mix of mandates and incentives to achieve the NCAP targets.
NCAP targets and subsequent REAP requirements will have financial and infrastructural implications for land-use planning. UBC should not adopt a new Land Use Plan until it has clear NCAP targets and consequent REAP requirements in place. We are concerned that the draft Land Use Plan under consideration is premised on older environmental and financial assumptions that are not compatible with the University’s current climate and sustainability priorities.
Prior to updating REAP standards, UBC should answer the following questions:
Given the lack of an updated Neighbourhood Climate Action Plan (NCAP) and available reporting or monitoring of REAP, it’s not clear what targets the REAP 3.3 guidelines aim to achieve, nor how it performs. NCAP targets are necessary to set the appropriate REAP mix of mandates and incentives, and to determine how incentives should be weighted.
With the UBC general Climate Action Plan (CAP) as a guide, there should be specific targets in the following areas:
REAP mandates should ensure that neighbourhoods meet UBC CAP targets. Mandates should include, among other things: energy efficiency standards, low-carbon energy sources, and unit-level metering for energy and water usage.
The incentives (points earned towards REAP Gold or Platinum certification) should reflect the relative priority UBC puts on the CAP’s climate, sustainability, and ecological targets. The proposed incentives for embodied carbon reductions (5pts) and mass timber construction (2pts) seem low relative to potential benefits and to construction costs involved. We are not convinced that any developer would choose to reduce embodied carbon and/or build with mass timber at these incentive levels.
Non-compliance can come in two forms: 1) developer does not achieve mandated and/or incentivized goals in the construction process; 2) constructed buildings do not achieve operational targets. In general, compliance measures should combine incentives and offsets sufficient to ensure that the neighbourhoods meet climate, sustainability, and ecological targets of the NCAP.
REAP should mandate monitoring and reporting of key indicators, including embodied carbon, GHG emissions, and energy and water-use efficiency. Future REAP updates should remedy gaps between targets and outcomes.
The Residential Environmental Assessment Program is the single most important regulatory mechanism for setting and enforcing climate and sustainability goals in UBC’s neighbourhoods. Its mandates and incentives should reflect a precise set of environmental targets, which have yet to be detailed for the neighbourhoods. We urge UBC to complete a Neighbourhood Climate Action Plan with the same rigour as the Climate Action Plan for the academic campus, and then revise REAP accordingly.