Net zero greenhouse gas (GHG) buildings in Quebec in record time

December 6, 2022 | Adina Georgescu

(Special thanks to Feriel Fatiha Djemame)

On April 7, 2016, the Government of Quebec (the “Government”) released the 2030 Energy Policy (the “Policy”)[1], which sets out Quebec’s goal of becoming a North American leader in energy efficiency and renewable energy by 2030. Accordingly, on November 16, 2020, the Government unveiled its 2030 Plan for a Green Economy [2] (the “Plan”), which prioritizes more extensive electrification and the development of the bioenergy sector.

I. The 2030 Energy Policy and its implementation

The Policy defines Quebec’s energy transition strategy until 2030. Its objectives include promoting a low-carbon economy, making optimal use of Quebec’s energy resources and taking full advantage of the potential of energy efficiency.

To achieve these objectives, the Government has adopted five targets to be met by 2030, including increasing the share of renewable energy in total energy production by 25% and increasing bioenergy production by 50%. To meet these targets, the Policy calls for the amendment of Quebec’s legal framework[3] and for the adoption of 4 action plans, which include the Plan.

II. The 2030 Plan for a Green Economy

The Plan aims to reduce greenhouse gas emissions (“GHG”) by 37.5% below 1990 levels by 2030, notably through the implementation of measures such as increasing the electrification of transportation and buildings, reducing the free allocation of emissions allowances to the industrial sector and increasing the use of other forms of renewable energy[4].

One objective of the Government is to reduce GHG emissions resulting from heating in buildings by increasing conversion from an energy supply based on fossil fuels (oil and gas), to electricity[5]. The Government also intends to prioritize renewable energy and the use of low-carbon materials in the construction and renovation of buildings[6].

III. New energy transition obligations for building owners at the municipal level

It is in this context that in December 2020, the City of Montreal adopted its 2020-2030 Climate Plan[7] (the “Climate Plan”), which aims to achieve carbon neutrality by 2050. The city’s plan calls for the implementation of 46 measures to reduce GHG emissions in the metropolitan area[8]. This includes the decarbonation of the building sector, which currently accounts for nearly 30% of the total GHG emissions, making it the second-largest contributor of the city’s total emissions after the transportation sector[9]. Specifically, the Climate Plan calls for a complete ban on the use of fossil fuels in all municipal buildings and their replacement with renewable energy by 2030[10].

While the city’s carbon neutrality goal was set to be met by 2050, the current administration announced last May that it was bringing it forward by 10 years by publishing its Roadmap towards zero-emission buildings in Montreal by 2040[11] (the “Roadmap”). The Roadmap sets out various steps to decarbonize all buildings (commercial, residential and institutional) in the city by 2040[12].

The roadmap contains two phases, the first for new buildings and the second for already existing buildings[13]. For new buildings, the roadmap calls for the adoption of a new regulation by 2023 that will require a zero emission performance threshold for new building permit applications[14]. As for existing buildings, the city plans to impose gradual GHG reduction performance thresholds so that all buildings may be supplied by 100% renewable energy by 2040.

These new obligations are in addition to By-law 21-042 respecting GHG emission disclosures and ratings of large buildings adopted in 2021 and already in force, which requires building owners to disclose each year the level of GHG emissions resulting from energy consumption of their buildings in order to allow the city to implement measures to reduce these GHG levels[15].

The city of Gatineau, in the Outaouais region, followed suit by adopting its own climate plan to reduce GHG emissions. The neighboring city of Chelsea has also indicated its desire to reduce its GHG emissions by focusing on large-scale geothermal energy[16].

Similarly, the City of Sherbrooke plans to implement a climate plan by the end of 2022 in order to achieve its goal of reducing its GHG emissions of 30% below 2009 levels by 2030[17]. The city also intends to address GHG emissions resulting from building heating[18].

It is apparent there is a clear willingness of cities and municipalities across Quebec to commit to the fight against climate change in a very concrete way. Other cities and municipalities in the province are moving to adopt climate plans and to impose new obligations for building owners with the objective to reduce GHG emissions. This will have a direct financial and administrative impact on building owners who will need to comply with new standards and requirements within a relatively short time frame.

[1] 2030 Energy Policy: Energy in Québec – A Source of Growth, Ministère de l’Énergie et des Ressources naturelles, Gouvernement du Québec, .

[2]  The 2030 Plan for a Green Economy(Plan pour une économie verte 2030, Politique-cadre d’électrification et de lutte contre les changements climatiques).

[3] See, for example: An Act to implement the 2030 Energy Policy and to amend various legislative provisions, SQ 2016, c 35; Petroleum Resources Act, CQLR. c H-4.2; An Act mainly to ensure effective governance of the fight against climate change and to promote electrification, SQ 2020, c 19.

[4]  Supra, note 2.

[5] The Plan, p 53-54.

[6] The Plan, p 53-54.

[7] Plan Climat 2020-2030, Ville de Montréal.

[8] Id.

[9] Plan climat 2020-2030 – Première reddition de compte annuelle (Ville de Montréal)

[10] Climate Plan, p 89.

[11] Roadmap towards zero-emission buildings in Montreal by 2040 (La Ville accélère le pas de la transition écologique et annonce sa feuille de route Vers des bâtiments montréalais zéro émission dès 2040), p 1.

[12] Roadmap, p 2.

[13] Roadmap, p 2.

[14] Roadmap, p 2.

[15] Règlement 21-042 de la Ville de Montréal, art 1.

[16] Plan d’action en développement durable 2018-2021 – Municipalité de Chelsea, p 26.

[17] Ville de Sherbrooke – Plan climat, .

[18] Ville de Sherbrooke – Plan climat, .


This publication is provided as an information service and may include items reported from other sources. We do not warrant its accuracy. This information is not meant as legal opinion or advice.

Miller Thomson LLP uses your contact information to send you information electronically on legal topics, seminars, and firm events that may be of interest to you. If you have any questions about our information practices or obligations under Canada's anti-spam laws, please contact us at

© 2023 Miller Thomson LLP. This publication may be reproduced and distributed in its entirety provided no alterations are made to the form or content. Any other form of reproduction or distribution requires the prior written consent of Miller Thomson LLP which may be requested by contacting