Building Performance Standards: An Emerging Policy Tool for Existing Building Decarbonization

The pathway towards deep decarbonization must go through existing buildings. Today’s existing building stock accounts for roughly 40% of the energy-related global greenhouse gas (GHG) emissions and approximately two-thirds of that stock will still exist in 2050. Six cities (Boston, MA; Chula Vista, CA; Denver, CO; New York, NY; St. Louis, MO; and Washington, DC) and two states (Colorado and Washington) have become trailblazers by enacting laws to establish the nation’s first building performance standards (BPSs) focused on existing buildings. BPSs are different from traditional building energy codes and other building policies (e.g., benchmarking ordinances, audit requirements, retro-commissioning requirements) because they require the energy performance and/or GHG emission impacts of certain types of existing buildings to be improved by a certain date, even if the building owners do not otherwise trigger the energy code. 

BPSs utilize benchmarking data to set standard performance targets for different building types. Building owners can realize energy-savings benefits while cities and states can spur job creation and make progress towards their energy and climate goals. The trailblazing jurisdictions have different rulesets for their BPSs and some implementation details are still being finalized. Below is snapshot of the current BPSs and how they differ:

• Washington, DC: Enacted in 2018 with an initial performance year of 2021. The key performance metric is an ENERGY STAR score, and the impacted buildings are commercial and multifamily buildings 10,000 square feet and greater.
• New York, NY: Enacted in 2019 with an initial performance year of 2024. The key performance metric is GHG intensity metric, and the impacted buildings are commercial and multifamily buildings 25,000 square feet and greater.
• Washington state: Enacted in 2019 with an initial performance year of 2026. The key performance metric is weather-normalized site energy use intensity (EUI), and the impacted buildings are commercial buildings 50,000 square feet and greater.
• St. Louis, MO: Enacted in 2020 with an initial performance year of 2025. The key performance metric is site EUI, and the impacted buildings are commercial and multifamily buildings 50,000 square feet and greater.
• Boston, MA: Enacted in 2021 with an initial performance year of 2025. The key performance metric is GHG intensity metric, and the impacted buildings are commercial, municipal, and multifamily buildings 20,000 square feet and greater.
• Chula Vista, CA: Enacted in 2021 with an initial performance year of 2023. The key performance metrics are an ENERGY STAR score or weather normalized site EUI, and the impacted buildings are commercial, multifamily, and public buildings 20,000 square feet and greater.
• Colorado state: Enacted in 2021 with an initial performance year of 2026. The key performance metrics are to be developed by the Air Quality Control Commission in collaboration with a BPS task force. The impacted buildings are commercial, multifamily, institutional, and public buildings 50,000 square feet and greater.
• Denver, CO: Enacted in 2021 with an initial performance year of 2024. The key performance metric is weather-normalized site EUI, and the impacted buildings are commercial and multifamily buildings 25,000 square feet and greater.

In addition to cities and states, the White House announced in May 2021 that the Council on Environmental Quality is, “launching an interagency Federal sustainability effort with [General Service Administration] GSA, [Department of Energy] DOE, and [Environmental Protection Agency] EPA to develop the first-ever BPS for the federal government. The BPS will establish metrics, targets, and tracking methods to reach federal carbon emissions goals. The performance standards will identify progressive performance milestones as well as the resources that agencies need to meet them.” The DOE, EPA, and the California Energy Commission (CEC) have all recently produced materials and/or hosted events that provide BPS resources. DOE and EPA support software tools, such as Portfolio Manager, Building Energy Audit Template, and the SEED Platform, that can assist with BPS data collection and compliance. In addition, the Institute for Market Transformation (IMT) maintains useful resources on BPS. 

Cities and states interested in developing BPSs to support decarbonization will need to carefully consider the following issues: building segment and size threshold, performance metric, performance target triggers, regulatory and legal barriers, stakeholder engagement, compliance pathways, and opportunities for integration with existing energy efficiency strategies (e.g., codes & standards, reach codes, incentive programs, benchmarking and labeling).

The Statewide Reach Codes Program, administered by Pacific Gas and Electric Company, San Diego Gas & Electric Company, and Southern California Edison Company, is interested in working with and supporting California cities, counties, and stakeholders that are pursuing BPSs. For those interested, please reach out to Alex Chase at alexchase@2050partners.com or Misti Bruceri at mistib@mbaenergy.com.