What are Building Performance Standards?
A Building Performance Standard (BPS) is a policy that requires existing buildings to meet specified performance goals, or targets, by certain dates. BPS are targeted at large commercial buildings and usually include large multifamily buildings but his definition changes place to place. Because of their connection to climate goals, BPS targets typically focus on the reduction of buildings’ energy consumption and/or greenhouse gas (GHG) emissions. In addition to providing useful information to cities and states working toward their climate goals, benchmarking data gives building owners an snapshot of their building's performance. Building owners will usually be required to submit building data annually, known as "benchmarking", and comply with the BPS standard every few years, known as a "compliance cycle."
Benefits of Building Performance Standards
The benefits of BPS compliance are many and align with the concept of the “triple bottom line,” which values not only economic prosperity, but also environmental and social/cultural prosperity, none of which are mutually exclusive. To comply with BPS, building owners will likely need to upgrade their building envelopes and/or their equipment, investing in high-efficiency and clean energy systems and practices. Owners will inevitably incur monetary costs; however, they will also see significant returns on investment across multiple dimensions.
Economic Benefits
Environmental and Health Benefits
Social and Cultural Benefits
If a building owner is responsible for paying some or all building utilities, they will see a reduction in utility costs because of their efforts to improve energy efficiency and embrace clean energy. If the utilities costs are passed on to tenants, the utilities savings will be passed on to them. Either way, a building owner benefits from reduced utility bill costs, whether they are paying less for utilities month after month or retaining tenants in part because of low utility costs. Additional savings gained from energy efficiency and clean energy investments may include janitorial and maintenance savings.
Benchmarking and BPS require building owners to understand their building portfolio and its operations, strengths, and weaknesses. This knowledge, coupled with BPS requirements, provides building owners a framework to plan envelope and equipment upgrades proactively and flexibly.
Tenants can be attracted and/or retained by seeing their values reflected in their workplace and/or their business’s building. Communicating about—or even celebrating—a building’s energy efficiency and emissions targets transparently may earn a building and its owner respect and investment from current and prospective tenants. (For more about benefits and occupants, see Social and Cultural Benefits section.)
The increasing adoption of BPS and potentially expensive building decarbonization technologies may seem burdensome to owners. However, with growing demand for these technologies and further normalization of BPS and other decarbonization measures, the market will adapt—and re-adapt—to make these technologies more available, accessible, and affordable.
Building and business owners indirectly benefit from healthier, less harmful built environments, which make for happier, more comfortable tenants and more productive employees. (Read more about occupant health in Environmental and health benefits section below.)
Reducing energy consumption when it is generated by fossil and other nonrenewable fuels avoids depleting the Earth of its limited resources, as well as the intensive processes that are required to extract, process, and transport those resources. Additionally, reducing energy consumption will alleviate some of the burden placed on the electric grid, as well as demand to build out oversized grid infrastructure in the future.
The transition to clean energy sources—most of which are renewable—improves planetary health as well as human health. Clean energy avoids the use of toxic fossil fuels and the resultant pollutants, keeping health threats out of bodies and out of the atmosphere. For example, the replacement of gas stoves with stoves that use electricity or induction would limit harm to human and planetary health. Additionally, installing, maintaining, and upgrading systems that use clean energy instead of fossil fuels is generally safer for all parties.
Minimizing GHG emissions benefits everybody. Slowing emissions will slow the impacts of the climate crisis, maintaining—or, eventually, regenerating—natural systems and livability for all beings on the planet.
Increased energy efficiency and clean energy use contribute to better indoor air quality (IAQ) and healthier buildings overall, in which tenants directly benefit from spending time. High-performing buildings can reduce moisture and temperature fluctuations, and the potential associated health issues these may cause in an indoor environment.
The implementation of existing BPS and the development of many more BPS in the future will require a skilled workforce that is able to understand and retrofit buildings holistically. Because much of this workforce is yet to be developed, there is an immediate opportunity to make the building industry more diverse and inclusive through intentional recruitment, training, support, and program design
High-performance buildings require sufficient insulation and airtight exterior envelopes, making them unlikely to experience extreme temperature shifts due to exterior conditions. This consistency allows occupants agency and predictable conditions when it comes to their own comfort.
When buildings become more energy-efficient, they need to consume less energy to operate. This means that high-performance buildings may offer relief of energy burden for low- and moderate-income occupants, by lowering their energy use and therefore lowering their energy costs. Those who contribute the least to the climate crisis are often impacted the most and to act accordingly. It is important to remember this and account for equity and climate justice while addressing one’s own climate impacts.
Understanding Your BPS
1
Identify If Your Building is Covered
You will need to know the building use type of your building (office, multifamily, warehouse, data center, etc) and the size of your building in square feet (sf). Then search the regulation to find the size threshold which will likely be written as “buildings greater than x square feet”
Recommended search terms: “covered,” “square feet,” “sqft”, “threshold,” “excluded,” “exclusion.”
Recommended search terms: “covered,” “square feet,” “sqft”, “threshold,” “excluded,” “exclusion.”
2
Identify Timelines
Make note of reporting requirements and compliance deadlines
Recommended search terms: “due,” “report,” “reporting,” “disclose,” “disclosure”, “timeline”, “cycle”
Recommended search terms: “due,” “report,” “reporting,” “disclose,” “disclosure”, “timeline”, “cycle”
3
Identify The Metrics
Identify what you are being expected to measure and reduce. What units are being used?
Recommended search terms: “kWh,” “MWh,” “kBtu,” “carbon dioxide,” “CO2,” “EUI,” “GHG”
Recommended search terms: “kWh,” “MWh,” “kBtu,” “carbon dioxide,” “CO2,” “EUI,” “GHG”
4
Identify the standards you are required to follow
Recommended search terms: “performance standards,” “kWh,” “MWh,” “kBtu,” “carbon dioxide,” “CO2,” “EUI,” “GHG”
5
Identify flexibility measures and alternative compliance pathways
Find out what compliance pathways are available and what works best for you.
Recommended search terms: “alternative,” “plan,” “schedule," "ACP," "Pathway"
Recommended search terms: “alternative,” “plan,” “schedule," "ACP," "Pathway"
6
Take Action
Once you understand the metrics and timelines being used it is time to consider the performance of your building(s) and how you can best improve them.
Take Action
A BPS has many benefits to you and your tenants but at the expense of capital improvements and upgrades. It can be challenging to know where to begin and what you can do to comply with a regulation. Here are some ideas and actions you can take to assess and improve the efficiency of your building
Get an Energy Audit
Energy audits, also referred to as energy assessments, are a process for evaluating the performance of a building and identifying pathways to reduce energy consumption. An Energy Audit is the best place to start because it can leave you with actionable steps. Not all audits are the same. The American Society of Heating, Refrigeration and Air-Conditioning Engineers (ASHRAE) defines 3 levels of energy audits.
Level 2 and 3 audits are best if your building has never been audited before and/or if you are looking to make significant energy efficiency improvements.
Level 2 and 3 audits are best if your building has never been audited before and/or if you are looking to make significant energy efficiency improvements.
Level 1
Site Assessment or Preliminary Audits identify no cost and low-cost energy saving opportunities, and a general view of potential capital improvements. Activities include an assessment of energy bills and a brief site inspection of your building.
Level 2
Energy Survey and Engineering Analysis Audits identify no cost and low-cost opportunities and provide EEM recommendations in line with your financial plans and potential capital-intensive energy savings opportunities. Level 2 audits include an in-depth analysis of energy costs, energy usage and building characteristics and a more refined survey of how energy is used in your building.
Level 3
Detailed Analysis of Capital-Intensive Modification Audits (sometimes referred to as an “investment grade” audit) provide solid recommendations and financial analysis for major capital investments. In addition to Level 1 and Level 2 activities, Level 3 audits include monitoring, data collection and engineering analysis.
Explore Federal, Utility, and State Incentives
Federal Incentives
The Inflation Reduction Act (IRA), along with the Bipartisan Infrastructure Law (BIL), from 2021 (also known as the bipartisan infrastructure law), allocate more than $1 billion for programs and tax incentives to improve the energy efficiency of new and existing commercial buildings.
The IRA expands two tax credits for energy efficiency and building decarbonization: Tax Deduction 179D and Tax Credit 48.
Information on Tax CreditsThe IRA expands two tax credits for energy efficiency and building decarbonization: Tax Deduction 179D and Tax Credit 48.
Utility Incentives
Many utilities offer ratepayer funded inventive programs to upgrade equipment, weatherize and air seal, or improve building operations and maintenance. Efficiency and decarbonization upgrades identified during the energy audit may have corresponding utility rebates.
Use this If you are unaware of the entity who provides ratepayer funded you can use the following link to identify them.
Utility Rebates FinderUse this If you are unaware of the entity who provides ratepayer funded you can use the following link to identify them.
State Incentives
Some states offer incentives of their own on top of federal and utility incentive programs. The following resource can help identify state level opportunities in your area.
Building Energy Efficiency RebatesConsider Strategic Energy Management (SEM)
Strategic Energy Management is a methodology of building operations that gets buy-in from all levels of a company or organization's staff to reduce energy consumption through equipment upgrades as well as behavioral and operational changes. SEM programs are often run in cohorts of similar buildings ie a cohort of hospitals or office buildings, to allow for collaborations and knowledge sharing. Some utilities are even able to offer financial incentives on top of the technical assistance, guidance, and peer collaboration. Strategic Energy Managements is also known as Continuous Energy Improvement.
Jurisdiction Retrofit Resource Hubs
Building Performance Standards are often launched alongside a resource hub to provide 1 on 1 assistance to building owners, public training sessions, and in some cases, financial incentives. Building hubs will likely identify all applicable state and federal incentives and resources that you may take advantage of. Some examples include the Boston Retrofit Resource Center and the Washington D.C. Affordable Retrofit Accelerator. Check the website of your jurisdiction's BPS to see if this is available to you.
Related Resources
Sustainable Energy Action
A Checklist for Building Owners Considering Solar Energy
View Resource
Sustainable Energy Action
EMPOWERED Solutions: Commercial Building Electrification Pathways
View Resource
Pacific Northwest National Laboratory
A Guide to Energy Audits
View Resource
Commercial Building Incentives: Programs for new construction and upgrades in the Inflation Reduction Act and other recent federal laws
View Resource
Glossary
It is easy to get lost in the policy and legal jargon of a BPS. Although each one is different, all BPS likely share some key concepts and terms. General guidance for understanding and interpreting a BPS is provided below.
The BPS rules and regulations are often organized in the following order:
- Definitions: Relevant terms described
- Benchmarking requirements: Who, how, and when to report data
- Building performance standards: Performance targets and timelines
- Alternative Compliance Pathways: flexibility mechanisms to help with compliance
Common Terms
- Covered building: A covered building is any building that is expected to comply with a BPS. A BPS will include thresholds to determine whether or not a building is a covered building. Note: Just because a building is not a covered building when a BPS is enacted does not mean it will not be a covered building in the future. BPS often begin by requiring compliance for a jurisdiction’s largest buildings, because those buildings typically consume the greatest amounts of energy and generate the greatest volumes of GHG emissions. A BPS incrementally incorporate more of a jurisdiction’s buildings into the covered building category as time goes on, through new or adjusted thresholds.
- Threshold: A threshold in a BPS is typically a minimum building size measured in square feet (sf) that determines if a building is covered or not. Building type or use—such as commercial, residential, institutional, governmental, and industrial—might also factor into the thresholds that a jurisdiction establishes. For example, the first cohort of covered buildings in a BPS could be all commercial and institutional buildings that are 20,000 sf or larger. Subsequent thresholds may then be introduced, or the original threshold adjusted, to include buildings that are, for example, multifamily in use, or, as another example, 10,000 sf or larger. The introductions of new or adjusted thresholds may be thought of as a way to implement BPS in logical and predictable phases, targeting the largest consumers and emitters first, then incorporating the next largest consumers and emitters, and so on until most or all buildings are covered.
- Baseline: A baseline refers to the performance of a building during one specific year. That year is called the “baseline year.” Baselines are used to set interim and final emissions reduction targets.
- Benchmarking: benchmarking is a way to track and measure a building’s operations performance in terms of metrics such as electricity consumption in kilowatt-hours and natural gas in therms. In particular, it is a way to compare one building’s performance to the performance of another. Typically, benchmarking is undertaken annually, so changes in building performance can be recorded and evaluated year after year.
Common Metrics For Energy Targets
- Energy use: Energy use is simply the amount of energy used by a building annually. Energy use is often reported in the following units:
- kWh (thousand Watt-hours) – A unit of electricity
- MWh (million Watt-hours) – A unit of electricity
- Therm – A unit of Natural Gas
- kBtu (thousand British thermal unit) – A unit of energy
- MMBtu (million British thermal unit) – A unit of energy
- Energy use intensity (EUI): EUI is the amount of energy used by a building annually divided by the size of the building. EUI is often reported in the following units:
- kBtu/sf (thousand British thermal units per square foot)
- ENERGY STAR Score: An ENERGY STAR score—also called an ENERGY STAR rating—is generated through the ENERGY STAR Portfolio Manager, which is a free online tool from the U.S. Environmental Protection Agency (EPA). An ENERGY STAR score ranks and rates the performance of a building against the performance of all comparable ENERGY STAR-participating buildings. ENERGY STAR scores are expressed as a number from 1 to 100; this number represents the building’s performance percentile.
Common metrics for greenhouse gases (GHGs).
- GHG emissions: GHG emissions are the amount of greenhouse gases generated by a particular activity. In the case of BPS, GHG emissions refer to the operational GHG emissions of a building. Operational GHG emissions are calculated based on a building’s annual energy consumption and the mix of energy sources that fuel a building’s operations. GHG emissions are typically reported in terms of carbon dioxide, for easy comparison:
- CO2e (carbon dioxide equivalent)
- GHG intensity: GHG intensity is the amount of GHG emissions generated by a building’s operations annually divided by the size of the building. GHG intensity is typically reported using the following unit:
- CO2e/sf (carbon dioxide equivalent per square foot
- Fossil fuel phaseout schedule: Not a GHG metric itself, a fossil fuel phaseout schedule may replace GHG emissions reduction targets in a BPS. The phasing out of fossil fuel use in buildings facilitates a reduction in GHG emissions, since burning these fuels for energy generates GHG emissions. Fossil fuel phaseouts may require total phaseout by a single date, or may require phaseout from various uses by various dates.