Decoding BPS: Your Guide to Building Performance Standard Compliance Pathways
Building Performance Standards (BPS) are continuing to emerge in jurisdictions across the United States. Cities, counties, and states are implementing these regulations to tackle climate change head-on and reduce energy consumption by requiring existing buildings – often the largest energy consumers and emitters in a city – to meet specific energy efficiency or greenhouse gas emissions targets over time.
If you own or manage a commercial or large multifamily building in a jurisdiction with a BPS, you might be wondering: "How do I comply?"
The good news is that most BPS policies are designed with flexibility in mind. They recognize that every building is unique, with different systems, uses, and constraints. As such, they typically offer several different pathways to achieve compliance. Understanding these options is the first step towards developing a cost-effective and strategic compliance plan.
Here is a breakdown of common BPS compliance pathways:
1. Hitting the Target: Direct Performance Improvement
What it is: This is the most straightforward path. You improve your building's energy efficiency or reduce its emissions to meet or exceed the specific target set by the BPS (often measured in EUI - Energy Use Intensity, or GHG emissions per square foot) by the compliance deadline.
How it is done: This usually involves energy efficiency upgrades or electrification projects, depending on whether the target is EUI based or GHG based. Think LED lighting retrofits for both the units and common areas, HVAC system upgrades or conversions to heat pumps, and/or optimizing existing systems. Benchmarking your building's current performance using tools like ENERGY STAR Portfolio Manager® is a crucial first step.
2. The Checklist Approach: Prescriptive Pathways
What it is: Some BPS policies offer a predefined list of specific energy efficiency measures or actions. Completing a certain number or combination of these actions satisfies the compliance requirement, even if the absolute performance target is not met through these actions alone in that cycle.
How it is done: You typically need to get approval in advance for this path to compliance. You select and implement measures from the jurisdiction's approved list. This might include things like installing variable frequency drives (VFDs) on motors, upgrading specific insulation levels, or replacing domestic hot water systems with high-efficiency models. Documentation proving completion is key.
3. Investing Off-Site: Renewable Energy Solutions
What it is: This pathway often involves using renewable energy to offset your building's energy consumption or emissions.
How it is done: This can take several forms, depending on local rules:
On-site Generation: Installing solar panels on your roof or property.
Off-site Renewables: Purchasing Renewable Energy Credits (RECs), entering into Power Purchase Agreements (PPAs) for renewable energy generated elsewhere, or subscribing to community solar programs.
Important Note: Jurisdictions have very specific rules about how much, and what types of renewable energy can count towards BPS compliance. Always verify the local requirements.
4. Paying Your Way: Alternative Compliance Payments (ACPs)
What it is: Many BPS policies include an option to pay a fee instead of meeting the performance target or completing prescriptive measures. This fee is often calculated based on how far the building is from its target (e.g., dollars per unit of energy or emissions above the standard).
How it is done: You calculate the required payment based on your building's performance gap and submit the payment to the relevant authority. The funds collected are typically reinvested into local energy efficiency or equity programs.
5. Special Circumstances: Target Adjustments and Variances
What it is: Most BPS programs have provisions to adjust a building's specific target or timeline based on unique circumstances that make meeting the standard target exceptionally difficult or inequitable.
How it is done: Owners must typically submit a detailed application justifying the need for an adjustment. Reasons might include:
Unique operational needs (e.g., data centers, labs with high process loads)
Financial hardship (often with specific criteria)
Conflict with historic preservation requirements
Financial Hardship for Affordable housing property.
Technical infeasibility of required upgrades
Recent major renovations that did not anticipate BPS requirements.
6. Fine-Tuning First: Retro-commissioning (RCx) & Tune-ups
What it is: While sometimes part of the "Direct Performance" path or a "Prescriptive" option, focused system optimization deserves mention. Retro-commissioning (RCx) involves systematically checking and adjusting existing building systems (HVAC, lighting, controls) to ensure they operate as intended and efficiently. Building "tune-ups" are often a less intensive version focused on operational improvements.
How it is done: Trained technicians perform diagnostics and make low-cost operational adjustments and minor repairs.
Choosing Your Path & Getting Started
The best compliance pathway depends on your specific building, its current performance, your budget, long-term capital plans, and the exact rules of your local BPS. It’s complex.
BPS represents a shift towards a more sustainable built environment. By understanding the available compliance pathways, building owners can navigate these regulations strategically, turning a requirement into an opportunity to reduce operating costs, enhance tenant comfort, and increase asset value.
Need help?
GreenT Climate Software is here to assist! We can evaluate your current property performance to see your risk with respect to existing and emerging BPS and provide recommendations to the compliance pathway that works best for your building. Contact us for all your needs and questions. We can support you in deciding your pathway to compliance, model your whole building data, and more!
