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Building Matters

U.S. Government Has Unveiled First-Ever Federal Building Performance Standard

But is it enough, and how might it impact the housing sector?

Late last year the Biden-Harris Administration unveiled the country’s first-ever proposed emissions standard for federal buildings. In a nutshell, the government’s targets are twofold: cut energy use and electrify equipment and appliances in 30% of federally owned building space by 2030; and achieve net-zero emissions in all federal buildings by 2045.

Federal Building Performance Standard (BPS) is a huge deal, if for no other reason because there is no precedent for one, at least not in the U.S. Such standards and benchmarks have always been left to state houses, local municipalities, or, on particularly good days, the good will of private developers. But not until recently has the U.S. government stepped in and committed to decarbonization on a mass scale. Rather than attempt to get into why that is so (not a mental stretch), let’s get into the potential impacts of the BPS, the kinds of emissions reductions being addressed, how it potentially ties to housing and private development, and perhaps where it falls short.

First the good. Reducing emissions in federally owned building stock even by 30% in the next seven years will help remove tens of millions of metric tons of CO2 equivalent from entering the atmosphere. This is inarguably a good thing. And once building emissions are cut to zero by 2045, that should account for an approximate 25% reduction in the government’s total greenhouse gas emissions output. Again, this is a big deal.

As for total GHG emissions (76% of which comprise CO2), the government is focusing on scope 1 emissions only, which is perhaps where the BPS falls short. According to the White House, the BPS aims to “eliminate scope 1 emissions attributed to standard building operations, including space heating and cooling, water heating,” and other appliances where all-electric alternatives exist. (Scope 1 refers to direct GHG emissions that stem from building operations and are controlled by the building owner.)

This also means that scopes 2 (purchase of electricity) and 3 (waste disposal, travel, purchased goods, et al.) aren’t factored in, nor is embodied carbon stemming from materials and construction (11% of all global energy-related carbon emissions), nor is fugitive emissions (accidental leakage of GHG from faulty infrastructure and equipment that transports fossil fuels).

The standard also concedes that in some instances, owing to climate zones, systems configurations, and other contributing factors, “full decarbonization may not be practicable today,” but emissions reductions should be pursued regardless, whether through dual-fuel and gas-electric options that can supplement carbon-free heating and cooling units, which may otherwise prove incompatible to meet building loads during extended periods of heat or cold.

These are big omissions and exemptions, any one of which places a noticeable asterisk on any claim of “net-zero emissions.” But if measurable reductions in carbon output and energy consumption are the ultimate yardstick, especially for the country’s single largest landowner and manager of buildings, then we mustn’t let perfection be the enemy of good.

According to the White House’s Council on Environmental Quality (CEQ), which oversees the standard, government agencies are encouraged to extend the principles of the Federal BPS to other projects in their portfolio, but only federally owned facilities will count towards the standard. This means that housing overseen by HUD (which doesn’t own rental properties) and other residential facilities under some degree of federal oversight are not covered. But when it comes to the residential market and its dire need to rapidly decarbonize, there may be some hope lying in the subtext.

Among the many (!) tangential agency programs that can potentially follow (or lead) the Federal BPS as it begins to take hold, here are two that stand out:

The Biden-Harris Administration’s National Building Performance Standards Coalition is composed of, to date, 40 governors, mayors, and county executives across 18 states who have signed on to implement emissions reductions through local building upgrades and retrofits. How this coalition, which launched in January 2022, will translate into actionable policies that affect more than government buildings is yet to be seen.

Then there is the Department of Energy’s Better Climate Challenge, launched in February 2022. This program enables municipalities and private companies to partner with the DOE to reduce their portfolio-wide scope 1 and 2 emissions by at least 50% within the next 10 years. Adopters of the challenge are a who’s who of major cities, state and private universities, and Fortune 1,000 companies. And where they go, residential and commercial development tends to follow.

Of course, any viable pathway to achieving zero emissions requires the use of clean(er) energy, and last we checked, transitioning the grid from gas and coal to renewables is no simple feat. But if the federal government has the capacity to show serious leadership when it comes to carbon reduction in the building sector on a mass scale, even though it’s limited to scope 1 operational emissions, then the private marketplace has no other option but to take notice.


Justin R. Wolf is a Minnesota-based writer who covers green building trends and energy policy. Image credit: Kevin McCoy



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