This is the third article in our series covering the continuously developing and expanding Building Performance Standard compliance environment. We will be looking at the center of the United States including jurisdictions within Colorado, Illinois, Missouri, Texas and Wisconsin.
All jurisdictions require energy and often water benchmarking. In addition to benchmarking, there are up to 10 different compliance mechanisms that jurisdictions have chosen to require. While some are similar, no two jurisdictions are identical. We’ll be exploring each below.
Colorado Statewide – Building Performance Colorado (BPC)
All multifamily, commercial, and public buildings over 50,000 square feet in the state of Colorado are covered under the BPC. Colorado’s first reduction compliance date is already here in 2026. While it is voluntary, it is still a good idea to get started as the next cycle closes in 2030. By 2030, buildings must reduce energy usage by 20% from a baseline of their choice: either 2019 or 2021 consumption.
Colorado has also aligned the statewide reduction targets with the local level requirements so all buildings must now only meet an energy use per square foot per year (EUI) target. Previously, a selection had to be made between a carbon reduction target or an energy reduction target. While certain technologies and techniques my reduce both, there is potential for not reducing carbon emissions while reducing energy consumption and vice versa.
Denver, CO – Energize Denver
Denver has multiple related building performance standards based on the square footage of the building. These programs begin with thresholds as low as 5,000 square feet. While there are complexities to each program, buildings over 25,000 square feet have energy use intensity (EUI) target reductions for each building type. These EUI targets equate to roughly a 30% decrease from the average energy consumption for each building type.
Due to the short compliance timeline, Denver allows for the opportunity to opt in to an updated compliance timeline. To opt in, a selection must be made when the building’s benchmarking report is submitted to the city in the 2025 cycle. If chosen, the new compliance dates are 2028 for the first interim target, and 2032 to meet the final EUI target. Penalties for noncompliance are based on the amount of kbtus per square foot over the building’s target. After 180 days of nonpayment, the penalties are converted into perpetual liens on the property.
Boulder, CO – Boulder Building Performance Ordinance No. 8071
While Boulder does not have a specific reduction requirement, it does have multiple recurring requirements and investment mandates.
Commercial and multifamily buildings with over 20,000 square feet must:
- Perform a retrocommissioning study every 10 years starting in 2025
- Implement measures identified in the retrocommissioning report by 2025
- Perform and ASHRAE level I, II, or III audit every 10 years beginning in 2025
- Upgrade all lighting to LED and potentially install lighting controls
Evanston, IL – Healthy Buildings Ordinance (HBO)
Evanston has passed the Healthy Buildings Ordinance. However, it has not yet given specific guidance for compliance requirements beyond alignment with the city’s Climate Action and Resiliency Plan (CARP) and that buildings over 20,000 square feet are covered.
While there have not been final rules produced, we have included the levels of reductions necessary to outline what may be required to align with the city’s CARP. By 2035, buildings would need to reduce emissions by 35% by 2035 and achieve net zero carbon emissions by 2050.
St. Louis, MO – Building Energy Performance Standard (BEPS)
St. Louis utilizes building type specific EUI targets for all commercial, municipal, institutional, and residential properties over 50,000 square feet. These targets are set at the local 35th percentile of site EUIs per category.
The first compliance cycle was completed on May 4th 2025. The next compliance date is in 2029. While this may not feel immediate, it is a backwards looking target, based on 2028 usage. After factoring in planning, purchasing, equipment lead times and installation, the compliance date is right around the corner.
Austin, TX – Energy Conservation and Disclosure Act (ECAD):
The city of Austin requires all multifamily and residential buildings over 10 years old to conduct an energy audit and benchmark utilities. This information must then be disclosed to the new owner or tenant at sale or lease. Multifamily buildings with energy usage that exceeds 150% of the average must also implement improvements and achieve at least a 20% reduction in energy consumption.
Madison, WI – Building Energy Savings Program (BESP):
Buildings 50,000 square feet and larger in Madison must comply with BESP. To comply, buildings must complete a building tune up, or follow an alternative compliance pathway. Buildings over 100,000 must comply by 2026, buildings with square footage between 50,000-99,999 must comply by 2027. To comply through the alternative compliance pathway, a building must complete an ASHRAE level II or III audit. Additionally, there is an implementation requirement for all measures with a two year simple payback or less.
How Firefly Building Performance Can Help You Navigate Changing Standards
Building performance standards are complex, continuously expanding and evolving. It’s important to take your own steps to ensure that you are meeting performance standards, running your business efficiently, and planning ahead for potential future tax changes.
If you are a building owner or property manager needing to comply with one or more of these standards, reach out for a complementary risk assessment. At Firefly Building Performance, we understand that each building and jurisdiction requirement is unique. Each will require a customized approach to achieve compliance and we stand ready to assist throughout the process from data collection to project finance and implementation.
