FCSG Statement on Proposed Building Performance Standards Policy

The Fort Collins Sustainability Group (FCSG) has reviewed the Agenda Item Summary for the City’s proposed Building Performance Standards (BPS) policy.  We believe that a BPS program, which sets enforceable “Energy Use Intensity” (EUI) targets for different existing building types, is an important tool for reducing climate pollution, and we are fully in support of implementing such a program here in Fort Collins.  We also believe that a Large Methane User Fee would work well in conjunction with BPS to achieve our community climate pollution reduction goals.

We are pleased to see that City staff is proposing that interim EUI targets be established for 2027 “so that the [final] 2030 goals are achievable.”  We encourage Council to make the interim EUI targets enforceable through fines as is proposed for the final targets to help ensure that the interim targets are taken seriously by building owners.

We note that even enforceable 2027 targets will not help the City meet its 2026 climate pollution reduction goal of 50% compared to 2005 levels.  We suggest that either the interim target year be moved up to 2026, or that Fort Collins Utilities make incentive payments available to encourage early achievement of both the interim and final targets for building energy use.

Additionally, we note that the proposed BPS policy:

  • Is not specifically focused on building electrification. This point is muddied by the incorrect assertion that EUI stands for “Electric Use Intensity” (instead of “Energy Use Intensity”) on page 44 of the work session agenda packet.  Promoting electrification as a substitute for methane (also known as “natural gas”) is an important climate pollution reduction strategy, which is separate from reducing overall building energy use.
  • Excludes hospitals, K-12 schools, and manufacturing/industrial plants. We understand and support excluding manufacturing/industrial plants, since the energy intensity of industrial processes varies widely, making the establishment of uniform EUI targets impossible for those facilities.  It is not clear to us why staff is proposing that hospitals and K-12 schools be excluded from the BPS policy, however.  Buildings in each of these two categories do consume energy in similar ways, making it possible to compare their energy performance to baseline values and set reasonable EUI reduction targets.

Finally, we note that hospitals, K-12 schools, and industrial facilities are likely to be both large energy users in general and large methane users in particular.  Their owners should be asked to step up – along with the owners of all other buildings larger than 5,000 square feet – to do their part in helping Fort Collins reach its climate pollution reduction goals.  Staff estimates that compliance with the BPS policy will cost $4.50 to $5.00 per square foot, or approximately $200,000 for a 40,000 square foot building.  It is not equitable to allow hospitals, K-12 schools, and industrial facilities to avoid paying these costs while other building owners must do so.

One way of ensuring that all building owners contribute to achieving the City’s climate pollution reduction goals is to establish a Large Methane User Fee (LMUF), as described on our website here.  Establishing a LMUF later this year would have the additional benefits of:

  • Encouraging early compliance with the interim and final EUI targets
  • Encouraging the substitution of electric energy for methane.

Like the BPS program, the LMUF would benefit building owners by encouraging them to reduce methane use and the associated costs.  It would also provide a pool of funding to help them switch from methane to electricity, a switch most would be less likely to make in a timely manner absent the LMUF.  Together, a Building Performance Standards program and a Large Methane User Fee would be a powerful suite of tools to help Fort Collins achieve its 2026 and 2030 climate pollution reduction goals.

 

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Author: Kevin Cross

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