The Fort Collins Sustainability Group (FCSG) is very pleased by the fact that after the work session on October 28^th, the City’s proposed Building Performance Standards (BPS) policy will move forward for possible adoption later this year.  We offer the following comments on the work session presentation and discussion:

1. Insufficient emphasis was placed on the financial benefits of implementing building energy upgrades, while too much attention was focused solely on implementation costs. Two of the pilot projects presented had simple paybacks of one year or less, which corresponds to a return on investment (ROI) of 100% or more.  This is a huge financial benefit to the building owners.
2. There was little to no discussion of financial mechanisms for implementing building energy upgrades, which include Colorado’s “Commercial Property Assessed Clean Energy” (C-PACE) program and energy performance contracting. These mechanisms allow building owners to pay for energy upgrades with little to no money upfront on terms that can be very financially attractive.
3. Given the financial benefits of many energy projects and the financial mechanisms available for avoiding significant capital outlays, we oppose exempting any building categories from the BPS program, or extending the compliance deadline to 2032 across the board. Why should the City support postponing projects with ROIs over, say, 10%, that will keep our air clean and will keep greenhouse gas pollution out of the atmosphere?
4. Instead, we suggest that building owners be exempted from complying with BPS requirements by 2030 if doing so would result in a project with an ROI less than a reasonable value. The City could require building owners to implement only those measures that are financially attractive before 2030, and allow them to postpone full compliance until 2032 or 2035.
5. Finally, we reiterate that including the two greenhouse gas intensity (GHGI) reduction pathways in the BPS policy that we have described in detail previously would make it more financially attractive for many building owners to comply. There is no conflict between building electrification and reducing greenhouse gas pollution.  While we support staff’s desire to reduce building energy use, we note that ALL electrification strategies, and in particular cost-effective electrification strategies, will result in reduced building energy use in addition to reduced GHG pollution.

We encourage council to ask that staff take the above points into account as they develop options for the BPS policy for council’s consideration later this year.  Let’s not weaken BPS by postponing implementation beyond 2030 or exempting certain building categories.

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Update: Sadly, City staff offered a further weakened BPS ordinance to council on December 2nd.  Council failed to approve the weakened version on a tie vote, 3 – 3.  Read the details in this Coloradoan article.