At its work session on October 28th, City Council will again consider Utility Services staff’s proposed Building Performance Standards (BPS) Policy. The Fort Collins Sustainability Group (FCSG) reiterates its support for a strong BPS Policy, because we see it as an important tool for meeting the community’s greenhouse gas pollution reduction goals. Here we propose two simple additions to the policy as it stands now. These additions will both make the standards easier to achieve and promote building electrification.
Based on conversations with Utility Services staff, we understand that the current version of the proposed BPS policy is based on two compliance pathways. They are the “Flat Energy Use Intensity (EUI) Point Reduction” pathway and the “Percentage EUI Reduction” pathway. The first sets an EUI target for each building based on its “property type” (e.g. office, warehouse, etc.) for 2030. The second sets a percentage reduction target to be achieved by 2030, relative to the building’s actual energy use during a base year chosen by the building owner. Owners may select whichever pathway is easiest for them to achieve.
We propose the addition of two more compliance pathways. They are the “Flat Greenhouse Gas Intensity (GHGI) Point Reduction” pathway and the “Percentage GHGI Reduction” pathway. The first is similar to the Flat EUI Point Reduction pathway in that the building would need to meet a GHGI target by 2030 based on its property type. The second is similar to the Percentage EUI Reduction pathway in that the building would need to reduce its GHGI by a set percentage by 2030 relative to its base year GHGI.
The crucial difference between the EUI and GHGI reduction pathways is that the GHGI reduction pathways would allow building owners to take advantage of the fact that the electric grid is becoming progressively “greener” (i.e. less carbon-intensive) over time. The addition of the two GHGI pathways would make it easier for many building owners to achieve their BPS goals, while not making it more difficult for anyone. Also, the GHGI pathways would encourage switching from gas-consuming to electricity-consuming appliances (e.g. water heaters), since the electric grid is becoming greener while the gas supply is not. The GHGI pathways would therefore promote building electrification.
The City of Fort Collins would not be breaking new ground by allowing building owners to use GHGI pathways to meet their BPS targets for buildings having an area less than 50,000 square feet. The State of Colorado already allows owners of buildings greater than 50,000 square feet to meet their BPS targets via the four compliance pathways described here, including the two GHGI pathways.
The FCSG will have more to say about the proposed BPS policy prior to your work session on October 28th. In the meantime, we urge you to ask Utility Services staff to include GHGI pathways in their proposed BPS policy.
