What is the Federal Building Performance Standard (BPS)?
A: more than 376.9 million square feet of space in 9,600 buildings in more than 2,200 communities nationwide.
The CEQ was instructed to work with federal partners to develop this BPS as part of a series of initiatives in E.O. 14057.
What are the federal government’s emissions and sustainability goals?
A: E.O. 14057 specifically calls on the government to achieve fully net-zero emissions across the entire federal portfolio by the year 2045. In the interim, federal departments and agencies have a target of reducing their greenhouse gas (GHG) emissions by fifty percent or more by the year 2032. Other goals, such as moving the leased portfolio into net-zero buildings for new leases of 25,000 sq ft or more starting around 2030 and implementing significant levels of building retrofits by 2030, are also hovering over departments and agencies as they look to manage their building portfolios in the future. The BPS establishes a goal of reducing scope 1 emissions to net zero across at least thirty percent of each agency’s building portfolio, by the year 2030. It is an extremely ambitious goal, with funding provided through vehicles such as the infrastructure law, and the Inflation Reduction Act (IRA). Almost every government facility in the federal portfolio falls into the category of being eligible to comply with the BPS.
Does this BPS take the place of the Federal Guiding Principles?
A: Absolutely not. In fact, both E.O. 14057 and the BPS specifically highlight the ongoing use of the Guiding Principles for Sustainable Federal Buildings as a key component in the plan to maximize emissions reductions. Guiding Principles will be used along with the BPS to guide federal building portfolio management, construction, and operations.
What is the practical scope of the BPS?
A: The BPS specifically focuses on reducing scope 1 on-site fossil fuel emissions. And the BPS notes that it does NOT apply to “fugitive” (intentional or unintentional releases of GHG) and fleet emissions. The goals of the BPS are to eliminate the scope 1 emissions from standard building operations such as, “space heating and cooling, water heating, cooking, backup generators used for non-emergency services….and laundry, where all-electric technology alternatives exist. Most emissions from the facility sector are ‘standard operating emissions’ and are subject to GHG emissions reduction targets.”
Aren’t there already a lot of other similar requirements for federal government facilities?
A: Yes. The BPS intends to complement those requirements by specifically targeting the measures that should be undertaken to address scope 1 emissions. Today, federal facilities and portfolios already have requirements related to design, sustainability, deep energy retrofits, performance contracts, operational improvements, fossil fuel reduction requirements, procurement requirements, and other goals. There are a myriad of goals and requirements that federal government staff must juggle when trying to determine how best to build, retrofit, and maintain federal facilities and portfolios. The BPS hopes to inform the prioritization of federal teams and tackle the scope 1 emissions issue.
How are they laying out the requirements for all of these diverse federal facilities?
A: The administration has created two pathways—performance and alternative pathways. Under the performance pathway, facilities must achieve zero scope 1 emissions by 2030 in order to count towards the 30% goal. The alternative pathway is a prescriptive pathway that essentially pushes the facilities to move toward all-electrification of major systems as best they can, and ensure that all non-excluded cooling, cooking, non-emergency generators and laundry equipment are all-electric. Agencies are clearly told that they should only use the prescriptive pathway if a facility is unable to satisfy the performance pathway.
How can an entity the size of the federal government, with the scope of federal government obligations and roles, totally eliminate fossil fuels in scope 1? Are there exclusions?
A: Yes, the program provides federal agencies with a wide berth of exclusions for mission-critical activities, especially, for national defense and security, and process loads that come from manufacturing, industrial, and commercial activities of the federal government, when no practical and plausible alternative exists. The BPS requires the government agencies to track those scope 1 emissions separately. The BPS recognizes that there are not currently technologies available to safely and securely fully replace all scope 1 emissions across all needs of the federal government.
Electrification is great… but what about where the electricity comes from? Does that count?
A: The BPS attempts to address what it can as it relates to source issues. In cases where facilities are receiving energy or water from an agency-owned district system, the agency cannot count the facility as net zero for scope 1 emissions until the agency-owned district system also eliminates its scope 1 emissions. So for agency reporting purposes, those facilities can’t count toward the agency’s thirty percent goal until the district system is also in compliance. If the district system is not agency-owned, that is considered scope 2 emissions and does not fall under the purview of the scope 1 requirements of the BPS.
How will agencies handle life-cycle cost effectiveness?
A: Life-cycle cost effectiveness is required to be determined by agencies on a per-project basis. And they must align activities with the life-cycle cost effectiveness requirements in (42 U.S.C. 8254). That statute does not preclude facilities from, for example, installing all-electric equipment even if doing so is not cost effective. Federal staff will have to balance cost-benefit analysis and other factors when determining whether to move a facility project forward.
Are there reporting requirements?
A: Yes. Federal agencies will provide annual reports on their progress toward achieving the goal of thirty percent of their agency facilities achieving net zero for scope 1 emissions. Regardless, by 2045 the entire federal building portfolio must achieve net-zero emissions.
Are other Departments taking action in support of the BPS?
A: As a complementary and collaborative step, the U.S. Department of Energy (DOE) announced a proposed rulemaking to electrify new Federal buildings and Federal buildings undergoing major renovations.
Additionally, the State of California announced it is joining the President’s National Building Performance Standard Coalition, a nationwide group of over 30 state and local governments that have committed to reducing the emissions footprint of existing buildings. GBI has certified over 26.4 million square feet of commercial and multifamily property in the State of California and is thrilled with their commitment to sustainability through the Building Performance.
Green Globes is recognized and recommended by GSA and GBI supports their commitment to creating a more sustainable, efficient, and resilient future through recent actions. If you have any questions, please contact hamilton@thegbi.org or visit the GBI website at www.thegbi.org.