Designing Utility Programs and Credit Models for BPS Support

Building Performance Standards (BPS) are policies that set energy or emissions performance requirements for existing buildings. As of late 2025, six U.S. jurisdictions have BPS policies in effect with active compliance deadlines, and 11 jurisdictions have passed BPS policies that will go into effect by 2030 (IMT 2025; Nadel and Hinge 2023). Significant energy and emissions reductions are associated with these policies, but challenges with policy implementation include compliance costs and technical challenges for building owners and limitations in the workforce available in jurisdictions.

Under-resourced buildings face greater compliance challenges due to limitations in staff capacity and sources of financial assistance (Jarrah, Garfunkel, and Ribeiro 2024). In this paper, we use the term under-resourced buildings to refer to building owners and occupants who face limited access to financial and technical resources to undertake building retrofits, drawing on the definition by Kelley, Koolbeck, and Duer-Balkind (2025). Under-resourced buildings may be affordable housing, nonprofits, community centers, schools, and others.

Utilities have an important role as key partners to governments enacting BPS by addressing these barriers to BPS implementation and facilitating achievement of the energy and emissions reduction goals of the policies. This paper outlines the landscape of existing and potential utility program offerings that can support jurisdictions and under-resourced buildings with BPS adoption and compliance and expand the impact of utility portfolios. We build upon prior ACEEE research and offer insights from utility interviews to capture the current opportunities for utility involvement in BPS implementation.

Utilities can support BPS policies through new and existing programs

As shown in figure ES1, a number of existing utility programs can provide BPS adoption and implementation support to jurisdictions and building owners. Some utility programs provide anonymized building energy data to the U.S. Environmental Protection Agency’s (EPA) ENERGY STAR Portfolio Manager tool for benchmarking building energy use, which helps building owners comply with benchmarking ordinances that mandate building energy data reporting. Building energy data from utilities can also be useful to jurisdictions in developing targets for BPS policies, especially for jurisdictions without prior benchmarking ordinances in place. Utilities can leverage energy expertise to offer technical assistance and education to jurisdictions in the policy development process. Given limitations in staff capacity in some jurisdictions, utilities can also assist with enforcement through providing tools and data.

Further, to help under-resourced buildings meet BPS targets and upgrade at lower cost, utilities can focus existing measure-based incentives, operations and maintenance programs, and financing toward under-resourced buildings. In addition to existing incentives, utilities can also coordinate with other entities like green banks and local agencies to help braid together financial resources for under-resourced buildings complying with BPS policies. Additionally, utilities can leverage existing workforce development programs and relationships with contractors to expand workforce skills and availability for BPS retrofits.

Figure ES1. Landscape of potential utility BPS support program prototypes

Considerations for program design, savings attribution, and evaluation

In tailoring program offerings to BPS support, utilities may encounter challenges related to delivering programs to a larger number of buildings, given that the number of buildings covered by BPS policies often far exceeds typical utility program enrollment. Utilities will need to consider the suite of BPS offerings that aligns with their regulatory requirements and territory, but we identify a few common considerations for structuring programs in the BPS context.

As many BPS policies are designed with long-term targets and phase in an increasing number of buildings over time, utilities may need to consider how to enable greater flexibility within their program timelines and develop strategies to provide advance information to building owners about their offerings. Most utilities develop energy efficiency plans on a three-year cycle (Relf et al. 2020), while many BPS policies set compliance dates for five to eight years after policy enactment, with increasingly stringent interim targets thereafter (Nadel and Hinge 2023). In addition to education and outreach, utilities can support building owners, particularly owners of under-resourced buildings, with audits and technical assistance in identifying compliance measures prior to upgrades. These contributions to greater building owner compliance with BPS can be classified as market transformation activities of utilities where permitted by regulation (Nadel 2022). Utilities and regulators may need to consider changes to attribution and evaluation models to ensure utilities receive credit for their needed contributions.

Another challenge for attribution of savings from utility BPS support activities is avoiding double counting of savings from overlapping efforts. As utilities already claim savings from measure-based incentive and whole-building programs, utilities and regulators will need to determine methods for crediting utilities for additional efforts that support BPS. Utilities can pursue attribution of savings from efforts like technical assistance for policy design and enforcement, which is unrelated to existing program offerings. Regulators will also provide pivotal guidance in how BPS policy impacts are considered in state or regional energy targets for utilities, and careful consideration will be needed to ensure utilities can receive appropriate credit for their contributions to these policies. As the BPS landscape rapidly evolves, policymakers and utility program administrators should coordinate efforts to ensure maximum energy and emissions reduction and community benefits from these policies.