A shift in federal government priorities has created uncertainty over federal funding for energy efficiency and sustainability initiatives, but state and local governments are continuing to develop building performance policies.
While large cities have led the way on implementing building performance standards and benchmarking policies in the past few years, smaller cities — those with populations under 100,000 — could continue to push these policies forward in 2025, according to James Burton, manager of policy engagement and tracking at the Institute for Market Transformation. This is in spite of staffing and funding challenges that could more substantially impact them, Burton said.
Even with limited resources, municipalities across the country are working to implement environmental policies, ranging from building performance standards to energy benchmarking to energy codes, Burton said in a blog post. These policies provide a way for them to meet goals to reduce energy use, lower utility bills and advance climate action, he said.
IMT works with cities and municipalities to develop and implement building performance standards that align with the goals of the National Building Performance Standards Coalition, a group of state and local governments that in January reaffirmed their commitment to implementing BPS.
Evanston, Illinois, is an example of a smaller municipality pushing ahead on climate action. It became the first government to pass a building performance standard in 2025 with its Healthy Buildings Ordinance. The HBO, which will cover commercial and multifamily buildings over 20,000 square feet, condominiums over 50,000 square feet and municipal buildings over 10,000 square feet, requires these buildings to achieve zero on-site emissions and 100% renewable electricity procurement by 2050, Burton said.
The HBO follows many of IMT’s best practice recommendations, such as setting multiple metrics to encourage efficiency alongside emissions reductions and setting up a community accountability board to ensure equity in the rulemaking and implementation process, said Jessica Miller, senior director of policy strategy and engagement at IMT, in a March 11 blog post.
The ordinance’s mandate that buildings procure 100% of electricity from renewable sources is the first of its kind among similar BPS policies, and it “makes Evanston’s BPS rulemaking process one to watch,” Miller said.
“So far, performance metrics for building performance standards are mainly focused on greenhouse gas intensity or energy use intensity. As different governments are developing these, they might have different things that they are focused on as priorities,” Burton said in an interview. IMT is aware of some governments that are also considering metrics like the amount of fossil fuel used to generate electricity and the cost of electricity, he said.
“There might be more things like that developing. There might be things around water use being developed. But that remains to be seen,” Burton said.
Existing BPS structures drive momentum in smaller communities
Following the start of the first compliance period for Boston’s Building Emissions Reduction and Disclosure Ordinance, or BERDO, two nearby, smaller municipalities are implementing policies with similar structures, according to Burton. This includes Newton, Massachusetts, which adopted a BPS law in December that will cover commercial and city-owned buildings over 20,000 square feet, and Watertown, Massachusetts, which IMT anticipates will pass its own BERDO in the first quarter of 2025, Burton said in his blog post.
“We are not first on BERDO, but ... we have learned a lot from the few communities in Massachusetts that have done it ahead of us,” said Watertown City Manager George Proakis, Watertown News reported in January. “We have been able to select from their best practices and strategy to put together this ordinance.”
Clayton, Missouri, also adopted a building benchmarking law in February. Its Building Energy Awareness law will require city-owned buildings over 10,000 square feet to comply by April and commercial and multifamily buildings over 100,000 square feet to report their energy use in 2027. The city expects this will cover four city-owned properties and up to 60 commercial and multifamily buildings, Burton said.
Municipalities in California are expected to adopt BPS and other building performance policies in the coming months as well. In the second quarter of 2025, West Hollywood is expected to pass its Equitable Building Performance Standards, and Santa Monica is working to enact its own Building Performance Standard, IMT says.
