Background on Building Performance Standards
State and federal-level efforts to reduce carbon emissions from existing buildings include:
• The recent adoption of amendments by the Bay Area Air Quality Management District (BAAQMD) to eliminate emissions of nitrogen oxides (NOx) from residential and commercial natural gas furnaces and water heaters by requiring new appliances to be zero-NOx (Attachment E). This will begin with water heaters in 2027.
• CA Assembly Bill 802 (Building Energy Benchmarking Program), which requires owners of large commercial and multifamily buildings (>50,000 square feet) to report energy use to the California Energy Commission annually. • CA Senate Bill 48 (Energy Savings Act), which expands upon AB 802 to require state agencies (led by the California Energy Commission) to collaborate on the development of a strategy for using energy data to track and manage the energy usage and emissions of greenhouse gases of covered buildings to achieve state climate goals. The bill would authorize state agencies to jointly establish energy and water usage Building Performance Standards.
• The Inflation Reduction Act of 2022 invested over $50 billion into clean energy technologies and improvements to lower energy bills, make buildings healthier and safer, reduce climate pollution, and prioritize associated benefits for lowincome communities. (Many of these incentives have since been rolled back by the Trump Administration, further emphasizing the need for state and local governments to step in.)
The CAAP’s Zero Net Carbon Buildings section lists action ZNC5: Adopt a Carbon Reduction Ordinance for Existing Buildings. Although the action does not specifically mention BPS, the recommendation states “Adopt a Carbon Reduction Ordinance to require energy benchmarking and carbon performance of existing buildings over 20,000 sq. ft. including multifamily buildings. Require a reduction of fossil fuel use of covered buildings by 15% in five years and elimination of fossil fuel use by 2050.” Jurisdictions across the U.S. have adopted or are beginning to adopt BPS to meet climate goals by decarbonizing existing buildings. Launched by President Biden, the National Building Performance Standards Coalition included over 50 state and local governments that had already adopted or committed to adopting BPS policies in their jurisdictions (Figure 4). In April 2023, Santa Monica was the first Southern California city to join the National BPS Coalition (Attachment K). The City is also a member of a state cohort of cities exploring BPS policies led by U.S. Green Building Council-California.
Figure 4. National BPS Policy Development
Source: Institute for Market Transformation, 2025