Use GHG Intensity for Benchmarking Buildings

Background

Existing buildings produce the most greenhouse gases (GHGs) in the building sector and more than what will be produced by new buildings in the forcible future. The largest existing buildings in Seattle emit almost as much GHG emissions as all of the rest of Seattle's buildings combined: 2.8% of the buildings are responsible for 45% of the emissions with 75% of the GHGs coming from gas water and space heating. The large buildings should therefore be a priority.

The city has benchmarking requirements that are targeted to specifically to these large buildings, to monitor their energy use and a Tune-Up program to reduce it over time through decreasing the operating energy use. Benchmarking typically uses EUI (Energy Use Intensity, or energy use per square foot) as a standard of measurement. We believe that they should use GHG intensity as well in order to directly target and measure the climate impacts of the building .

The State, through the 2019 Cleaning Building Act (CBA), requires large commercial buildings (larger than 50,000 square feet) to benchmark and then meet a EUI performance standard by 2026-27. This is done by building type. The stated goal of the CBA is to reduce GHG emissions from building. The performance standards were set in 2020 by the State Department of Commerce and we fought to get the EUI as low as possible. Unfortunately, they are still too high due to the use of old and incomplete data and political pressure from the real-estate industry and some influential building owners and organizations. We will continue to push to have these lowered when possible by law. The city will not benefit as much from the CBA since the city’s buildings are far better than in many places in the state. Lowering the performance will therefore put more pressure on the city’s large buildings to upgrade. We also will work to have the performance include GHG/sft as well as EUI/sft so that we can work on reducing GHG specifically. To this end we are trying to get the incentives for early adopters of the CBA performance standards partially be awarded based on GHG reduction. This may also result in Seattle being able to take advantage of the incentives despite their more efficient buildings. Seattle has so many of the State’s largest buildings we really need to make progress in our large buildings, despite their already better efficiency.

In addition, we need to have the actual, accurate and complete benchmarking data, EUI and GHG/sf, sooner than required by the CBA so the city and state can fully plan for reducing the GHG’s in these buildings and to provide more accurate targets. Seattle has been doing a good job of tracking and reporting on EUI but needs to also track GHG/sf. The state, through the Department of Commerce, needs to start tracking this and making the information available to public as Seattle has been doing.

The proposed bill in 2021, Healthy Homes and Clean Building, includes a provision to require buildings 20-50,000 square feet to also benchmark in the next year and then possibly set performance standards. It is important to include more of the large buildings so we will be supporting this and push for the standards for the smaller buildings.

The City’s Office of Sustainability and Environment (OSE) is working on performance requirements for large buildings and has been looking at using GHG/sft. There has been some delay due to Covid but also it has taken time for the state to come up with performance standards. The state standard is now complete and incentive program will be set in by mid-2021. We need to encourage OSE to continue to pursue this and be sure they have the funding and support they need to get it done.