Building Performance Standards: Coming Soon

Kyle Kisebach, August 2022

At ASHRAE's annual meeting in Toronto this June, a building risk consultant from Philadelphia stood up and asked a panel of experts, essentially: "when will we have a standard to compare actual building performance to?" Silence ruled for a minute, as no one including the panel members had an answer. I was shocked.

Obligated to break the silence, I walked to the microphone and offered that ASHRAE has created a building performance standard, and that standard has been already adopted in my home state of Washington as governing law. This room full of building owners and their consultants seemed a bit puzzled why that wasn't common knowledge. Not to worry, dear reader - many are finding out now. The rest will find out in coming years. We explain this trend and its impact to you below.


  • California and several cities, such as Los Angles and New York, started requiring energy performance reporting for commercial building owners a few years ago. The stated goal: reduce this sector's energy use and thus its climate impact. The idea was that this reporting would to get them to realize their impact, and let the pressure build to adopt best practices in energy management. Since the commercial building sector uses ~18% of total energy in the U.S., improvement to common practices would have a significant impact on national emissions.

  • Not satisfied with the speed of progress under mandatory energy performance reporting, these entities are looking to building performance standards as the next step.

  • ASHRAE created such a building performance standard as Standard 100 in 2018. This standard is written in enforceable ("must/shall") language with a fairly straightforward rules, which break down into universally mandatory actions, and actions that depend on how well the building performs relative to the standard.

  • Washington state was the first to adopt ASHRAE Standard 100 as law with its own amendments (called the "Clean Building Standard"). Colorado appears to be on the cusp of doing the same. You can see the current situation across the U.S. here.

  • Especially large (>50,000 ft2) buildings are likely to be legally bound to this standard before long. Large buildings typically have the lowest-cost opportunities to save significant energy in my experience, a realization no doubt in the minds of policy makers.

ASHRAE Standard 100 Requirements

  1. A qualified person (see Notes) to baseline and benchmark the buildings' performance vs. a target (see Notes Below for details).

  2. A complete maintenance plan as defined in ASHRAE Standard 180, with real specifics on what tasks need to happen when on what equipment. A way to track tasks completed is also required.

  3. A complete energy management plan as defined in ASHRAE Standard 100.

Every building needs the above and to refresh them every period, roughly every 2-5 years. If a building doesn't perform?

  1. The Owner is required to have a qualified energy auditor determine how energy is used, and what can be done about it. This is a building audit and/or assessment, for which there are also standards such as ASHRAE Standard 211 and ISO 50002.

  2. At least in Washington state, the Owner is required to update the energy management plan and take all of the actions within that audit that fit financial criteria. That miht really mean having to replace old equipment.

For some this will be a few thousand dollars of documentation that their building does meet the target, that they do manage energy according to a plan, and that they do have a system of maintenance that works. For others it may be a rude awakening and significant financial impact. My experience says that the majority of buildings are closer to the latter situation.

Stakeholder Impacts

How is this impacting and how will it impact which stakeholders? Some clear and some speculative impacts to consider:

  1. Building owners will get letters informing them that they have work to do, and not doing it carries a continuous significant penalty. In Washington state, that penalty can be $1/ft2/period - very close to doubling some buildings' energy bills and well worth avoiding.

  2. Building consultants are going to be very busy, and under greater scrutiny. Owners promised a LEED or otherwise high-performance building who find out they don't meet the standard are going to have serious questions for design engineers, architects, and maintenance contractors among others. In any case, retrofit work including retro- or re-commissioning is going to be in demand and we who offer such services will be in greater demand.

  3. Manufacturers' equipment lead times are going to be even longer. We've already seen items like variable-frequency drives go form off-the-shelf to up to 40 weeks' lead time, and this energy push will not help.

  4. Governments will be busy trying to enforce, to validate conformance, to deal with appeals, and so forth. I expect long wait times in the year(s) that a new tranche of buildings falls due for meeting the rules.

  5. Utilities area already scrambling to meet part of the law in Washington - they must make the benchmarking data available since they hold it. Investor-owned utilities in most states already run regulated incentive programs to help Owners manage energy; these are or will be expanding or shifting to better address the law. If the laws have the intended impact, utilities can also expect consumption and demand reductions.

The Last Word

As of summer 2022, it's fair to say that the building and building operations industry isn't broadly aware of building performance standards. or that they will probably have to understand and deal with them in the next 10 years. Energy AIMS is built to help stakeholders take on the core challenges of these standards - baselining, benchmarking, documentation and energy audits. Let us know if it's time to get up to speed on this oncoming challenge.


Baseline: Baseline for most buildings is the energy usage per square area (kBTU/ft2/year) - known as an Energy Usage Index or "EUI." This is determined by converting billed energy units such as kWh or decatherms in the U.S. to the appropriate units, over a couple of years' worth of energy bills. The main thing to do is gather a couple of years worth of bills; we recommend at least 36 months.

Benchmark: Benchmarking is comparing your baseline performance against other buildings. The most common benchmark in the U.S. is the Energy Star Score, which is a 0-100 score reflecting what percentile of performance your building is compared to similar buildings in a similar climate.

Target: ASHRAE Standard 100 committee settled on using CBECS data to set the target performance ("EUIt"). States & Cities are free to use whatever targets they want and to change them over time; for now I expect most will start with the Standard 100 targets.

Qualified Person: Generally an engineer or otherwise 3rd party certified professional such as an AEE-Certified Energy Manager (CEM)