Policy Principles to Get Buildings to Net Zero Carbon
WRITTEN BY YVE TORRIE, DIRECTOR OF CLIMATE, ENERGY, & RESILIENCE
Reducing carbon emissions from large buildings is key to the City of Boston and Commonwealth of Massachusetts meeting their respective carbon neutrality goals by 2050. With commercial, industrial, and large residential buildings accounting for 51.6 percent of greenhouse gas emissions in the City of Boston in 2017i, and commercial buildings accounting for 10.1 percent in the Commonwealth in the same yearii, both the City and Commonwealth are working on pathways to get to net zero carbon in existing buildings and on net zero carbon standards for new construction.
The business community has a strong voice in conversations around development and as there is room for advocacy in the development of these pathways and standards, A Better City, on behalf of the Boston Green Ribbon Commission’s Commercial Real Estate Working Group, convened a group of progressive real estate representatives interested in the development of building policy principles to advocate for in Boston and the Commonwealth. Over the course of the last year, this group met four times to discuss opportunities for engagement, learn from peer cities like New York City and Washington D.C. that have pursued similar goals, and develop a set of principles for which they can collectively advocate.
The City and Commonwealth are in the process of developing the following net zero carbon strategies relevant to the buildings sector:
CITY OF BOSTON
Based on the City’s 2019 Climate Action Plan update, in 2020 the City of Boston committed to two zero net carbon building1 pathways – one for existing buildings and one for new buildings - below:
- BUILDING EMISSION PERFORMANCE STANDARD aimed at putting existing buildings on a trajectory to zero net carbon by 2050. The City is particularly interested in how to integrate these changes into their current Building Energy Reporting and Disclosure Ordinance (BERDO) program.
- NET ZERO CARBON ZONING ORDINANCE for new buildings that will assess net zero carbon zoning feasibility, develop standard recommendations and a timeline for implementation, and explore expanding and strengthening its green building requirements.
COMMONWEALTH OF MASSACHUSETTS
- GLOBAL WARMING SOLUTIONS ACT (GWSA) IMPLEMENTATION ADVISORY COMMITTEE (IAC): Prior to Governor Baker’s announcement on January 21, 2020, that committed Massachusetts to net zero carbon emissions by 2050, the IAC was studying sector pathways to reach the GWSA’s goal of 80% emissions reduction by 2050. Since that announcement, the study group has now included a net zero pathway in its modelling for each sector. Still in the technical modelling phase within the buildings sector, next steps will include policy pathways.
- NET ZERO STRETCH ENERGY CODE: At the Board of Building Regulations and Standards’ (BBRS) June 2019 meeting, the Board agreed to review a Net Zero Stretch Energy Code after significant advocacy including the Mayors of Boston, Cambridge, and Somerville. Net Zero Stretch Energy Code proposals have been put forth by the American Institute of Architects, and most recently, numerous advocates have submitted the MA E-Z code offering an alternative prescriptive pathway for new buildings (instead of the performance path).
- In January 2020, the Massachusetts Senate introduced Bill 2477 (now SB2500): An Act Setting Next Generation Climate Policy, which includes language that authorizes DOER to, “develop and adopt, as an appendix to the state building code, in consultation with the BBRS, a municipal opt-in specialized stretch energy code that includes, but is not limited to, a definition of net-zero building” by 2024.2 An amendment was later adopted by the Senate, to accelerate the implementation date for the net zero stretch code to one year after passage of the bill, potentially as soon as July 2021. The bill is now under House consideration.
- STATE HAZARD MITIGATION AND CLIMATE ADAPTATION PLAN: The latest plan includes an initiative to “review the state building code to assess feasibility of incorporating hazard mitigation and resilience” in the next 2-4 years.
BUILDINGS POLICY PRINCIPLES
As these various policies, pathways, and strategies are developed over the next one to two years, the group of progressive real estate representatives that A Better City has convened over the last year, have developed a set of buildings policy principles to advocate for. The nine policy principles below were defined and agreed to by the group:
- NET ZERO DEFINITION: To achieve the emissions reductions necessary from the building sector, the Commonwealth and the City of Boston should proceed with establishing “net zero” emission standards and codes that are guided by what science demands and are consistent across jurisdictions. Development of this definition could be informed by approaches such as zero over time and science-based targets.
- ROLE OF CARBON TARGETS
- SQUARE FOOTAGE THRESHOLDS: More buildings should be subject to carbon targets. For existing buildings, the threshold for inclusion in future BERDO updates should be set reduced from 35,000 to 25,000 square feet. For new construction, the threshold should be set at 10,000 square feet.
- USE TYPES: Performance standards should be set by use type to account for unique characteristics across the building stock.
- TIMING: Zero-Over-Time should be an option for building emissions standards compliance. To avoid abuse, interim targets determined in a ZOT plan should be enforced.
- REPORTING: Building owners should be allowed to achieve their emissions reductions targets at a building or portfolio level. They should report through portfolio manager in a manner that reflects the approach they’ve pursued, while providing the City with an accurate representation of building level impacts.
- ROLE OF EFFICIENCY, RENEWABLES, OFF-SETS, AND GRID-CLEANLINESS: Building emissions policies should be designed to allow a flexible mix of energy efficiency, renewable energy, and electrification, with the goal of enabling every building owner to pursue the solution that most effectively reduces emissions in their building or portfolio. This should include:
- Promoting implementation of energy efficiency measures before or alongside other carbon reduction solutions;
- Requiring on-site renewable feasibility assessments with an opt-out for buildings upon which on-site is not feasible or cost-effective given current incentives;
- Defining additionality and providing building owners guidance for off-site renewable procurement;
- Defining allowable RECs to ensure their quality and/or that RECs play a diminished role in achieving emissions reduction targets over time; and
- Factoring in grid-mix to ensure first-movers on electrification are not penalized for increasing emissions due to local grid mix.
- INTEGRATING LANDLORDS AND TENANTS INTO BUILDING EMISSIONS: Base building systems and tenant spaces both contribute to building emission profiles. To encourage cooperative action and ensure the correct parties are held accountable for complying with emission limits, building emission policies should be crafted in a manner that shares responsibility across landlords and tenants. Implementation of this advocacy principle could include development of resources that facilitate action by landlords and tenants to mitigate their respective scope of emissions over the course of a lease.
- FINANCIAL CONSIDERATIONS FOR MAKING NET ZERO FEASIBLE: Existing incentive programs targeted at energy efficiency should be updated or expanded to encompass the goal of carbon reductions, rather than simply energy reductions. The City and Commonwealth should seek out ways to ensure that landlords are not disincentivized from taking early, aggressive action. Implementation of this principle could include:
- Considering financial impacts of carbon reduction measures and creating corresponding incentive programs, including energy efficiency, deep energy retrofits and electrification;
- Offering accelerated depreciation of assets;
- Omitting the cost of carbon reduction upgrades from the threshold that triggers other code compliance changes;
- Creating dedicated permitting review and approval processes for projects that reduce carbon emissions;
- Updating PACE to focus on emissions broadly, not energy individually;
- For non-compliance, collecting fines in a designated fund to subsidize improvements, rather than allocating to the general fund; and
- Updating Boston’s Community Choice Aggregation program to allow for aggregation at the building or portfolio level.
- WAYS TO ALIGN MITIGATION AND RESILIENCY: The City and Commonwealth should align their mitigation and resiliency policies to ensure that building owners are taking actions that both reduce carbon emissions and increase safety. Implementation of this principle could include:
- Incentivizing buildings to increase envelope performance and utilize backup power derived from clean and renewable sources.
- When upgrading gas infrastructure to protect against leaks, considering whether adjustments should be made that could enable the use of alternative fuels in the future.
- SHARING DATA AND INFORMATION: The City and Commonwealth should create avenues through which real estate members can share and receive informational net-zero materials, such as case studies, local resources, examples from other jurisdictions, and other updates.
- DEFINING SUCCESS AND COORDINATION ACROSS PROCESSES: It is essential that state and local municipalities coordinate to ensure building policies are aligned across jurisdictions. The real estate community should work with the City and Commonwealth to convene an overarching, representative body to engage on all processes related to zero carbon building standards. This body should engage a broad coalition of real estate stakeholders, establish clear processes for their engagement throughout, and involve the necessary expertise to inform technical issues throughout the process.
- ROLE OF REAL ESTATE COMMUNITY: The real estate community, comprised of for-profit owners and developers, and not-for-profit educational, healthcare and cultural institutions, is a partner in defining building emissions standards and a net zero code.
The following advocacy opportunities may commence in the next two-three months with:
- THE CITY OF BOSTON’S EXECUTIVE OFFICE OF ENERGY, ENVIRONMENT, AND OPEN SPACE AND PLANNING AND DEVELOPMENT AGENCY: Group members are seeking to engage directly with the two offices responsible for the active net zero processes in Boston.
- COMMONWEALTH OF MASSACHUSETTS’ EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENT AND DEPARTMENT OF ENERGY RESOURCES: Group members are also seeking to engage directly with the representatives leading the net zero processes at the Commonwealth level.
If you are interested in engaging in these meetings or this work, please feel free to reach out to Yve Torrie: firstname.lastname@example.org.
- City of Boston Climate Action Plan. (2019). p. 35. “The City defines a net carbon building as “a low-energy fossil fuel-free building that meets its annual energy needs from a mix of on- and off-site renewable energy assets” https://www.boston.gov/sites/default/files/embed/file/2019-10/city_of_boston_2019_climate_action_plan_update_4.pdf.
- An Act Setting Next-Generation Climate Policy, S.2477, 191st General Court of the Commonwealth of Massachusetts. (2020). https://malegislature.gov/Bills/191/S2477.
ii. Data from 2017 Massachusetts GHG Emissions Inventory, MA DEP