The first compliance cycle deadline for St. Louis’ building energy performance standard is May 4, when owners of buildings 50,000 square feet and larger will be required to show they have reduced energy use to comply with standards.
At the deadline, St. Louis will join New York City and Boston as cities that have begun compliance periods this year. Other municipalities that have passed building performance standards include Seattle, Denver, Washington, D.C. and Cambridge, Mass. Another 30 cities have pledged to pass BPS by 2026, according to a report last year by JLL.
May 4 also marks the deadline for building data that will be analyzed for the second compliance cycle beginning in 2026. That cycle will include qualified affordable housing and houses of worship, which will have until May 2027 to comply with the standard, according to a fact sheet from the city.
On April 20, 2020, the St. Louis Board of Aldermen voted unanimously to adopt the first Building Energy Performance Standard bill, the fourth in the United States. The city set a standard for each property type based on three years of local benchmarking data, from 2017 to 2019, according to a blog post by the Institute for Market Transformation. IMT works with cities and municipalities to develop and implement building performance standards, supporting the National Building Performance Standards Coalition, a collection of state and local governments that in January reaffirmed their commitment to implementing BPS.
The standards are set to impact the highest energy users of each building type so that at least 65% of the buildings of each type will need to improve their performance, IMT says. Building owners have been given flexibility to decide what combination of physical and operational improvements to pursue to achieve the standard.
To ensure reductions in building energy use over time, St. Louis will set new standards in 2026 and repeat the process every four years, according to the city’s BEPS ordinance, with IMT noting the law “strengthens St. Louis’ position as a frontrunner in the race for cleaner, greener cities.”
While this type of “trajectory approach” allows buildings that currently use the most energy to continue using more energy at every interim period, they also “have to improve at the fastest rate, so that all lines converge” at some point, according to Cliff Majersik, senior advisor at IMT, who co-wrote the blog post.
St. Louis’ BEPS includes four main compliance paths: performance, early adopters, narrow the gap and custom alternative. Performance is the most straightforward, with properties able to comply by reducing energy use intensity to meet standards for their property type and submitting verification.
The early adopter pathway aims to incentivize owners to invest in deeper energy retrofits. If at the conclusion of cycle 1 in May, if a property’s energy use intensity is at or below the standard of its property type and the property’s energy use intensity was reduced by 20% or more compared with its 2018 property baseline, then it will be in compliance for both cycles 1 and 2, the city said in a 2022 factsheet.
In addition, if a building meets BEPS guidelines and reduces EIU by 50% or more by May 4, 2025, then it will be in compliance through the third cycle, the city says. Alternatively, properties can comply by reducing energy use, to no higher than the midpoint between its 2018 property baseline standards and the energy use standard for its property type, and submitting required documentation.
“We need to have some clear sort of escape valves for buildings that, for unusual circumstances, can't achieve the same level of performance that other buildings can,” Majersik said. IMT recommends that municipalities “cover these buildings in the policy, but then they give them flexibility in terms of how they achieve the goals.”
The custom alternative path is intended for these properties. Buildings need to file a technical report and get approval from the city’s building division to go down this path.
