Originally published in Climate Urgency, Climate Action. Third in the BPS series.
In this edition, I’m going to talk about the energy targets that are set for building performance standards! I’m now almost six months into my BPS journey and am greatly enjoying my learning process. I’m now through my first target development process and have a much better sense of how the data all works together, how the laws get applied, and into the public participation process.
Energy Use Intensity Target Setting
The public comment period for Oregon’s Building Performance Standards (BPS) is open. I wanted to share some information about what it has been like working with our team as we worked on this. One of the components of the rulemaking is the targets. BPS set specific goals for how much energy or emissions a building can use. These goals depend on the type and size of the building. Those goals are referred to as the energy use intensity targets (EUIt).
Throughout the summer and early fall, we have been busy at work developing the targets for Oregon’s BPS. The first step was calibrating the methodological approach that we used in Washington to the Oregon context, and then getting into the work of developing Oregon’s targets.
The Process
House Bill 3409 laid the groundwork for Oregon’s BPS, setting specific criteria for the development of EUI targets. The bill requires that targets be:
- Weather normalized
- Equal to or greater than average EUIs
- Inclusive of two or more climate zones
- Adjusted for unique energy-using features
- Consideration of regional and local energy use
- Exclusive of EV supply equipment
- Designed to maximize greenhouse gas reductions
These requirements guided our approach and ensured that the final targets would be both achievable and impactful. Our team had already done this in Washington so we had a lot of experience and resources that we were able to draw from, but the policy context, the stakeholders, and the realities of the buildings in Oregon do not match the realities that we faced in Washington. We worked with the Oregon stakeholders throughout the entire process.
Data Realities
One of the most significant challenges in developing EUI targets is working with available data. The law required that the targets be reflective of the average energy use intensity for each of the building types that needed a target.
Publicly available building energy use data is messy, incomplete, hard to work with, and there’s no single dataset that is representative of the entire building stock. We had to dig up good data, combine multiple sources, and make decision after decision to make sure that we eventually were able to calculate a true and representative average energy use. We employed a rigorous process that combined data from multiple high-quality sources:
- National data from the Commercial Buildings Energy Consumption Survey (CBECS)
- Regional data from the Commercial Building Stock Assessment (CBSA)
- Local data from Oregon state-owned buildings, schools, and city benchmarking programs
Custom Adjustments and Trends
One of the most significant custom adjustments we made was for schools and educational buildings. We had access to high-quality data from 966 Oregon schools. This data revealed that Oregon schools generally use less energy than the averages we could calculate from public datasets.
Another notable custom adjustment was made for restaurants. Our analysis of local datasets showed that restaurants in Oregon are already more energy-efficient than their regional or national counterparts.
Future Proofing
We applied a universal trends adjustment to all building types. We all know that COVID was a whammy for commercial buildings, and we wanted to make sure that we accounted for the natural reduction in energy consumption in buildings that occurs due to codes, standards, and technical and cultural advances. Our analysis of data since 2012 revealed a consistent downward trend in energy use intensity. We applied a forward-facing adjustment of -1.7% per year between 2019 and 2027 to all building types.
The Targets
In the end, after months of analysis, adjustment, and consideration, we developed EUI targets for 40 different building types across Oregon’s two climate zones (4C and 5B). The targets represent a balance between ambitious energy reduction goals and realistic, achievable standards for building owners and operators.
If you’re hungry for details, feel free to dig deeper by reading our EUI Targets Methodology memo and exploring the Oregon BPS Rulemaking website.