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Opportunities and Risks for BEPS

Contractual recommendations for designers to reduce liability

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Washington, DC has been a leader in green building policy for 15 years. This resource series explores how the District’s Building Energy Performance Standards (BEPS), which regulate energy use in existing buildings, will affect building design and construction for architects and related practitioners.

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The District’s sustainability policies bring opportunities for investment in high-performance buildings and deep green retrofits. While the District’s energy code continues to move rapidly towards requiring net-zero energy in 2026, approximately 71% of the District’s current greenhouse gas emissions come from buildings—and they are almost entirely from existing buildings. This is why BEPS could be a very powerful environmental and economic tool. The District estimates that thousands of buildings may ultimately be affected by BEPS.

These building requirements will ultimately help the District achieve its goal to become carbon neutral by 2050. Building owners will be looking towards practitioners—architects, engineers, and sustainability consultants—to help them navigate these regulatory requirements and make improvements to their building’s performance.

Risk Management

However, along with opportunity comes risk. Architects and the larger design community want to set expectations, establish clear guardrails to keep projects on track for successful compliance with DC’s codes and policies, and manage optimal project outcomes. This process starts with the following steps:

Risk Management Steps

Each of the following modules provides guidance on best business practices as BEPS take effect, how to ensure provisions for building performance are integral to the entire design and construction process, and ways to manage risk while expanding potential opportunities to support larger sustainability goals.

Conclusion: Planning a Future-Proof Performance Target

Can you predict the BEPS in future cycles? Not really.

The DC BEPS are currently based on the local median ENERGY STAR Score for each property type, where available, which is in turn based on national building data collected through the Commercial Building Energy Consumption Survey (CBECS). Because the ENERGY STAR Score is based on a comparison to a national data set that is updated every four years, this score is heavily dependent on the relative performance of other buildings in the database, which is beyond the control of the designer or the owner. Furthermore, the local median ENERGY STAR Score is dependent upon the performance of peer properties in DC, where new buildings are delivered every year under some of the nation’s most advanced energy codes and green building policies. Therefore, it is impossible to predict the exact trajectory of BEPS, but assuming the compliance threshold will increase in rigor each successive compliance cycle and therefore targeting a higher ENERGY STAR Score would certainly be safer than cutting it too close to the current BEPS cycle’s minimum performance requirements.

It bears repeating that the only way to be predictably safe for several BEPS cycles would be to deliver a net zero or net positive building—one that generates as much or more clean energy than it uses over the course of a year. But aspirational performance goals may not fit within an owner’s program, schedule or budget, so it is important to mutually identify the right target somewhere between meeting code and safely meeting BEPS for one or more cycles. Determining how many cycles ahead the project should plan for and therefore estimating what the ballpark ENERGY STAR Score or source EUI should be are a critical part of managing a successful project that is positioned to comply with the BEPS in the future. In addition, selecting the right team and planning for iterative energy benchmarks at key points along the way will keep the project on track and well equipped for future success.

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