Leveraging Codes and Standards for Climate Action


By Stephen Gunther

December 3, 2020

Building codes and standards are the principal regulatory mechanisms available to state and local governments to decrease energy use in residential and commercial buildings and continue to reduce U.S. carbon emissions. Jurisdictions looking to effectively tackle this sector should consider the following recommendations.

Benchmarking, Data Access and Performance Targets

Following the adage, “You can’t manage what you don’t measure,” building energy benchmarking is a key first step to reducing energy use in the built environment. Understanding current building performance helps policymakers identify savings opportunities and plan for a more efficient building stock. Through benchmarking, policymakers can ensure building codes are realizing the anticipated savings. They also can quantify what is needed to pursue net zero energy and net zero carbon goals for the existing building stock.

Once benchmarks are set, requirements can be gradually applied through square footage thresholds based on building type. Energy benchmarking policies can be expanded by implementing disclosure requirements, adding metrics such as GHG emissions and water consumption, and learning from successful policies in other jurisdictions, such as the District of Columbia, Boston, and Washington state.  

To accurately track and report on building energy performance, building owners will need access to whole-building energy data without requiring individual tenant permissions, provided certain data aggregation thresholds are met to protect privacy. For example, California adopted whole-building energy data access policies for all commercial, multifamily, and mixed-use property owners that meet certain aggregation thresholds.

Jurisdictions with benchmarking policies see trends in increased energy savings. To further drive the building stock toward increased energy efficiency, many jurisdictions are also implementing mandatory energy audits, performance targets, data verification by third parties, lighting upgrades, retrocommissioning, and/or submetering. In 2019, the Washington State Legislature passed House Bill (HB) 1257, which represents the first ever statewide adoption of an energy performance standard for existing buildings.

Stretch Codes and Integration with Other Climate Strategies

Beyond benchmarking ordinances, states and cities can use their authority over building codes to help meet climate goals. California’s Building Energy Efficiency Standards (“Energy Code” or “Title 24, Part 6”) and Green Building Standards (“CALGreen” or “Title 24, Part 11”) exceed current national standards, such as those established by the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) and the International Energy Conservation Code (IECC). In addition, both standards include mechanisms for local jurisdictions to go above and beyond statewide requirements. CALGreen includes mandatory requirements, along with voluntary tiers that local jurisdictions can make mandatory. Local jurisdictions may propose amendments to the state Energy Code that require buildings to be designed to consume no more energy than permitted by Title 24, Part 6. These options allow for the development and testing of more aggressive standards to drive efficiency.

Energy Efficiency and Demand Response

Demand response-ready technologies will enable buildings to interact with the modernized grid and respond to real-time signals about the carbon-intensity of the electricity mix to reduce a building’s carbon emissions. Deploying grid‐interactive technology ensures that investments made today will send the right market signal to industry stakeholders, while socializing the concept of grid‐interactive technology with customers. This approach is consistent with CSE’s experience implementing statewide electrification initiatives, such as the Energy Commission’s California Electric Vehicle Infrastructure Project (CALeVIP), which requires EV charging equipment be networkable and use an open standard communications protocol. Jurisdictions can also consider demand management capabilities in their codes and standards. For example, in 2018 the California state legislature passed Senate Bill 49, which directs the California Energy Commission to adopt standards for appliances to facilitate the deployment of flexible demand technologies.

It is important that code updates provide a clear path to long-term goals. For example, Canada’s Energy Step Code commits British Columbia to taking incremental steps to make buildings net zero energy-ready by 2032 and provides voluntary standards to help local jurisdictions advance toward that goal.

Building and energy code development should also be integrated with other local climate strategies. For example, CSE worked with the City of Carlsbad, California, to adopt ordinances that addressed mandatory solar requirements, alternative energy water heating, energy efficiency, and electric vehicle (EV) charging infrastructure standards. In addition, jurisdictions should expand the scope of codes and standards to include demand flexibility and connectivity needed to enable grid-interactive buildings. Achieving a carbon‐free grid will require significant amounts of flexible load to integrate intermittent renewable energy and provide ancillary services. Such efforts should also support the advancement of standardized, user-friendly communications protocols designed with integration in mind to help meet net zero emissions goals.

Ensuring Compliance

Energy savings and GHG reductions from building codes and equipment standards are only as good as their compliance rates. States and cities must seek ways to ensure codes are understood and followed and that efficient equipment is installed properly to achieve expected performance and savings.


  • Provide technical training and resources

  • Leverage web-based technologies for code compliance documentation

  • Provide online permitting and virtual and digital verification for certain installations in existing buildings

  • Develop incentives and/or penalties

An essential component to strengthening local building and energy codes is providing technical assistance and support to local governments and relevant stakeholders, as requirements are often both complex and frequently updated. The U.S. Department of Energy provides technical assistance to help state and local code enforcement adopt, upgrade, implement and enforce their residential and commercial building energy codes. Some states, including Massachusetts and California, have encouraged local “reach” or “stretch” codes through such support. CSE also recognizes the effectiveness of hands-on training for local examiners and inspectors. CSE’s Energy Code Coach program provided supported increased collaboration among local building department staff and applicants, which helped increase compliance.

In addition to providing training and resources, state and local governments should make it easier to understand and comply with energy codes and standards. Web-based technologies, such as dynamic PDF forms with online interface for code compliance documentation, is a positive step toward achieving this goal. This new format was developed by Energy Code Ace (ECA) under the California Statewide Codes and Standards Program for the 2019 Non-Residential Certificate of Compliance documentation. Dynamic features include hyperlinks to code language for simplified cross-referencing, links to guidance, automatic calculations, and the functionality to automatically customize according to a project’s size and the user’s job function.

Similarly, states and cities should establish streamlined compliance processes for equipment installations that leverage web‐based technologies. Online permitting and virtual and digital verification for certain over-the-counter measures in existing building projects (e.g., HVAC systems, domestic water heaters) can significantly improve compliance, resulting in improved performance.

Lastly, a general lack of enforcement and/or consequences for non-compliance is a significant issue and is exacerbated by the resource constraints of local building departments and prioritization of other non-energy-related codes and standards. It is essential that building and energy code development and appliance standards are accompanied by incentive structures or enforceability mechanisms, which are appropriately funded, to help ensure compliance and achievement of intended savings goals.

Stephen Gunther

Distributed Energy Resources Policy Manager

Stephen engages at the regulatory and legislative level to inform policy on energy efficiency, demand response, building decarbonization, building codes and standards, and other demand-side programs. He serves as the subject matter expert on policy areas related to DER and supports the programs…

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