Boulder staff outline plan to align large commercial buildings with state performance targets

City of Boulder staff on June 3 presented the Environmental Advisory Board with a multi‑phase plan to reduce greenhouse‑gas emissions from buildings, starting with an ordinance to align commercial buildings 50,000 square feet and larger with state building‑performance targets.

"Our buildings are our single largest source of emissions in the community," Carolyn Elam, senior manager in the Climate Initiatives Department, told the board. Staff said they plan to pursue a target‑based Building Performance Ordinance (BPO) for large buildings and seek "deemed compliance" with Colorado's state program by adopting the state's 2030 targets as the initial benchmark.

The roadmap divides work into near‑term, mid‑term and longer‑term phases. Near‑term actions include consolidating overlapping regulatory pathways for large commercial properties, streamlining compliance for owners who already report under state benchmarking programs, and targeted updates to SmartRegs that govern rental‑licensing inspections. Over the next three years staff will use $1.5 million in grant funds awarded via a Denver‑regional electrification effort to hire consultants for technical analysis, policy design and implementation planning, Laurel Matri, a policy advisor on the energy team, said.

Staff emphasized equity and practical supports for building owners. Consultants will develop a "tune‑up" program of specific, building‑level actions, and Boulder plans to lean on existing programs—Energy Smart for residential advising, Partners for a Clean Environment for commercial advising, and Boulder County PACE—to help owners access incentives and financing. Matri also said the city will establish an "equity priority" concierge service to provide hands‑on support for nonprofit or low‑income housing properties that lack capacity to navigate compliance.

Board members raised tenant‑protection concerns and potential unintended consequences if energy or emissions targets constrain heating or cooling access in rental housing. "If we set an aggressive energy‑use‑intensity target for an apartment building, it is probable the building owner would constrain what tenants can do in terms of cooling access," Carolyn Elam said, noting staff are weighing emissions‑based targets against energy‑intensity targets and the equity implications of each.

Staff described SmartRegs as a licensing pathway used by nearly all landlords (a 100‑point checklist or HERS path) and said proposed short‑term updates would initially focus on new rental licenses rather than retroactive changes to all existing licenses. Ryman and Matri clarified SmartRegs does not apply to owner‑occupied short‑term rentals; the team's near‑term SmartRegs work emphasizes new rental licenses and whether bonus points and appliance scoring should shift to better align with decarbonization goals.

On timing, staff said engagement—surveys, owner meetings and public open houses—will run through late summer, with a first ordinance revision for 50,000+ buildings targeted for presentation to City Council late this year or early next year. Staff also pointed to the city's public emissions inventory and a web dashboard as tools for tracking progress.

Next steps: staff will pursue consultant analysis funded by the grant, carry out owner and public engagement, and return to the board with more detailed proposed ordinance language, compliance pathways and implementation timelines.