Raising the Floor: Why Building Performance Standards Aren't a Design Failure
An industry piece published this month made a claim I've been chewing on. The argument: for years, building performance standards were treated as a design-community conversation, architects, energy modelers, policy advocates, working from the assumption that if the design community got it right, compliance would take care of itself. Now that BPS enforcement is arriving with real deadlines and real penalties, that assumption is being tested, and building owners are the ones absorbing the consequences.
I don't think that's the right read. And I think the actual story here is more interesting than "the design community left a gap."
Every project meets the standard it was designed under
Buildings don't underperform because architects were unwilling to push further. In over a decade working across sustainability programs at the American Institute of Architects, I never met an architect who didn't want to push a project's performance further. What I saw instead were two much more common, much less discussed reasons a project lands at "meets code" instead of "exceeds it":
Improved performance beyond the required level wasn't a priority for the client at the time decisions were being made.
Budget constraints or other outside pressures forced high-performing features out of the design before construction, the reality of value engineering.
Neither of those is a design failure. Both are decisions made above the design team, often well before a building ever reaches occupancy.
Facilities teams have a real, legitimate constraint
The article does raise a point worth taking seriously: facilities managers working within a building that's already in a compliance window have limited levers. You can't retrofit a building's fundamental envelope or system architecture overnight, and operational tweaks can only move performance so far. That's a real constraint, not an excuse.
But the conclusion that follows shouldn't be that compliance now falls on facilities teams to solve alone, any more than it should have fallen on architects alone before them.
Ceiling programs vs. floor programs
Here's the distinction I think gets lost in conversations like this.
Programs like the 2030 Commitment, LEED, and the Living Building Challenge raise the ceiling. They prove what's achievable on the projects that opt in, and they've meaningfully pushed the industry's sense of what's possible. That's real, valuable work.
But new construction and major renovation, the work these programs primarily touch, make up only about 2% of the U.S. building stock in any given year, according to the National Trust for Historic Preservation. The other 98% already exists. Voluntary, project-by-project programs were never structurally built to reach it.
Building Performance Standards do something different. They raise the floor. Every building over a jurisdiction's square footage threshold is covered, regardless of whether the owner ever opted into a voluntary framework. Seattle's BEPS, for example, is projected to cut existing building emissions 27% by 2050, the equivalent of taking roughly 72,000 cars off the road every year. That's not a claim about any single building performing better than another. It's a claim about how many buildings get touched, and the other 98% is where the scale of impact lives.
This is a team problem, not a solo one
None of this is something architects solve alone, or owners solve alone, or facilities teams solve alone. It's a team problem that spans design through operations. Architects and engineers partnering with owners and facilities managers, from the earliest planning conversations through the life of the building, is what actually closes the gap between what a handful of buildings have proven possible and what becomes probable for every building on the list.
That's the kind of progress this industry has been trying to reach for a long time. BPS enforcement isn't a verdict on who fell short. It's the mechanism that finally makes it everyone's work.
Sources
Melissa Morancy is a strategic climate and building decarbonization consultant and founder of Lighthouse Advisory Solutions.