What’s Required, What’s Not, and How to Stay Compliant
New building performance requirements in Colorado have raised a lot of questions for commercial property owners. This article explains what the state’s Building Performance Standards mean for your building, what steps are actually required, and how to stay compliant without unnecessary upgrades. At Chiller, we focus on understanding how your building operates today and making smart improvements that support performance, comfort, and long-term value.
If you own or manage a large building in Colorado, you’ve likely heard plenty about the state’s Building Performance Standards (BPS), and probably just as much conflicting information.
Between emissions targets, reporting requirements, and ongoing legal challenges, it’s understandable that many building owners are asking the same question:
What do I actually need to do, and what can I safely ignore for now?
You’re not alone. Here’s the straight answer: BPS is real, the deadlines matter, and compliance does not require panic-driven upgrades or unnecessary electrification. What it does require is a clear understanding of the rules and a practical plan.
Let’s walk through what actually matters.
What Colorado’s BPS Requires
Colorado’s statewide Building Performance Standards apply to commercial, multifamily, and public buildings 50,000 square feet and larger.
At a high level, building owners of covered buildings are ultimately responsible for compliance, including:
- Benchmark and report energy use annually using ENERGY STAR Portfolio Manager
- Meet performance-based emissions reduction targets over time
- Select a compliance pathway that aligns with how their building operates
These aren’t just regulations. Compliance reduces the risk of financial penalties, capital disruptions, and future operational challenges.
The state’s long-term goal is a 20% reduction in greenhouse gas emissions by 2030, using 2021 as the baseline. Interim targets begin earlier, but the key point is this:
BPS is performance-based. It does not prescribe a single technology, system, or fuel source.
Once you understand what’s required, it’s just as important to understand what isn’t.
If you haven’t benchmarked yet or aren’t confident your data is clean, this is the place to start.
What’s Not Required (and Causes the Most Confusion)
Most confusion around BPS comes from assumptions that simply aren’t true. Let’s clear up a few common misconceptions.
You are not required to electrify everything
BPS does not mandate blanket electrification. The rule focuses on measured outcomes, not forcing specific equipment decisions. In many cases, buildings can comply through efficiency improvements alone.
You are not required to replace functioning equipment immediately
If your systems are operating well and can be optimized to meet targets, wholesale replacement is often unnecessary, especially before equipment reaches end-of-life.
You are not expected to “figure it out later”
While there have been legal challenges related to building performance policies, owners should not assume the program will disappear. Planning does not mean overcommitting. The safest approach is to plan based on current requirements while building flexibility into your strategy.
The biggest risk isn’t doing too much. It’s doing the wrong thing based on bad assumptions.
Understanding the Targets: EUI and Emissions
Colorado evaluates building performance using two primary metrics:
Energy Use Intensity (EUI)
EUI measures how much energy a building uses per square foot. Each property type has specific EUI targets for interim and long-term compliance periods. Keep in mind, building owners don’t need to be experts in order to comply.
Lower EUI generally means:
- Lower operating costs
- Easier compliance
- Fewer disruptive upgrades
Greenhouse Gas (GHG) Intensity
This measures emissions per square foot, accounting for fuel type and energy source.
Some buildings choose a GHG-based pathway, others focus on EUI reduction. The key is selecting the path that makes the most sense for your building, not defaulting into one unintentionally.
Choosing the right metric early can significantly reduce compliance costs later.
Compliance Pathways: How Owners Avoid Overcorrection
Your compliance pathway isn’t permanent. It can, and often does, evolve over time. Colorado intentionally allows for multiple compliance approaches. In practical terms, that means:
- Meeting your building-type EUI target, or
- Achieving a defined percentage reduction from your baseline, or
- Using a GHG-based pathway when appropriate
This flexibility exists for a reason: not all buildings perform the same. Owners who understand these options early often avoid unnecessary system replacements later.
Where HVAC Fits In (and Why It Matters So Much)
For most large buildings, meeting BPS targets comes down to one system more than any other. HVAC is the single biggest lever for BPS compliance.
But that does not automatically mean new equipment. HVAC is often misunderstood as an “all or nothing” investment. However, there are many problems that can be fixed instead of replaced.
The highest-impact HVAC improvements typically come from:
- Controls optimization and scheduling
- Retro-commissioning
- Correcting simultaneous heating and cooling
- Fixing airflow and pressure imbalances
- Optimizing chiller and boiler sequencing
- Sensor calibration and setpoint correction
These changes address how systems actually operate day to day. They often deliver meaningful EUI and emissions reductions at a fraction of the cost of full replacement. These improvements count as measurable and verifiable for compliance reporting.
At Chiller, the focus is simple: solve the underlying problem before buying new equipment.
When Equipment Changes Do Make Sense
Equipment replacement and upgrades are inevitable. The key is to plan around lifecycle timing rather than urgency.
Equipment upgrades become necessary when:
- Systems are at or near end-of-life
- Repair costs no longer make economic sense
- The building cannot meet performance targets through optimization alone
In those cases, decisions should still be application-driven, not policy-driven. The right solution depends on how the building is used, what it supports, and what the infrastructure can realistically handle.
A Practical, Cost-Conscious Path Forward
For building owners navigating BPS, the smartest sequence looks like this:
- Confirm whether your building is covered
- Benchmark accurately and consistently
- Understand your specific performance target
- Choose a compliance pathway intentionally
- Address low-cost, high-impact HVAC improvements first
- Plan equipment upgrades strategically, not reactively
- Document everything
This approach reduces risk, controls costs, and keeps future options open, even as regulations evolve. Consider compliance documentation as protection, not paperwork.
Frequently Asked Questions: Colorado Building Performance Standards (BPS)
1. Do Colorado’s Building Performance Standards require me to electrify my building?
No. Colorado’s BPS is a performance-based regulation, not a technology mandate. The state cares about measured energy use and emissions outcomes, not whether your building uses gas, electric, or a combination of systems.
In many cases, building owners can make meaningful progress toward compliance through efficiency improvements, controls optimization, and system tuning without full electrification or major equipment replacement.
2. What buildings are required to comply with Colorado’s BPS?
BPS applies to commercial, multifamily, and public buildings that are 50,000 square feet or larger. Covered buildings must benchmark and report energy use annually using ENERGY STAR Portfolio Manager and meet performance targets over time.
If your building is close to the threshold or has mixed uses, it’s important to confirm coverage early so reporting and planning don’t become last-minute issues.
3. What is EUI, and why does it matter for BPS compliance?
EUI (Energy Use Intensity) measures how much energy a building uses per square foot. Colorado assigns EUI targets by building type, and many compliance pathways are tied directly to improving that number.
From a practical standpoint, EUI is often the most controllable metric for building owners, especially through HVAC scheduling, controls, airflow correction, and system optimization. Lower EUI typically means lower operating costs and easier compliance.
4. Do I need to replace my HVAC equipment to meet BPS requirements?
Not necessarily. In fact, equipment replacement is often not the first, or best, step.
For many buildings, the biggest performance gains come from:
- Controls optimization
- Retro-commissioning
- Correcting simultaneous heating and cooling
- Improving system sequencing and setpoints
Equipment replacement usually makes sense only when systems are at end-of-life or cannot meet performance targets through optimization alone. A measured, building-specific approach almost always delivers better results than rushing into capital upgrades.
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The Bottom Line
Colorado’s Building Performance Standards don’t call for rushed decisions or blanket upgrades. They’re about understanding how your building actually operates and making smart, measured improvements over time.
The buildings that do best under BPS aren’t the ones replacing everything at once. They’re the ones that take the time to understand their systems, improve performance where it counts, and invest in solutions that make sense for their building.
That’s how you stay compliant, without overdoing it.
If you’d like help understanding how your HVAC systems factor into BPS compliance or want to identify the most cost-effective way forward, Chiller is here to help.