National Building Performance Standards (BPS): One HVAC Partner for a Multi-City Portfolio

An emissions cap in New York and Boston, an ENERGY STAR or EUI target in Washington DC and St. Louis, a statewide standard in Washington and Maryland. Managing each property against its own rulebook, with no shared HVAC strategy, is where portfolios fall behind.

Compliance dates differ by jurisdiction and often by building size within a jurisdiction. Without a consolidated calendar, a deadline in one city can arrive with no runway to design, fund, and install the HVAC work needed to meet it.

Most building-performance standards assess a penalty tied to the amount a building exceeds its emissions cap or energy target — typically per ton of CO2-equivalent over the limit, or per unit of energy over an EUI target, every year you remain non-compliant. Across a portfolio, small overages at many buildings add up.

Dropping a new fossil-fuel boiler into a building right before its city's limits tighten can lock in a carbon load for 20-plus years. Routine, building-by-building capital decisions made without a portfolio strategy quietly raise long-term liability.

Nearly every one of these laws tightens on a schedule — interim targets stepping toward net-zero around 2050. A building that just clears today's threshold can fall out of compliance at the next interval, so a one-time fix per building is rarely durable.

The federal HFC phase-down and the move to lower-GWP A2L refrigerants are changing what equipment can be installed and serviced. Buying the wrong refrigerant platform now can strand equipment or complicate future service.

A different mechanical contractor in each market means different equipment standards, different documentation, and no single view of portfolio risk — making it hard to report, budget, or prove progress to lenders and stakeholders.

• •Electrifies heating to cut on-site combustion across the portfolio
• •Delivers heating and cooling from one system
• •High efficiency, including cold-climate and water-source designs
• •Scales from individual zones to whole-building plants

• •Standardized high-efficiency replacements across sites
• •Right-sized to actual loads to stop waste and short-cycling
• •Lower energy use and reduced reported emissions
• •A bridge step that keeps later electrification options open

• •BAS/BMS scheduling, setbacks, and demand-controlled ventilation
• •Continuous monitoring to catch efficiency drift across sites
• •Lower-GWP (A2L) refrigerant transition planning
• •Fast, lower-cost reductions to begin each building's plan

Compliance is our differentiator

HVAC-driven building-performance compliance is the core of what we do. We started in the most demanding regulatory market in the country — New York City's Local Law 97, 87, 88, and 84 — and apply that same discipline to standards in every other jurisdiction.

One partner, every market

Rather than coordinating a different mechanical contractor in each city, your portfolio runs through a single team with one set of equipment standards, one roadmap, and one point of accountability.

Standardized engineering, local rules

We apply consistent heat-pump, controls, and refrigerant strategies portfolio-wide, then tailor each building's scope to the specific metric and deadline its jurisdiction enforces.

Built for owners and asset managers

Clear portfolio-level reporting, a consolidated deadline calendar, and phased budgeting give owners, asset managers, and facilities leaders one view of mechanical compliance risk across the footprint.

Portfolio Compliance Assessment

The starting point for a multi-city owner: understand where every building stands against the standard that governs it.

Portfolio Upgrade Program

Coordinated execution of the HVAC scope that brings buildings into compliance, standardized across markets.

Ongoing Portfolio Compliance

Keep the whole portfolio performing and ahead of tightening limits over time.

Own a Commercial Property?

Business+ plans start at $499/year — includes 2 rtu tune-ups, 10% off all services, and priority scheduling.

What is a building performance standard (BPS)?

A building performance standard is a law requiring existing buildings to meet an ongoing performance target — either a cap on greenhouse-gas emissions or a ceiling on energy use intensity (energy per square foot) — and to measure, report, and improve toward it over time. NYC's Local Law 97 and Boston's BERDO are emissions-cap versions; Washington DC's BEPS and St. Louis's standard are energy-performance versions. More than 30 state and local governments committed to adopt these standards through the National Building Performance Standards Coalition, and many are now in force. As of 2026 the details continue to change, so confirm current requirements with each jurisdiction.

We have buildings in several cities — why use one HVAC partner instead of a contractor in each market?

Because the engineering that drives compliance is the same everywhere — efficiency, electrification, controls, and refrigerant — even when the law and the metric differ city to city. One partner gives you a single strategy, consistent equipment and documentation standards, a consolidated deadline calendar, and one accountable point of contact, instead of stitching together different vendors, different specs, and a fragmented view of risk.

Which building-performance laws does this cover?

The major U.S. standards as of 2026 include New York City Local Law 97, Boston's BERDO, Washington DC's BEPS, Denver's Energize Denver, Seattle's Building Emissions Performance Standard, Washington State's Clean Buildings Performance Standard, Maryland's statewide BEPS, Montgomery County (MD) BEPS, St. Louis's BEPS, California's AB 802 benchmarking under Title 24, and others, plus the federal EPA refrigerant rules. Thresholds and deadlines vary, and new jurisdictions continue to adopt standards, so we confirm exactly which law governs each of your buildings during the assessment.

How is HVAC the common thread across all these different laws?

Whether a law measures carbon emissions or energy use, a building's number is driven largely by how it heats, cools, ventilates, and produces hot water, and by the fuels those systems burn. Improving equipment efficiency, electrifying fossil-fuel heating with heat pumps, tightening controls, and managing refrigerant choice lowers that number under every standard. That's why an HVAC-focused partner can drive compliance across an entire multi-jurisdiction portfolio.

What happens if a building misses its target?

Most building-performance standards assess a financial penalty tied to how far a building exceeds its emissions cap or energy target — commonly per ton of CO2-equivalent over the limit, or per unit of energy over an EUI target — for each year it stays out of compliance. Some also penalize failure to file the required benchmarking or emissions report. Across a portfolio, modest overages at many buildings compound.

How do federal refrigerant rules factor into compliance planning?

Separate from the city and state performance standards, the federal HFC phase-down under the AIM Act and EPA's Technology Transitions program are shifting new equipment toward lower-GWP A2L refrigerants. When we plan portfolio upgrades, we align equipment choices with those federal rules so a new installation that helps a building's energy or emissions number doesn't create a refrigerant liability later.

Do we have to upgrade every building at once?

No. We build a single phased roadmap that sequences work against each jurisdiction's deadlines and your budget cycles. Typically the highest-risk buildings and the fastest, lowest-cost measures — controls and efficiency tuning — come first, with larger electrification and equipment-replacement projects staged over multiple years across the portfolio.

Does Com+ file our emissions or energy reports?

Com+ provides the HVAC engineering, installation, and supporting equipment and efficiency documentation. The emissions and energy filings themselves are certified and submitted by the qualified professionals each jurisdiction requires — in NYC, for example, a Registered Design Professional. We coordinate directly with your reporting professionals across markets, or can help you engage them.