February 20, 2026
Building Performance Standards Can Reshape the Local Playbook
Whole-building mandates impact strategy beyond lighting fixture swaps and rebates
Lighting has always been local.
It is specified city by city. Rebates shift by utility territory. Energy codes and local requirements can change from one city limit to the next. In some places, lighting guidance arrives as recommended practice. In others, it arrives as a mandate with a deadline.
For years, our industry has been a primary driver of building energy savings. The conversion from HID and fluorescent to LED delivered double-digit reductions that utilities could bank on. But with LED penetration now high across much of the commercial market, lighting is no longer the low-hanging fruit it once was. The incremental gains from LED-to-LED swaps or controls optimization are real, but they are smaller.
And that is precisely why lighting people should care about building performance standards.
Building Performance Standards (BPS) are policies that require existing buildings to meet specific energy or emissions targets by set deadlines, with penalties for noncompliance. Instead of prescribing individual upgrades, they measure how the whole building performs.
In January, the American Council for an Energy-Efficient Economy (ACEEE) released Designing Utility Programs and Credit Models for BPS Support, arguing that utilities are essential to making BPS policies effective and equitable . Buildings accounted for 31 percent of U.S. emissions in 2022, and ACEEE cites research estimating BPS policies could reduce building energy use by 25 to 45 percent in most cities and property types .
But here is the tension. As lighting’s share of remaining savings shrinks, whole-building mandates are rising. BPS policies set energy or emissions targets for existing buildings, with compliance deadlines and penalties. Lighting is no longer the headline measure, but it remains one of the most accessible compliance levers inside a much larger performance equation.
Adoption Support: Setting the Targets
ACEEE divides utility engagement into adoption and compliance support . On the adoption side, utilities can provide anonymized whole-building energy data and technical assistance as jurisdictions draft performance thresholds.
Why does that matter to a lighting contractor or manufacturer? Because the stringency of those targets shapes how much room remains for lighting savings versus HVAC, envelope, or electrification strategies. If utilities influence baseline data and target design, they influence where incentives flow.
The white paper urges regulators to standardize data-sharing frameworks and allow utilities to recover costs for supporting BPS adoption . That is policy plumbing, but it determines how smoothly compliance markets function.
Compliance Support: Where Lighting Still Counts
On the compliance side, ACEEE points to measure-based incentives, custom rebates, operations and maintenance programs, and strategic energy management as key tools . Increasingly, incentives are tied to watts saved or whole-building performance, not simply fixture counts.
Local examples make this concrete.
Denver allows certain covered buildings to comply by certifying full LED installation or equivalent lighting power density, or by offsetting 20 percent of annual energy use with solar. Lighting remains central.
In nearby Boulder, the city’s Building Performance Ordinance requires benchmarking, ASHRAE-based energy assessments, retro-commissioning, and one-time lighting upgrades tied to IECC standards. Participation in Xcel Energy programs can satisfy parts of the assessment or retro-commissioning scope , directly linking utility programs to compliance.
In New York City, Local Law 97 and Local Law 88 impose emissions caps and lighting upgrade requirements, with filings managed through DOB NOW and the BEAM platform . Lighting compliance is documented, tracked, and enforced.
Across markets, the pattern is consistent. BPS creates the obligation. Utility programs create the pathway.
The Evolved Role of Lighting
ACEEE emphasizes that regulators must establish clear savings attribution models so utilities can claim credit for BPS-related support without double counting . Without that clarity, utilities may hesitate to invest in the technical assistance and incentive structures BPS requires.
For lighting people, the takeaway is straightforward. Lighting may no longer deliver the dramatic percentage drops of the LED conversion era. But in a BPS world, controls, right-sizing, commissioning support, and rebate fluency become part of a broader compliance ecosystem.
Lighting is not the whole story, but it continues to be a noteworthy chapter inside a mandated, whole-building narrative.
