Large Building Ordinance Requirements: Massachusetts's Growing Momentum Toward Carbon Neutrality

in March 3rd, 2025

By Emmett Burns, Associate Manager of Analytics

In recent years, in regions with carbon reduction goals, incentive policies and falling renewable technology costs have resulted in reduced electricity sector carbon emissions. Transportation emissions have also declined because of electrification and improved fuel efficiency. Now, many local and state governments across the country have set their sights on building emissions as the next meaningful target to continue to reduce emissions in our cities.

According to the International Energy Agency, on a global scale, building operations account for 30% of energy consumption and 26% of energy emissions (8% of which is accounted for by direct emissions and 18% by indirect emissions). In more densely populated cities, however, that metric shifts drastically. For example, 70% of Boston’s emissions and almost two-thirds of New York City’s emissions are derived from buildings. With buildings being the primary driver of city-wide emissions, it’s no surprise that more than 600 municipalities have generated climate action plans which frequently target building emissions. Some key recent developments in this area are the Massachusetts Large Building Energy Reporting (LBER) law and the Net Zero Carbon (NZC) zoning amendment to Boston’s zoning code, both of which target tracking and mitigating building emissions in the state of Massachusetts.

The LBER law was introduced as a part of An Act Driving Clean Energy and Offshore Wind and requires buildings greater the 20,000 square feet across the state of Massachusetts to report their energy usage. This legislation, administered by the Massachusetts Department of Energy Resources (DOER), takes a similar form to Boston’s Building Emissions Reduction and Disclosure Ordinance (BERDO) and Cambridge’s Building Energy Use Disclosure Ordinance (BEUDO) (discussed in detail by CES’s Sandy Beauregard, Director of Sustainability, in her CES Insights blog titled “Municipal Ordinance: The Next Wave of Compliance?”) – with a couple key differences.

The first major difference is that utilities will be required to report electricity, natural gas and steam on behalf of the buildings they serve, which deviates from the municipal ordinances which require building owners to report their own energy consumption. Building owners will still be required to report oil, propane, solar generation and other forms of energy not delivered and tracked by a utility company. Another key difference is that unlike the municipal ordinances, LBER only requires reporting and does not introduce emissions restrictions. Despite the absence of emissions restrictions, DOER intends to publish the data and provide an annual report which will help inform decisions among business owners and governing bodies as they look to understand the carbon footprint of the state’s buildings and general trajectory toward state and local emissions goals. Similarly to the municipal ordinances, however, LBER does introduce penalties for utilities and building owners that do not report their energy use in a timely manner.

The reporting deadline is set as June 30 for all reporting parties in 2025, which is set to shift to May 30 in 2026 and beyond for utilities but remain on June 30 for building owners. On January 29, DOER published a Draft Covered Buildings List which is searchable by address or owner. A final list is set to be published by the end of March.

Complimentary to BERDO, BEUDO and LBER is the new Net Zero Carbon (NZC) Zoning amendment in Boston. This amendment, approved by the Boston Zoning Commission in January, will aid the city’s 2050 carbon neutrality goal by requiring most new buildings to emit net zero emissions from day one. NZC Zoning will be required for new projects that file for permits after July 1, 2025. The amendment applies to buildings that consist of 15 residential units or exceed 20,000 square feet. Building additions of 50,000 square feet or more would also be required to comply. Additionally, all projects will have to report on embodied carbon emitted based on construction and materials, and large buildings will be required to conduct a full embodied carbon life cycle assessment analysis. Some exceptions include laboratories which are required to be carbon neutral by 2035, and hospitals and manufacturers which are required to be carbon neutral by 2045. This zoning amendment currently represents the most aggressive carbon neutrality policy of any zoning rule in the country.

Both Boston’s BERDO and Cambridge’s BEUDO were enacted as steps toward achieving City-wide emissions reductions and the state’s 2050 net zero greenhouse gas emissions goal. NZC zoning builds on BERDO to further Boston’s climate action priorities. LBER takes that a step further by expanding energy benchmarking to the entire state with the goal of providing meaningful insights to policymakers, building owners, and greenhouse gas planners. Clearly Massachusetts sees addressing building-level energy consumption and emissions as the next frontier in pursuing its climate goals, and CES is here to assist our clients in understanding these policies and their impacts. 

Photo by Sakorn Sukkasemsako

 

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