I would strike the 2nd draft inclusion of reviewing any regional BPS if it's in GHGi. There are some state and local BPS which are GHGi-only or such as Colorado's which has both a site EUI and optional GHGi path. CO's Reg 28 is also capped at $60,000 per annum regardless of building size or the amount the building exceeds its targets. The targets are also the same for all 4 of CO's climate zones.
The point being too many BPS will be poorly designed and some are set at the top 15th percentile of incoorect datasets and some are at the bottom 35th percentile. And GBCI won't have the bandwidth to track all the nuances of each jursdiction's requirements and how they deal with on-site and off-site renewables and the sale or retention of RECs (Denver allows the sale of RECs and CO does not). I don't see how adding this new language or requirement actually adds value compared to asking the design team to figure out their GHG emissions vs the red tape of a poorly conceived BPS.
Associate Principal
ME Engineers
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