Sustainability Services
GHG Emissions Reporting — Measure, Report, and Reduce Your Building's Carbon Footprint
Building performance standards in NYC, Boston, and DC are shifting from energy-use targets to carbon emissions limits. Know your numbers before the deadline does.
Why It Matters Now
The Rules Changed. Energy Alone Is No Longer Enough.
For years, building performance programs focused on energy use intensity (EUI) as the primary compliance metric. That is no longer the whole picture. New York City’s Local Law 97 penalizes buildings based on carbon emissions intensity—not just how much energy they use, but what kind. A building heated by natural gas faces a very different compliance challenge than an all-electric building with the same EUI. Boston BERDO 2.0 and Washington DC’s BEPS follow similar carbon-first frameworks, and other jurisdictions are moving in the same direction.
Many commercial building owners do not have a clear picture of their Scope 1 and Scope 2 greenhouse gas emissions. Annual GHG reporting is increasingly required under municipal law and expected by lenders, institutional investors, and ESG disclosure programs such as GRESB and CDP. Getting your emissions baseline right is not a compliance checkbox—it is the foundation for every capital decision you make in the next decade.
Understanding Emissions
Scope 1, Scope 2, and Scope 3 Explained
The GHG Protocol divides emissions into three categories. For most building performance standards, Scope 1 and Scope 2 are what determine your compliance status.
Direct Emissions from On-Site Combustion
Scope 1 covers greenhouse gases released directly from equipment and processes that the building owner controls and operates on-site.
- Natural gas boilers and furnaces
- Fuel oil heating systems
- Backup diesel generators
- On-site propane combustion
Indirect Emissions from Purchased Energy
Scope 2 emissions result from energy the building buys from outside sources. Combustion happens off-site, but the building’s demand drives those emissions.
- Purchased electricity from the grid
- District steam from a utility provider
- Purchased chilled water
- Other purchased thermal energy
Value Chain Emissions
Scope 3 captures emissions beyond what the owner directly controls or purchases—spanning upstream supply chains and downstream tenant activity.
- Tenant-controlled energy use
- Embodied carbon in construction materials
- Commuter and visitor transportation
- Waste generated in operations
Scope 3 is generally not required for BPS compliance today, but is increasingly tracked for GRESB, CDP, and institutional ESG reporting.
Our Services
What We Deliver
From raw utility data to a regulatory-ready submission and a clear path to lower emissions—we handle the full scope of GHG work for commercial building owners.
GHG Inventory
A complete, documented Scope 1 and Scope 2 emissions calculation for your building or portfolio. We collect 12 months of utility consumption, apply jurisdiction-appropriate EPA emissions factors, and produce a verified total expressed in metric tons CO₂e and kgCO₂e per square foot.
Annual Reporting
Preparation and submission of required emissions reports to NYC, Boston, DC, and other regulatory agencies. We ensure your data meets jurisdiction-specific format requirements, submission deadlines, and certification standards so you avoid late penalties and reporting errors.
Gap Analysis
A comparison of your current emissions intensity against the applicable jurisdiction target for your compliance period. We quantify the shortfall in metric tons CO₂e, translate it into projected annual penalties under the current penalty rate, and prioritize where intervention will have the greatest compliance impact.
Reduction Roadmap
A prioritized list of capital improvements and operational changes ranked by cost per ton of CO₂e reduced. We evaluate fuel-switching, electrification, envelope upgrades, renewable energy procurement, and demand response options—giving you a clear investment plan tied to compliance targets, not just energy savings.
Regulatory Landscape
Jurisdictions Requiring Emissions Reporting
Carbon reporting mandates are expanding. Here is where annual GHG disclosure is currently required for large commercial buildings.
| Jurisdiction | Program | Compliance Metric | Building Threshold | Reporting Frequency |
|---|---|---|---|---|
| New York City | Local Law 97 | Carbon intensity (kgCO₂e / SF) | >25,000 SF | Annual |
| Boston, MA | BERDO 2.0 | GHG emissions intensity | >20,000 SF | Annual |
| Washington, DC | BEPS | GHG emissions | >50,000 SF | Annual |
| Washington State | Clean Buildings Act | EUI (energy-based) | >50,000 SF | Annual |
| Colorado | Building Performance Standards | EUI + GHG emissions | >50,000 SF | Annual |
Thresholds and reporting requirements subject to change. Contact us for current requirements in your jurisdiction.
Our Methodology
How We Calculate GHG Emissions
Our process follows EPA Emission Factors for Greenhouse Gas Inventories and GHG Protocol guidance, producing defensible, audit-ready results.
Collect 12 Months of Utility Consumption Data
We gather actual consumption records for all fuel types and purchased energy sources serving your building: electricity (kWh), natural gas (therms or CCF), fuel oil (gallons), district steam (MMBtu), and chilled water (ton-hours). We work directly with utility providers when needed and validate meter-level data for multi-tenant properties.
Apply EPA Emissions Factors for Your Utility Region
Electricity-related emissions vary significantly by geography because different utility grids have different generation mixes. We apply the most current EPA eGRID subregional emissions factors for your service territory for Scope 2 calculations, and EPA stationary combustion factors for Scope 1 fuels. This ensures your inventory reflects actual grid conditions, not national averages.
Calculate Scope 1 and Scope 2 Emissions in CO₂e
Consumption figures for each fuel type are multiplied by the appropriate emissions factor to produce CO₂, CH₄, and N₂O emissions, then converted to CO₂ equivalent using IPCC global warming potential values. The result is a single, jurisdiction-ready figure expressed in metric tons CO₂e total and kgCO₂e per square foot of conditioned floor area.
Benchmark Against Jurisdiction Targets and Prior Years
We compare your emissions intensity to the applicable compliance target for your building’s primary occupancy type and size tier, identifying surplus or shortfall in metric tons CO₂e. Year-over-year trending shows whether your building is improving, flat, or worsening—and informs the prioritization of reduction measures in your roadmap.
Common Questions
Frequently Asked Questions
Answers to the questions building owners and property managers ask most often about GHG emissions reporting.
A building GHG inventory is a structured accounting of all greenhouse gas emissions generated by a property over a 12-month period. It quantifies Scope 1 emissions (direct combustion of natural gas, fuel oil, or other on-site fuels) and Scope 2 emissions (indirect emissions from purchased electricity, steam, or chilled water). The result is expressed in metric tons of CO₂ equivalent (tCO₂e) or as an emissions intensity (kgCO₂e per square foot). Jurisdictions like NYC Local Law 97 and Boston BERDO 2.0 use this figure to determine compliance status and assess annual penalties.
Scope 1 emissions are direct greenhouse gas emissions from sources that the building owner controls. For commercial buildings, this typically means combustion of natural gas in boilers or furnaces, operation of backup diesel generators, or burning of fuel oil. Scope 2 emissions are indirect emissions that result from purchasing electricity, district steam, or chilled water from a utility. Although combustion happens off-site at the power plant, the building is responsible for those emissions under most carbon reporting frameworks because its energy demand drives them.
Mandatory GHG emissions reporting requirements vary by jurisdiction. In New York City, Local Law 97 requires annual GHG intensity reporting and enforces carbon caps on buildings over 25,000 square feet starting in 2024. Boston BERDO 2.0 applies to buildings over 20,000 square feet. Washington DC BEPS covers buildings over 50,000 square feet. Colorado’s BPS incorporates GHG alongside energy-use targets for large commercial buildings. ESG disclosure programs such as GRESB and CDP also expect GHG inventories from institutional real estate owners regardless of regulatory mandates.
NYC Local Law 97 penalties are calculated based on the difference between a building’s actual carbon emissions intensity (in kgCO₂e per square foot) and the applicable emissions limit for its occupancy type. The excess emissions, expressed in metric tons of CO₂ equivalent, are multiplied by $268 per tCO₂e per year (the current penalty rate). For large buildings with significant excess emissions, annual penalties can reach tens or even hundreds of thousands of dollars. Penalties accrue annually for each compliance period in which the building exceeds its cap, making early action and accurate measurement critical.
Yes. Measuring emissions is the starting point, not the finish line. Once we complete your GHG inventory and gap analysis, we develop a prioritized reduction roadmap that identifies the capital improvements and operational changes with the highest carbon reduction per dollar spent. Common measures include fuel-switching from natural gas to electric heat pumps, LED lighting upgrades, building envelope improvements, and renewable energy procurement. We also evaluate compliance flexibility options available under specific ordinances, such as purchasing renewable energy credits or participating in beneficial electrification programs.