Despite trends at the national level, my hometown of Evanston, IL, a small city located just north of Chicago, has put a stake in the ground to show that local governments will lead the continued push for climate action. On March 10, Evanston passed a building performance standard (BPS)—the first passed in Illinois, the first in 2025 and the second in the Midwest, following St. Louis.
The Healthy Buildings Ordinance (HBO) includes many of IMT’s best practice recommendations, including setting multiple metrics to encourage efficiency alongside emissions reductions and setting up a community accountability board structure, to ensure equity is at the forefront of the rule-making and implementation process. The HBO is the first BPS passed since Newton, MA passed their policy in late 2024 and serves as evidence that small cities are leading the charge on BPS.
The ordinance will amend and build on Evanston’s existing laws: 1) benchmarking law that has been in place since 2016 and 2) the city’s Climate Action and Resilience Plan (CARP), which was approved by City Council in 2018 and calls for carbon neutrality by 2050 (see this timeline from Illinois Green Alliance). As 80% of Evanston’s GHG emissions come from buildings, policies for this sector are critical to meeting that carbon neutrality goal. Evanston’s staff project this ordinance will reduce emissions across the city by 45% by strategically targeting larger buildings. While reducing emissions in these large buildings is itself a worthy endeavor, community advocates made clear that we cannot address climate goals at the expense of residents who are already vulnerable. In this critical decade, we need to seek solutions that can both reduce carbon emissions and improve the lives of community members. Evanston’s Community Accountability Board will be the mechanism to protect residents and businesses.
Now let’s dig into the design
The HBO, which used IMT’s short model law as a jumping off point, sets performance requirements for approximately 500 of Evanston’s largest buildings–mostly commercial and multifamily buildings over 20,000 square feet, condominiums over 50,000 square feet, and municipal buildings over 10,000 square feet. The ordinance sets the goal posts for the two performance targets buildings must achieve by 2050: zero on-site emissions and 100% renewable electricity procurement.
The ordinance establishes two new boards which will provide legislative guidance and allow for democratic input. The boards are charged with developing the interim targets, the structure for fines, and the compliance pathways, and flexibility mechanisms. One is a technical committee to develop regulatory details. The other is a Healthy Buildings Accountability Board to ensure that compliance pathways and classifications, such as ‘equity priority buildings’ reflect community priorities and do not lead to unintended consequences. Board members are nominated primarily by the mayor and approved by the city council, with some seats set aside for key stakeholder groups, as discussed below. The boards’ recommended rules will also have to go back to city council for adoption before they can be enforced. The HBO passed in one of the last council meetings before a local election, and two of the current council members are not running for re-election. Therefore the composition of the boards and the implementation rules will be approved by a different group of elected officials that includes at least two new voices. Community advocates felt that this added an additional layer of democratic process to the ordinance’s timeline by giving a different set of elected officials the opportunity to have a say in the final regulations.
Metrics are the meat of the requirements in any BPS. The HBO includes three primary metrics to meet by 2050: 1) phased reductions in site energy use intensity (EUI), 2) achieving zero on-site emissions, and 3) procuring 100% of electricity through renewable sources. That last metric is the first of its kind among similar BPS policies, and makes Evanston’s BPS rule-making process one to watch. The HBO explicitly builds on commitments already made at the state level through the Clean Energy Jobs Act. These commit Illinois to a clean, zero-carbon electricity grid as well as to aligned goals from Evanston’s electricity utility, ComEd. Unlike the other two, the final 2050 EUI standards will be developed as part of the rule-making process. The intention with including the EUI metric is to encourage efficiency alongside decarbonization goals and ensure that building owners don’t opt for inefficient electric equipment (such as electric resistance heating) to meet emission standards, which could negatively impact tenant utility costs.
While there will be upfront costs to making these building improvements, those should be understood within the context of equipment lifecycles and operations planning. Within the twenty-five year timeframe covered by this ordinance, most of the covered buildings will need to replace HVAC equipment anyway, since most equipment has a useful life of 15-20 years. In addition, area residents are bracing for another round of rate hikes from methane gas providers. Nicor Gas, the state’s largest gas utility, serves Evanston. It filed a proposal earlier this month that would increase customer charges more than $20 per month on average (see this analysis by the Citizens Utility Board) Absent energy efficient improvements, residents will pay higher utility costs and also need increasing amounts of energy to stave off summer heat.
Civic engagement
In addition to including three performance metrics, the HBO also more formally delegates power to building owners than others we’ve analyzed at IMT. Three specific local building owners associations were given the power to nominate representatives to the technical committee as a way to ensure that building owner concerns around cost feasibility, will be given adequate consideration as part of the rule-making process. Building owners and managers were vocal throughout the legislative process, and the amendment to include this direct nomination power was made after a third council discussion in which council members could not reach consensus. While the intention was always to include building owners in making the rules, this amendment makes that increasingly explicit; with only six total seats on the technical committee, representatives of building owners will control half the committee. Those three members of the technical committee will also be given the opportunity to join the Healthy Buildings Accountability Board (HBAB) to ensure their perspectives are given further weight. The HBAB will have an additional six members nominated by the mayor.
As part of the engagement process, staff and council members worked together to ensure that community input helped to shape the bill. An appeals process was added to the language around the alternative compliance process to make it explicit that applications will not be unreasonably denied. Additionally, the percentage of fines collected for non-compliance was increased from fifty to ninety percent to support compliance for under-resourced buildings.
What’s next
Now that the ordinance has been adopted, the next step is for the city to set up the two rule-making bodies and begin the challenging work of making sure Evanston’s rules truly reflect the needs of its residents and businesses. Rule-making is projected to last for about a year and then, as is detailed in the ordinance, city council will need to formally amend the ordinance to begin the enforcement process.
In the meantime, there are ways building owners can get started. They should reach out to the nonprofit Building Energy Resource Hub to understand the resources available for retrofitting their buildings, including a help desk which provides one-on-one support to Evanston properties. Additionally, building owners should explore financial supports. In an exciting recent development, Illinois’s Climate Bank recently launched its Energy Efficiency Revolving Loan Fund to provide loans to support nonprofits and public entities with decarbonization retrofits.
Call to action
I was fortunate to participate in the city’s Building Electrification Working Group, which supported city staff in policy design, and many of the stakeholder discussions leading up to policy passage. It was so exciting to participate in the process to get an ambitious, forward-looking policy designed in my own backyard. Cities, smaller ones in particular, rely on engaged residents to help out. One of the most moving layers of this experience has been seeing the span of generations involved in getting this policy across the finish line. From the retired engineers that led the working group, to the young activists from our local high school and Northwestern who showed up at every meeting to speak up for the future they want to see. It was truly an intergenerational effort.
At a moment when local action is so critical to meeting our climate goals, I urge you to get involved where you live. These policies are complex and thoughtful design can improve the chances that they lead to positive outcomes for both people and the climate.
