From municipal building performance standards to statewide clean electricity laws, US energy policy operates across layered jurisdictions that shape the pace of system change.
Austin, Texas, set a 2040 net-zero target in September 2021 when the City Council adopted the Austin Climate Equity Plan. The plan outlines emissions pathways for electricity, buildings, transportation, and industry, linking decarbonization goals with equity considerations. Since Austin Energy is a municipal utility, the city can align electricity procurement and climate planning more directly than many US cities.
Buildings are at the center of the strategy. The plan calls for expanded electrification, efficiency upgrades, and additional renewable procurement, supported by updates to development standards and local energy codes.
Texas has taken a different approach. The state has no binding net-zero requirement, and recent legislative priorities have focused on grid reliability and market structure. The Electric Reliability Council of Texas operates a competitive wholesale electricity market that functions largely outside federal grid jurisdiction.
At the same time, Texas ranks first in the nation for installed wind capacity and has rapidly grown utility-scale solar. Data from the US Energy Information Administration shows sustained growth in both sources, driven primarily by resource conditions, transmission development, and market economics rather than a statewide emissions mandate.
The contrast between Austin’s municipal framework and Texas’s broader energy posture is a pattern seen in other cities across the country.
New York City
New York City passed Local Law 97 in 2019 as part of the Climate Mobilization Act, setting emissions limits for most buildings over 25,000 square feet. The first compliance period began in 2024, with tighter caps in 2030.
Carbon intensity thresholds vary by occupancy type. Owners of properties that exceed those limits will be fined per metric ton of carbon dioxide equivalent above the cap. Annual reporting is required, and compliance documentation must be certified by a registered design professional.
The law applies primarily to existing buildings. Large residential and commercial properties account for a big share of the city’s emissions, so operational performance is under direct municipal control. Enforcement is with the Department of Buildings.
Boston
Boston strengthened its Building Emissions Reduction and Disclosure Ordinance in 2021, turning what was a benchmarking requirement into a performance standard. The new framework applies to buildings 20,000 square feet and larger.
Compliance began in 2025 for larger properties and in 2030 for smaller covered buildings. Emissions limits decrease over time, and owners must either meet those limits or qualify under an approved compliance pathway. Reporting is annual, and penalties apply for exceeding limits. The ordinance covers existing commercial buildings and multifamily housing. By focusing on operational emissions from the existing building stock, the city puts long-term performance obligations directly on property owners.
Seattle
Seattle’s City Council passed its Building Emissions Performance Standard in 2023, setting greenhouse gas requirements for larger nonresidential and multifamily buildings. The law applies to buildings over 20,000 square feet and has phased emissions targets.
Reporting starts in 2027. Initial performance standards must be met between 2031 and 2035, depending on building type. Net-zero greenhouse gas emissions are required between 2041 and 2050 under the phased schedule.
The framework goes beyond benchmarking by tying compliance to measured emissions performance. Administration is with the Seattle Office of Sustainability and Environment, with rulemaking and reporting happening before full implementation.
Washington, D.C.
Washington, D.C., created its Building Energy Performance Standards under the Clean Energy DC Omnibus Act of 2018. The program initially applied to privately owned buildings of 50,000 square feet or more, with smaller properties phased in later.
The standard sets performance thresholds by building type rather than specific technologies. Properties must meet defined benchmarks during compliance cycles or pursue approved pathways. The first compliance period ended in 2026 for the largest covered buildings.
Owners must benchmark and report energy use annually. Civil penalties apply if buildings don’t meet minimum standards. Oversight is with the District’s Department of Energy and Environment.
The municipal cases focus on existing buildings. Emissions limits attach to individual properties, and compliance is enforced through local regulations.
State policy operates at a different scale.
Michigan
Michigan passed Public Act 235 in 2023, increasing the state’s clean electricity requirement to 80% by 2035 and 100% by 2040. The law applies to regulated utilities within the state.
Utilities show compliance through integrated resource plans filed with the Michigan Public Service Commission. The Commission reviews those plans and tracks progress toward interim targets leading up to the 2040 goal.
The statute covers electricity supply, directing changes in generation portfolios and procurement strategies across utility territories statewide.
Minnesota
Minnesota passed legislation in 2023 requiring utilities to provide 80% carbon-free electricity by 2030 and 100% by 2040.
The requirement applies to investor-owned utilities serving customers across the state. Compliance is through the state’s utility regulatory process, which reviews long-term resource planning and procurement decisions. The mandate is about electricity generation, not individual building performance, shaping the state’s energy mix through utility portfolio standards.
California
California Senate Bill 100 (2018) requires 100% of retail sales to come from renewable and zero-carbon resources by 2045. It builds on earlier renewable portfolio standards and has interim targets along the way.
Applying to all investor-owned utilities, publicly owned utilities, and other retail sellers statewide, a longer-term plan must align with the 2045 target under state regulation.
SB 100 reshapes the entire state grid over multiple decades.
Washington
Washington State’s Climate Commitment Act (2023) is a cap-and-invest program with a declining statewide emissions limit. Covered entities must buy allowances for their emissions, and the total number of allowances decreases over time.
It applies to all major emitting sectors, including electricity. Auction revenues go to clean energy, climate resilience, and related investments.
Rather than a specific electricity mix, the framework sets an economy-wide cap that utilities and other covered entities must plan within, regulated by the Washington Department of Ecology.
New York
New York updated its state building code in 2025 to implement the All-Electric Buildings Act. The changes require most new buildings to be all-electric starting in 2026, with broader application in later phases.
The new building code applies statewide and shifts new development to off-site combustion systems. Residential and commercial buildings are covered, except for defined exceptions.
Implementation has been delayed due to legal challenges, and enforcement timing has been adjusted while litigation proceeds. The code changes set a statewide electrification requirement for new construction.
Patterns Across Jurisdictions
City policies regulate building performance directly. Emissions limits apply to individual properties, and compliance is verified through reporting and inspection. In several cases, deadlines are this decade.
State policy is through utilities and large emitting sectors. Electricity mandates and emissions caps are in the 2030s and 2040s, reflecting the time it takes to shift generation portfolios and build out infrastructure.
Cities control development standards, building codes, and in some cases, municipal utilities. States regulate investor-owned utilities, wholesale market participation, and long-term resource planning. Building electrification and grid decarbonization are happening in parallel. In multiple cases, local governments have passed binding building measures before the state has done so, while state mandates drive the pace of the broader electricity sector.
Conclusion
In Austin, climate is in the municipal policy and utility strategy. In Texas, renewable growth has happened through market conditions and infrastructure investment, not a state-wide emissions mandate. Both levels influence the direction of the electricity system, but through different mechanisms.
Across the jurisdictions reviewed, municipal governments have focused on building performance, putting compliance on property owners. State governments have focused on utility portfolios, emissions caps, and generation standards that shape the grid over longer time frames.
The pace of decarbonization is the result of the interplay between those authorities. Building electrification increases demand for cleaner electricity while state mandates determine how that electricity is produced. The US energy transition is happening within this layered system of governance, where local implementation and state regulation happen simultaneously, but not always at the same pace.
