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Office of Sustainability > BEUDO Development
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BEUDO Development

Who BEUDO Covers I What BEUDO Requires I Resources I Covered Properties Lookup I Data and Analysis

Since the Building Energy Use Disclosure Ordinance (BEUDO) amendments passed in 2023, Cambridge staff have worked with stakeholders and expert consultants to establish a framework for implementation of policy updates. This page helps you understand how that work is being done, and how BEUDO came about. 

Cambridge is committed to making BEUDO a collaborative, supportive process, with involvement by all stakeholders. We invite your questions, comments, feedback, and participation in meetings. To get involved and receive updates, sign up for the BEUDO Newsletter.

 

BEUDO Newsletter

 

 

 

BEUDO Review Board

The Building Energy Use Disclosure Ordinance (BEUDO) Review Board ensures the fair and transparent administration of the BEUDO ordinance. It reviews and makes recommendations on applications from property owners seeking extensions or alternative ways to comply with requirements. The board also approves detailed regulations that guide how BEUDO requirements are applied, including the types of credits that can be used to offset emissions.

The board has nine members, including:

  • Two who represent climate advocacy groups
  • Two from the real estate or business sectors
  • Five technical experts

Members are appointed by the City Manager and approved by the City Council for terms of three years. The board meets 1-2 times a month, on Wednesdays from 4-6 p.m. Meetings are held remotely.

Detailed procedures for the Review Board will be published later this year. Guidance and application forms for deferrals and hardships will be available by early 2026.

Deferrals

 

A property owner can ask the Review Board for extra time — up to five years — to meet BEUDO’s requirements. To do this, they must submit a detailed plan that:

  • Explains how the property will get back on track within five years.
  • Shows that overall emissions through 2050 will not be higher than they would have been without the delay.
  • Follows all related regulations.

If the Board approves the plan, the property will be considered in compliance during the deferral period. However:

  • No deferral can allow emissions to go above zero after 2050.
  • Once the deferral ends, the property must either meet its targets or buy Alternative Compliance Credits each year for any extra emissions.
  • Minimum performance standards during a deferral will be set by the City.

 

 

Hardships

 

If a building can’t meet BEUDO requirements, the property owner may qualify for a “hardship” if:

  • They can prove financial distress.
  • Their building is made up of separate commercial condo units (offices, shops, labs, etc.).
  • They’re unable to obtain enough electricity from the grid.
  • Their building has a historic designation or other regulatory restrictions that block compliance.

If requirements are met for a hardship, the property owner can submit a “hardship compliance plan” to the BEUDO Review Board. This plan must be based on an energy audit or similar assessment, must explain the overall situation, and must detail how the property owner will work toward compliance. If the Board approves it, the building will be considered in compliance for the length of time covered by the plan.



BEUDO Phases

Policies and regulations are rolling out in phases, prioritizing information building owners need to plan for compliance. The phased approach gives Cambridge staff time to research what’s working elsewhere, conduct outreach to local stakeholders, and collect community feedback. This section details what happened in Phase 1, how Phase 2 is being finalized, what to expect in Phase 3, and what future work may include. Click to expand and see more information for each phase.

Phase 1

 

As part of Phase 1, Cambridge formally enacted the first set of BEUDO regulations in December 2024. Those regulations defined how emissions would be calculated by the City, and how renewable energy could be used to offset emissions. We’ll provide brief explanations here; for more detail, review this October 2024 webinar by City staff. 

Emissions:

  • BEUDO regulates greenhouse gas emissions from energy use, including direct emissions from combustion of fossil fuels, and indirect emissions from energy purchased by a utility.
  • The City will calculate a building’s emissions based on emission factors. Those are essentially multipliers for each type of energy used.
    • Emission factors are based on standard scientific values published by federal agencies, Massachusetts’ mandatory Renewable Portfolio Standard, and a methodology from the World Resources Institute. Formulas look like this: 

Picture 843271659, Picture, Picture

 

Renewable energy:

  • Renewable energy comes from sources like solar, wind, hydro, or biomass. As Cambridge buildings transition to using these sources, their emissions will decrease.
  • Renewable energy, either on or off-site, must be purchased in the form of Renewable Energy Certificates (RECs). These are tradeable market-based instruments used to track the supply and use of renewable energy. City officials will use these certificates to verify your renewable energy use. 
  • RECs must come from eligible new projects, including
    • Solar Photovoltaic systems (rooftop, carpark, ground mounted) 
    • Solar thermal power plants 
    • Wind turbines 
    • Geothermal power plants 
    • Small hydropower 
    • Other renewable energy generating sources certified by the Department
  • RECs not previously approved by the City must be submitted for review and approval before being acquired. 
  • RECs must be submitted for retirement to the City after use to prevent double-counting.
  • On-site renewable energy must be located either on the same property that claims the RECs, or on another property in Cambridge with the same owner. 
  • Types of off-site renewable energy purchasing include:
    • Physical Power Purchase Agreement (PPA)
      • A buyer contracts directly with a provider to set up a traditional power purchase agreement for “bundled” energy & RECs from a new facility 
      • May be from project located inside or outside of New England
    • Virtual Power Purchase Agreement (vPPA)
      • A buyer acquires RECs from a new renewable energy project out of region “virtually,” effectively paying for both energy & RECs, but without taking legal title to physical energy
    • Unbundled New MA Class I REC purchases that meet 225 CMR 14.05 
      • A buyer acquires RECs from new renewable energy project that meets qualifications 
      • These are typically procured from broker or renewable energy developer 
      • May be purchased as green tariff product from competitive supplier
    • Department Approved Project or Program

 

 

Phase 2

 

A 30-day comment period on a second set of regulations took place in May 2025. They include:

  • Legal definitions for different types of properties 
  • Procedures for new and renovated properties 
  • Third party verification details
    • Emissions must be verified by an individual certified by one of the Approved Verification Bodies.
    • The individual submitting Third-Party Data Verification may not be employed by the Owner or the designated property management company for the property. 
    • The individual submitting Third-Party Data Verification may not be the same individual submitting Benchmarking Information for that Covered Property.

 

  

Phase 3

 

In Fall 2025, the City will hold a Comment period for draft regulations regarding:

  • How a group of five or more buildings with the same owner may choose to submit data and qualify their emissions as a “campus” rather than individually. They can comply with BEUDO:
    • As individual Covered Properties
    • At the aggregate Campus level
  • Initial details about how the review board for BEUDO compliance will operate, including how hardship and deferral cases will be reviewed.
  • Hardship and deferral plans for properties that are struggling to comply with BEUDO.

 

 

Future Phases 

 

City staff will revisit regulations continually to understand how they can work better for Cambridge property owners. Staff may also clarify the Alternative Compliance Credits and Verified Carbon Credits qualifications and process. 

  • Alternative Compliance Credits – Available to any BEUDO property which meets the requirements of compliance with the ordinance. If alternative compliance credits or fines are used/issued, the amount will depend based on the volume needed or length of violation. The per-unit responsibility will then vary by building size.
  • Verified Carbon Credits (VCCs) – Certifications that a project has achieved a reduction or removal of carbon dioxide from the atmosphere. These will be allowed at limited compliance options beginning in 2030. BEUDO requires City staff to develop criteria for VCCs by the end of 2028.

 

 



BEUDO Timeline

2013

Cambridge's citizen-led Getting to Net Zero Task Force searches for creative ways to stop climate change. The group focuses on buildings because they often use fossil fuels to operate and stay warm or cool, and consequently are one of the largest sources of emissions.

2014

The Cambridge City Council takes its first step to regulate building emissions by passing the Building Energy Use Disclosure Ordinance, requiring owners of Cambridge buildings of more than 25,000 square feet and residential properties with over 50 units to report annual water use and greenhouse gas emissions data with the City. The City hoped that just by tracking this information, building owners would start to reduce their pollution on their own.

2015-2016

Emissions in Cambridge do not decrease. The City launches a two-year period of talking with residents, businesses, and activists to determine next steps. 

  • Access an interactive map that shows properties covered by BEUDO in 2016, including their energy and water use.  

2017

City staff conduct extensive policy research and analysis.

  • Access an interactive map that shows properties covered by BEUDO in 2017, including their energy and water use data. 

2018

City staff evaluate the trend of energy use in BEUDO buildings and hold four meetings with stakeholders to develop a “straw proposal” for BEUDO requirements.

  • Access an interactive map that shows properties covered by BEUDO in 2018, including their energy and water use. 

2019

City officials and staff hold small group meetings with BEUDO property owners and associations to continue to develop the straw proposal.

2020
  • Access an interactive map that shows properties covered by BEUDO in 2020, including their energy and water use.

2021

City staff submit a proposal for BEUDO amendments to the City Council on November 8, 2021. 

  • Access an interactive map that shows properties covered by BEUDO in 2021, including their energy and water use data. 

2022

The Health and Environment and Ordinances Committees hold multiple hearings about the proposed amendments.

2023

Cambridge City Council approves BEUDO amendments, requiring large, non-residential buildings to reduce their greenhouse gas emissions to net zero levels over time.

2024

To develop BEUDO regulations, City staff work with expert consultants to conduct research and communicate with the public, including 10 meetings with stakeholders and three larger group forums. In July, the City and expert consultants host a meeting to discuss plans for finalizing the methodology and considerations for calculating emission factors for all energy use types in BEUDO buildings. 

2025

City staff release draft Phase 2 BEUDO Regulations and Procedures, with updated guidance on property ownership and configuration, third party verification, alternative baseline selections, and updates to the previously drafted sections regarding emission factors and renewable energy purchases. After a June 2 - July 2, 2025, comment period, staff finalized the Phase 2 Regulations and Procedures. 

2026

 City staff establish operating procedures for the BEUDO Review Board, Hardship Plan requests, and Deference Compliance Plan requests. Non-residential buildings of 100,000 sq ft or more start reducing emissions.

2027

 City staff clarify how payments will be submitted for Alternative Compliance Credits. 

2028

 City staff establish Verified Carbon Credit requirements.

2029

 City staff set the price for Alternative Compliance Credits for the next compliance period. 

2030

 Non-residential buildings of 25,000 to 100,000 sq ft must start reducing emissions. Verified Carbon Credits are now allowed as a limited BEUDO compliance option. 

2035

 Non-residential buildings of 100,000 sq ft or more reach net zero emissions.

2050

 Non-residential buildings of 100,000 sq ft or more have no on-site fossil fuels. Non-residential buildings of 25,000 to 100,000 sq ft reach net zero emissions.
   
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