November 24, 2025

Fort Collins City Council
Mayor Arndt, Mayor Pro Tem Francis, and Council Members Gutowsky, Pignataro, Canonico, Potyondy and Ohlson
300 Laporte Ave.
Fort Collins, CO  80521

Mayor Arndt and Members of Council:

The Fort Collins Area Chamber of Commerce and its members are among the most active contributors in the pursuit of environmental, social and economic sustainability ideals.  Just as we recognize that any endeavor is only as strong as its weakest component, so too must we consider that every important strategy must be environmentally, socially and economically self-sustaining in order achieve its objectives.

Building Performance Standards, as proposed for your consideration on December 2, 2025, fails to recognize this maxim.  This regulatory, penalty-based concept encompasses far more than mere virtue-signaling, it is a direct challenge to the social and economic vibrancy of our community.  It forces property owners and businesses to commit limited capital to enhancing buildings at a time when people are demanding greater attention to their own needs.

We strongly encourage you to reject Building Performance Standards as insufficiently analyzed and poorly designed for the following reasons:

• There is NO BUDGET for implementing a Building Performance Standard program. It would be nothing short of fiduciary malpractice to adopt a program of this scale and complexity without any knowledge of what it will cost to administer and enforce, especially when the current budget is facing negative headwinds.  Additionally, we don’t know what it will cost the City itself to bring public facilities into compliance.
• Cost estimates utilized within previous presentation materials are not credible. Though promised under the pilot phase, obtaining current and relevant contractor bids did not occur.  All costs estimated based upon historical data even as supply chain constraints, international trade disruptions, and insufficient depth of skilled technicians are known to be asymmetrical cost drivers.
• Legal basis for local control over federal standards remains an open question. Less invasive programs implemented by the State of Colorado and the City and County of Denver are on hold as federal courts consider the legality and consequences of allowing local governments to pick and choose among all equipment and appliances the federal government has certified as meeting efficiency standards.  Until there is clarity, there can be no valid reason to dedicate local resources to lengthy and costly legal entanglements.
• Affordability is a concept driving tremendous concern within the community. Through prior efforts, building improvements that deliver a net financial benefit to owners and tenants have largely been completed.  Building Performance Standards, as they are being proposed, essentially requires property owners and occupying businesses to make unsound financial decisions.  This, in turn, exacerbates affordability concerns by raising commercial rents without an adequate offset of other inputs, including utility costs.

The Chamber does support the idea of deploying 2050 sales tax receipts and related sources to enhance incentives for voluntary participation.

The driving force of this program is the stated desire to address global environmental conditions.  We believe that if this truly is a shared community priority, associated costs should not be shouldered by property owners and businesses alone.  The community as a whole must share in the responsibility for affecting change.

As you consider weakening demographic and economic trendlines, now is not the time to double down on environmental policies that lack adequate rigor.  The choices made today will determine who can live here tomorrow.

Sincerely,

Fort Collins Area Chamber of Commerce
Ann Hutchison, CAE
President & CEO

cc:     Kelly DiMartino; Jacob Castillo