Building Baselines: Veronique Bugnion
For Véronique Bugnion, climate has always been both deeply personal and profoundly practical. Growing up in Switzerland, she saw firsthand how a changing climate was transforming the mountains and glaciers that shaped her love of the outdoors. That early awareness grew into a career at the intersection of science, policy, and markets, one that now informs her work as co-founder and CEO of ClearlyEnergy, where she helps cities, states, and building owners navigate the complex work of reducing emissions from the built environment.
In this Building Baselines interview, Bugnion shares why building performance standards have emerged as such an important policy tool, what utilities and jurisdictions still need to get right on data access, and how lessons from carbon markets and international models like Tokyo can help shape the next generation of building policy. The conversation also reveals her core belief: that solving climate challenges in buildings is not just about setting targets, but about operationalizing them in ways that are flexible, data-driven, and grounded in how buildings actually work.
We hope you enjoy this deep dive with Veronique!
From Swiss Glaciers to Building Policy
To start, how did growing up in Switzerland shape your climate views?
I’m a big outdoors person, I love hiking, skiing, sailing. Growing up in Switzerland, you’re acutely aware the climate is changing, especially in the mountains. It’s sort of one of the ground zeroes for climate change. I look back now at the glaciers I skied on as a kid, and they’re nowhere near what they used to be, if they’re still there at all. The sensitivity was always there.
For me, climate is this beautiful mix of science and policy that affects the real world. I’ve been hooked on that intersection for a long time.
Say a little more about what you mean by the intersection of science and policy.
I’ve always been a STEM person. You can go down plenty of scientific tracks that lead to business like build a new engine, for example, and that’s great. But climate is different. It’s fundamentally the hardest problem we have to solve. It’s almost intractable.
It’s the intersection of complicated science, understanding how an incredibly complex climate system works and evolves, with complicated real-world policy and economics. The science tells us what’s happening and what’s likely ahead, and policy determines whether we act on it.
Buildings can work with the grid. And that work starts with whole-building data that is easy to access and easy to use, not kept under lock and key.
Turning Policy into Practice
How have your scientific and climate finance backgrounds shaped your leadership at Clearly? And how do those perspectives influence how you see building performance standards fitting into broader climate finance and market opportunities?
Clearly Energy is essentially a software company, but we work to help roll out these policies. We’re operating at the intersection of climate policy and software solutions.
For me, being unafraid of numbers and technology really helps. I’m happy being the biggest policy geek with one half of the house and the biggest tech/software nerd with the other half. I love reading policies start to finish, but I get an even bigger kick when the software developers start reading the policies, and vice versa, when the analysts start proposing software solutions. That combination is what you need to build tools that operationalize new policies.
It’s one thing to write a policy, there’s a huge amount of stakeholder work and debate that goes into it, but often it’s still done on paper without much thought for: How are we going to do this in practice? Solving the “how” is really fun.
I came to building performance standards partly from carbon markets. Tokyo has what is known as the Tokyo carbon market, but it’s really a building performance standard. I like environmental and climate policies that are market-based in the sense that they’re not telling people what to do or how to do it. They set goals and leave the marketplace to figure out how to reach them.
There’s still evolution around how “market-based” these programs really are. Tokyo’s is technically tradable. New York City looked at that approach but backed away. At the same time, many policies allow portfolio-level compliance, for example, if you have ten buildings, you can comply across them as a group. That creates quasi-trading-like behavior and flexibility without full tradability.
Tokyo has a very specific geography. Is their model scalable? And how is it doing?
It’s scalable in the right environments. Tokyo is the only case we have with real history and building performance standards have been working there.
These policies make the most sense in dense urban environments where buildings are a large share of emissions. In cities, anywhere from half to three-quarters of emissions can be buildings, so it makes sense to focus on the largest emitters—the largest buildings.
I would not expect building performance standards to work at the residential level. There’s too much data to handle; you’d need another approach. But in dense urban environments, at a high level, the design makes sense.
It also makes me consider how building stock and age factor in. For example, comparing cities experiencing rapid growth with those that have older building stock.
A lot of our built environment is already built, especially big commercial buildings, malls, office buildings, hospitals. Much of it was built decades ago, so it lags modern energy codes. You can’t only focus on new construction and ignore the huge amount of existing real estate. Retrofitting buildings built 30, 40, 50 years ago is incredibly tricky, but if cities and states have climate ambitions, it’s hard to hit them while ignoring that fraction of energy use and emissions.
You’ve worked with big cities, small communities, and states. What differences stand out, and how does Clearly adjust, especially for voluntary versus mandatory programs?
We work with everyone from Nitro, West Virginia with maybe 30 buildings, all the way up to New York City with 65,000. We’re happy working with entities of all sizes. As long as someone is willing to roll up their sleeves to tackle building efficiency, we’ll be there.
We work with voluntary benchmarking programs and the most complicated building performance standard programs. In West Virginia, we work with Energy Efficient West Virginia, and sometimes it literally comes down to a guy in a truck driving around collecting utility bills from buildings and entering the data into Portfolio Manager because that’s the only way to get some smaller jurisdictions started. You can’t just tell them, “go do it,” because they won’t. You need to do it with them.
At the other end, it’s a ton of fun to work with BPS programs as they roll out. We’ve been involved with DC since the start of their Building Energy Performance Standards (BEPS) program. They’re entering year five of compliance, which is the critical year. New York City just had its first true-up compliance year. It’s starting to feel a lot more real, and you can see the seriousness, the support, and the business opportunity it creates.
Building performance standards are also very local and need to consider their own unique needs.
Yes! One of the beautiful elements is that it’s a bottom-up movement. Every jurisdiction makes it their own, and they’re all different. From an implementation standpoint, it can be challenging. But it’s great because it’s customized to local needs. Do you want to target emissions or energy use? Are you worried about peak load? You can design for those priorities. For cities and states, it is policy-design heaven.
For big corporate real estate owners, it can be the opposite, a fragmented policy landscape that’s hard to navigate.
Why Data Access and Flexibility Matter
Should buildings be allowed to use carbon credits to comply with BPS targets? If so, under what conditions, and if not, why not?
Many programs already include flexibility mechanisms. They might allow renewable energy credits, reward early action like installing heat pumps, and so forth.
With “carbon credits,” you have to define what you mean. If it’s a broad concept of flexibility, then yes, programs should have flexibility. Buildings have their own timelines—you can’t just rip out systems overnight. Flexibility helps buildings comply on a realistic schedule.
But “carbon credit” as in any carbon credit is tricky. It gets controversial quickly. Would you accept a forest credit from somewhere far away? And many states already have policies like renewable standards—so you can’t double-count reductions from sectors that are already covered. That narrows the scope a lot.
There are other ways to create compliance flexibility without going all the way to carbon credits.
Let’s dream a bit. Tomorrow, you wake up and every utility can deliver a complete dataset for the built world including affordable housing and multifamily buildings. Utility program owners can use it to empower and inform their programs. Customers and building owners can use it to make smarter decisions for their buildings. What are you most excited about and why? What else do you think is possible with this whole building data access?
We’re at the point where its plainly obvious utilities are overprotective of their data. They need to make it more accessible, there’s so much that can be done with it.
Clearly works in the space where data is a tool to achieve compliance. But philosophically, it’s about reductions in consumption and emissions in large buildings. This space has been underinvested and understudied for a long time. These buildings are big, static sources of electricity demand.
Buildings should be able to modulate lighting continuously. They should be able to modulate HVAC and temperature continuously based on occupancy and how the building is being used. That’s not the case in many buildings today.
Buildings can work with the grid. And that work starts with whole-building data that is easy to access and easy to use, not kept under lock and key.
It’s one thing to write a policy, but often it’s still done on paper without much thought for: How are we going to do this in practice? Solving the ‘how’ is really fun.
Do you think this whole building data is useful internally for utilities?
They’re going to wake up fast. They’ve been living in a world where the grid was stable, and that world is ending rapidly. If utilities need demand flexibility, buildings are the first place to start. They are big stationary loads that are relatively straightforward to analyze and make responsive.
What Comes Next for Building Performance Standards
Back to the Tokyo model. What should U.S. jurisdictions take from Tokyo’s program, especially about balancing flexibility with clear carbon-price signals?
Tokyo’s program has been around about 15 years. Their emissions have dropped roughly 30%, which is substantial. You can debate how much was low-hanging fruit, but it’s working.
What I love is the reporting. They publish a comprehensive list of measures buildings used to comply. You can see technology waves over time: lighting retrofits early on, then building energy management systems, then heavier-duty upgrades.
And there are quirky measures too, like “casual” workdays that allow short sleeves and no tie, so offices can set thermostats higher in summer. It’s honestly the cutest thing, and it’s listed as an individual measure with quantified savings. That kind of transparency is very cool.
It’s technically a market, but I’m not aware of a transparent price signal. Trading may be happening within portfolios, buildings that over-comply can help buildings that under-comply, but we don’t see a clear public market price.
There is huge potential in improving well-being in buildings while also optimizing efficiency. With more granular controls like temperature zones, lighting levels, even lighting color, you can make spaces more comfortable and more efficient. We spend so much time indoors; making buildings more livable should be part of the goal.
If you could create one building performance rule that everyone had to follow, what would it be?
The reasonable answer is portfolio-level compliance. If you’re not going to do full tradability, at least allow entities with many buildings to comply as a group so overperformance in one building can offset another.
The more ambitious answer is time-of-use compliance, which is far more complicated. Instead of giving buildings a single grid emissions factor per year, you let them comply in a way that incentivizes avoiding the high-emitting hours. Those hours largely overlap with high grid stress hours so you create incentives to decarbonize and reduce grid stress at the same time.
It’s a nightmare to operationalize, but for jurisdictions worried about peak load, it’s a powerful design.
What metrics have proven most meaningful for measuring success, and what lessons would you share with jurisdictions just beginning?
First: collect good data at the level you’re going to implement the policy. The most obvious example is New York City: the benchmarking law is at a different level than Local Law 97, and that creates operational headaches. Spend time making sure the data foundation is robust. It takes time to properly aggregate building-level data. Without good data, you can’t build anything.
Second: remember this is a bottom-up policy. What matters locally? Is it consumption, emissions, peak load, grid stress? How do you design a program that targets what your jurisdiction cares about?
How do you see building performance standards evolving over the next decade?
We’re just reaching the true-up phase. New York City’s 2025 was year one of compliance, and we don’t have the full results yet. But the indication is that many buildings put in a lot of work on reporting, which is a fantastic start. DC’s 2026 is going to be the true-up year, and then we’ll know more.
The big question is whether cities will stick to their guns. There’s a game of chicken between real estate and jurisdictions. There will be complaints. We’ve already seen additional flexibility mechanisms like New York City’s “good faith effort,” Colorado making the first period voluntary. That push-pull will define the first wave.
I see evolution in two big directions. First, the policy landscape is becoming more complex—multiple targets, multiple programs, and other policies like renewable standards. This requires a new mindset from legacy industries. You can’t just look at retrofits as “payback under ten years”—you have to look at it within the policy context.
Second, it’s becoming obvious that buildings need to be dynamic participants in the grid rather than passive loads. Utilities, rate design, and BPS programs can all help buildings reduce electricity emissions and support grid reliability.
As cities and states move from ambition to implementation, Véronique’s perspective underscores a central truth: success will depend not just on strong policy, but on the ability to translate it into real-world action. With better data, smarter tools, and more flexible approaches, buildings can become a powerful lever for decarbonization, one that is already beginning to reshape how we think about energy, markets, and the grid itself. Many thanks to Véronique for sharing her time and insights.
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