Regulatory Agenda: Addressing Greenhouse Gas Emissions from Health Care Building Energy Use

Abstract

Since the early months of 2025, the notion that government would adopt policies to reduce the threats from climate change seems almost quaint.However, physics and chemistry do not negotiate; collective failure to bend the climate curve can only result in increased suffering for increasing numbers of people.Most policies that work to reduce climate impacts have extensive co-benefits: they create jobs, they make the air healthier to breathe, they reduce energy costs to US businesses.Many policy makers in local and state governments still care about these benefits.Importantly, most of the policies described herein for application at a national level can also be applied by state and local authorities.In the spirit of "first, do no harm," the policy proposals advanced herein to protect the health of people and the environment-admittedly developed at a time when government seemed more attentive to the issue of climate change-still need to be advanced.The purpose of this discussion paper is to outline a series of potential policy proposals that can be implemented at the federal, state, and municipal levels of government, as well as by nongovernmental organizations, to reduce building energy Scope 1 and Scope 2 emissions from health care facilities and thus accelerate progress toward addressing the climate challenge (Greenhouse Gas Protocol, n.d.).This discussion paper does not address all Scope 1 emissions from health care organizations, such as refrigerants, inhaled anesthetics, and other sources.Thus, it should be acknowledged that this discussion paper, while addressing approximately 25 percent of overall health care emissions, leaves almost 75 percent of health care emissions unaddressed-due to Scope 3 sources, including pharmaceuticals and chemicals, medical devices and supplies, food, water, waste, and transportation.Scope 3 emissions remain a significant area to be addressed to achieve net zero emissions from the health care sector.By focusing on Scope 1 and 2 building emissions, this discussion paper attempts to accelerate progress in the area most directly in the control of health care organizations.This discussion paper is not intended to be the last word on this topic.The authors anticipate future updates to this agenda as thinking and opportunities evolve.In its waning days, the Biden Administration committed the United States to achieving a 61 percent reduction in aggregate greenhouse gas (GHG) emissions by 2035, relative to a 2005 baseline.This 2035 climate target can serve as a North Star for states, cities, and corporations (Dlouhy, 2024).The strategies outlined herein will complement recently enacted policies and available funding streams.The potential policies described in this discussion paper are not mutually exclusive.The purpose of this collection of potential policy opportunities is to offer policy makers actions they can take quickly, to help the world achieve the needed emissions reduction in a timely way.Policy makers should consider the overlap among suggested initiatives as they craft their policy agendas.In all cases, the authors have tried to describe the existing condition,

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