Despite a national goal for every building to achieve net-zero energy by 2050 and despite exemplary projects proving the technical and economic feasibility of much better energy performance, commercial buildings in the USA today use more energy per square foot than they ever have. Decisions made during planning, design, and construction (delivery) of commercial buildings appear systematically irrational, not maximizing utility for designers, occupants, or society. In other fields, notably economics, improved understanding of cognitive biases like "loss aversion" and "anchoring" has helped to explain seemingly irrational decision making. Related work has examined these cognitive biases for energy decisions made in an occupied building. Less clear is the role these cognitive biases play in the high-impact, long-term energy decisions made during commercial building delivery. As an initial step towards addressing this gap in understanding, this paper outlines key energy decisions in commercial building delivery and shows how cognitive biases may impact these decisions. A suggested approach to study these biases, and to design policies that address them, is provided. By highlighting these potential cognitive biases, based on an understanding of the building delivery process, this paper aims to engage those with relevant expertise in the behavioral and social sciences to help address the decision making that is preventing progress towards improved energy performance in commercial buildings.