- Am I required to benchmark?
- What is Portfolio Manager and how do I benchmark my property?
- What information am I required to provide?
- How do I report my data to DOEE?
- What is the reporting deadline?
- What happens if I do not meet the reporting deadline?
- What is a DC Real Property Unique ID Number?
- What is required of tenants and where can I get whole-building data?
- My building is ineligible to receive an ENERGY STAR Score; am I still required to benchmark?
- How can I improve the energy efficiency of my building?
- If I submit my Report and then realize I made a mistake, or find out that there was a utility bill error, can I correct and resubmit it, even after the deadline?
- What are the "worst" practices in energy benchmarking, and how can I avoid them?
- What happens when a building transfers ownership?
- Should I exclude certain non-ratable commercial spaces?
- How do I collect information for and benchmark multiple structures?
Currently, benchmarking is required for all privately-owned buildings over 50,000 square feet and District-owned buildings over 10,000 sq. ft., as mandated in the Clean and Affordable Energy Act of 2008. Starting with the calendar year 2021 data (due April 1, 2022) all privately-owned buildings over 25,000 square feet will be required to benchmark, and starting with the calendar year 2024 data (due April 1, 2025) all privately-owned buildings over 10,000 square feet will be required to benchmark, as mandated under the Clean Energy DC Omnibus Act. Under these mandates, building owners are required to track the energy and water usage for their building(s) using ENERGY STAR® Portfolio Manager and report that data to the Department of Energy and Environment (DOEE) on an annual basis.
What is Portfolio Manager and how do I benchmark my property?
Portfolio Manager is a free, secure, web-based benchmarking tool developed and maintained by the U.S. Environmental Protection Agency (EPA). The program calculates a 1-100 performance score for 21 different building types using a building’s energy use, water use, and characteristics (e.g. size, type(s) of use, number of occupants, etc.). This score allows building owners to evaluate their building’s performance based on scores of similar buildings nationwide.
If you are benchmarking a property for the first time, the EPA offers live and pre-recorded webinars that demonstrate how to navigate ENERGY STAR Portfolio Manager and how to use all core functionalities needed to properly benchmark your building.
Building owners are required to report whole building energy and water utility data, space use information, and garage or other secondary space information associated with a building’s energy and water use. Whole building data refers to energy and water data for the entire property, including all retail, tenant, and common area spaces. This may be in the form of one central meter or a combination of house and tenant (residential and non-residential) meters. Detailed instructions on what information is required and how to collect it can be found on DOEE’s Energy Benchmarking Data Collection page.
After entering all data properly into Portfolio Manager, you will need to ensure that this data is then transmitted to DOEE. DOEE now utilizes Automatic Reporting through Portfolio Manager Web Services for all benchmarking reports. Detailed instructions for both options can be found on DOEE’s benchmark reporting page.
What is the reporting deadline?
Benchmarking reports are due on April 1st of each year for the previous calendar year’s energy and water consumption. For example, the energy and water consumption tracked in Portfolio Manager for calendar year 2018 is due April 1, 2019.
Any building owner that fails to meet the benchmarking requirements can be subject to fines of up to $100/day of non-compliance. Prior to imposing fines, DOEE is required to issue a formal warning. Thus, any building owners found to be out of compliance will first receive a Notice of Violation, giving them (30) days to comply before receiving a fine. Once the thirty (30) days has expired, DOEE may then begin issuing fines of up to $100/day.
What is a District of Columbia Real Property Unique Identification Number?
The DC Real Property Unique ID Number is the number that uniquely identifies your building in the District’s records. It is the Square-Suffix-Lot (SSL) number from your District of Columbia Property Tax Records. For condominiums, it is the Square-Suffix-Regime (SSR) number (Every condominium is assigned a four-digit unique “regime” number by the District government.) These numbers can be found on the Covered Building List published every year or the DC Master Address Repository.
The DC Real Property Unique ID Number is how DOEE will match your submitted report with the tax lots on the covered building list. Without an accurate up-to-date DC Real Property Unique Property ID Number DOEE will not be able to mark your report compliant and your property may be subject to fines.
To enter or verify your DC Real Property Unique ID Number, navigate to the “Details” tab of your property in Portfolio Manager, then click the edit box in the “Unique Identifiers (IDs)” section on the left side of your screen. You will then be able to edit the custom and standards IDs. The DC Real Property Unique ID will show as an option under the Standard IDs section. Please make sure you enter the DC Real Property Unique ID and not the DC Building Unique ID.
What is required of tenants and where can I get whole-building data?
Non-residential tenants are required to provide the building owner or manager energy, water, and space use information within thirty (30) days of the initial request. Non-residential tenants can opt to provide actual bill data, or sign a utility release waiver to grant their landlord access. Failure of tenants to comply could lead to enforcement and fines by DOEE.
Residential tenants are NOT required to provide any data to their landlord, however many multifamily properties are master-metered so whole building utility data can be collected without having to go to individual tenants. For multifamily properties that are not master metered but have five (5) or more individual meters, aggregated whole building data can be requested from the utility company(ies). Many properties keep the meter numbers on record; however, if the records are unavailable then you will have to physically check the meters by visiting the “meter bank” in the property, or any other location where the meter numbers are housed.
Whole building aggregate data is accessible through both Pepco and Washington Gas and can be automatically uploaded to your property in Portfolio Manager®. Through Pepco’s Resource Advisor tool and Washington Gas’s Utilli tool, you can collect electric and natural gas data for your facilities and have online access to historic data any time you need it, as well as monthly updates. To protect the confidentiality of individual tenant electricity use, this monthly data will be provided in aggregate form for the entire building. Once you have successfully set up your Resource Advisor or Utilli account, your utility provider will outline the necessary steps to ensure utility data is automatically uploaded into your Portfolio Manager account.
Yes, building owners are required to benchmark and report their data to DOEE, regardless of whether their building(s) can receive a score or not. The law applies to all building types “for which ENERGY STAR® tools are available.” Even if an ENERGY STAR® score cannot be calculated, Portfolio Manager can still generate many useful statistics, including weather-normalized source Energy Use Intensity (EUI) and direct and indirect greenhouse gas emissions. Portfolio Manager allows you to benchmark your building against its own past performance regardless of whether a score is generated.
The DC Sustainable Energy Utility (DCSEU) can assist you in saving energy and money in your buildings. Through their custom rebate programs, free technical assistance, and training programs, DCSEU will work with you to design a customized strategy for maximum energy efficiency improvement. Contact DCSEU at 202-479-2222 or visit the DCSEU website.
Additionally, U.S. EPA’s proven Guidelines for Energy Management offered by ENERGY STAR® can help you determine where to start and how to maximize the return on your upgrade investments. Additional information on energy management, efficient technologies, and financial evaluation can be found on the Tools & Resources page on the ENERGY STAR® Website.
If I submit my Benchmarking Report and then realize I made a mistake, or find out that there was an error in the utility bills, can I correct my report and resubmit it, even after the deadline?
Yes, you must. If an owner receives updated data, they have thirty (30) days from the date the updated data is received to submit a revised report to DOEE. One example of when this would be necessary is when a non-residential tenant does not provide the building owner with the required energy and property use data, but then provides the building owner with this data after the April 1st deadline. Another instance of needing to provide an updated benchmarking report would occur when a building owner receives corrected data from a utility provider after the building owner has already submitted a report to DOEE.
What are the "worst" practices in energy benchmarking, and how can I avoid them?
ENERGY STAR Portfolio Manager® put together a useful list of “worst practices” of energy benchmarking and propose solutions for avoiding those mistakes.
What happens when a building transfers ownership?
Per the provisions of the Sustainable DC Act of 2014 (D.C. Official Code § 6-1451.03(c)(2)(E)), when a property is transferred, the seller is required to provide the buyer with the information necessary for the buyer to submit a complete benchmarking report in a timely manner. Once in possession of a full calendar year of data comprising both the period of their ownership and the period of the seller’s ownership, the buyer/new building owner must submit a complete and accurate benchmarking report to DOEE by April 1 of the year after the building is transferred. In order for the buyer to meet this requirement, the seller has a few options in terms of transferring the information (click the links for instructions from EPA ENERGY STAR):
- Transfer Property Data Administrator privileges in Portfolio Manager to the buyer
- Share the property, with “Full Access,” in Portfolio Manager with the buyer
- Provide the buyer with property use information and utility bills for all energy and water sources during the time period that the property was in the seller’s possession
If the new owner is unable to get the required data, you may submit a partial report with the data you do have, and then follow-up with DOEE in writing to provide explanation and documentation as to your efforts to acquire the needed data. DOEE will evaluate the new owner’s submission on a case by case basis.
Should I exclude certain non-ratable commercial spaces?
Spaces that meet the definition of one of the property use types eligible for an ENERGY STAR score in Portfolio Manager (i.e. following the EPA guidance on ratable space types) cannot be excluded under any circumstances. If such a property use type is excluded from Portfolio Manager, the property cannot earn an accurate score. When entering data, DOEE recommends (but does not require) grouping all instances of a single property use type together, unless they vary dramatically in operating characteristics.
It is best practice to include all of a property’s floor area when benchmarking. All commercial property uses that do not qualify as one of the types eligible to earn an ENERGY STAR score can be benchmarked as a subtype of the category “Other.” You may exclude a portion of the property from the benchmarking report if, and only if, all of the following conditions are met:
- The property use and energy use patterns are significantly different than those of the rest of the building (for example: A restaurant or a gym in an office building);
- The space is less than 10% of the building’s gross floor area;
- The space must not be a type eligible to receive an ENERGY STAR score;
- The space’s energy use is separately metered or sub-metered for all energy sources, so that both the space’s floor area and total energy consumption can be excluded from the benchmarking report; and,
- The building as a whole is eligible to receive an ENERGY STAR score.
If all of the above conditions are met, then that space, and only that space, can be excluded from the building’s record in Portfolio Manager, including the building’s total gross floor area. These exclusion guidelines do not affect whether the building as a whole is required to report.
How do I collect information for and benchmark multiple structures?
If your property has energy or water meters, or buildings systems (such as a central gas furnace), shared across multiple structures, then the energy use cannot be attributed to any individual building. In such cases, the buildings must be benchmarked as a single property in Portfolio Manager. Hospitals, K-12 schools, and multifamily housing properties in this situation should be benchmarked as a single property. University campuses and other large campuses comprised of buildings with vastly differing uses should benchmark and report in the same manner as any other property in Portfolio Manager but select “More than One” and the number of buildings in the first screen when creating a property.
Note that if you have multiple buildings that are separately metered for all energy sources, but share a common water meter, DOEE recommends that you pro-rate the water use across the buildings by their gross floor area. Read more guidance from EPA on benchmarking campuses.