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Am I Required to Benchmark

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All privately owned commercial and multifamily buildings over 50,000 gross square feet are required to measure and report energy and water benchmarking data to the District on a yearly basis by April 1 of each year.

Covered Building List

DOEE had published a list of buildings covered by the benchmarking regulation. The DC Real Property ID, square footage (as listed in the tax records), premise address, owner of record, and ward are provided. You need to include the District of Columbia Real Property Unique ID when you report your building.


DOEE regulations allow exemptions from the benchmarking regulations under certain conditions. Major exemption categories are listed below; these are largely not new, but are listed here for clarity.  All exemption requests should be made in writing to [email protected]. DOEE has final authority on whether to grant any exemption.

  • Unoccupied: A building may apply for an “unoccupied” exemption if on average less than one full-time-equivalent employee or occupant (less than 40 person-hours per week/2080 person-hours per year) worked or resided in the building, exclusive of security guards, janitors, construction workers, landscapers, and other maintenance personal during the year being reported. (20 DCMR 3511.2(d))
  • National Security: If you believe the disclosure of the energy use of the building would be harmful to the public interest and national security, you may apply for an exemption from reporting or public disclosure. (20 DCMR 3511.2(b))
  • New Construction: If your building received its Temporary or Permanent Certificate of Occupancy in the year being reported then reporting will commence once a full calendar year of utility data can be collected. (20 DCMR 3513.11(a))
  • Demolition: If your building was demolished in the year being reported, then reporting is not required, as the building no longer exists. (20 DCMR 3513.1)
  • Under the threshold: If your building is smaller than 50,000 gross square feet, then it is not required to benchmark, unless it shares energy use with other buildings. (20 DCMR 3513.1)

Note that effective January 1, 2016, owners are no longer eligible for the sale exemption. The provisions of the Sustainable DC Act of 2014 (D.C. Official Code § 6-1451.03(c)(2)(E)) state that 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 prior ownership, the building owner must submit a complete and accurate benchmarking report to DOEE by April 1 of the year after the building is transferred.

Now that you know if you are covered by the regulation, find out how to collect the data you need.