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DC Benchmarking Trends Part I: How are Buildings Faring with Respect to BEPS?

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Introduction

The end of the DC Building Energy Performance Standards (BEPS) compliance cycle is less than two years away, ending on December 31, 2026, and building performance improvements need to be in place by the end of 2025 in order to collect a full year of data for the Dept. of Energy and Environment (DOEE) to evaluate compliance with BEPS. The District’s annual 2023 benchmarking data was third-party verified which improves the accuracy of the data and provides a good snapshot of where buildings stand with respect to compliance at the end of the cycle. AOBA and the Building Innovation Hub (Hub) are interested in this data to help advise our stakeholders and members on how multifamily and offices are doing with respect to this current BEPS. We also seek to answer two big questions:

  1. How many buildings are meeting the median BEPS threshold today?
  2. What options are available to buildings that don’t yet meet the BEPS threshold?

The observations in this blog apply generally. Specific buildings will have their own unique challenges and may have different experiences. The Hub will be analyzing additional building typologies later this year.

ENERGY STAR & BEPS

How many office buildings meet the BEPS threshold today?

As of February 2025, about 71% of offices over 50,000 square feet (SF) in the District have ENERGY STAR scores that are above the median BEPS threshold of 71. Figure 1 below shows the ENERGY STAR ratings for 430 offices based on 2023 benchmarking data currently accepted by DOEE. Buildings with an ENERGY STAR rating at or above 71 meet the BEPS, while buildings below an ENERGY STAR rating of 71 do not meet the BEPS threshold. The one-third of office buildings that are currently below the BEPS standard may include buildings that are still on track for compliance depending on the pathway selected and distance from the standard. In the graph below, ENERGY STAR ratings from 1-40 have been sorted into buckets of 10 ratings points; scores above 40 have been sorted into buckets of 5 ratings points. This was done for formatting purposes since most Washington, DC offices and multifamily buildings have ENERGY STAR ratings above 40.

Figure 1: 2023 ENERGY STAR ratings for offices in Washington, DC, based on data obtained on February 24, 2025.

Figure 1: 2023 ENERGY STAR ratings for offices in Washington, DC, based on data obtained on February 24, 2025.

Of the 126 offices that are below the BEPS threshold, 81 buildings (or 19% of total buildings in the dataset) have an ENERGY STAR score between 55 and 71. These buildings are in a range, generally speaking, where the score is within 20% the BEPS standard. This indicates that the Standard Target pathway is a possible method of meeting BEPS. Reference Table 32 in Appendix D of the BEPS guidebook for scores which represent about a distance of 20% from the BEPS. Note that for some buildings, the Performance Pathway would still be the preferred approach depending on specific conditions of their building.

For the 10% of office buildings with an ENERGY STAR score below 55 (about 45 buildings), it is likely that the majority of these buildings selected the Performance Pathway to comply with BEPS due to the distance from the standard. In that case, the current ENERGY STAR metric is less relevant for BEPS compliance; for buildings on the Performance Pathway, the path to BEPS compliance is a 20% reduction in site EUI adjusted to current year.

How many multifamily buildings meet the BEPS threshold today?

About two-thirds of multifamily properties (68%, or 459 out of 675 buildings) meet the BEPS threshold of an ENERGY STAR score of 66. See Figure 2, below, for the breakdown of scores for buildings 50,000 square feet and up. In the graph, ENERGY STAR ratings from 1-40 have been sorted into buckets of 10 ratings points; scores above 40 have been sorted into buckets of 5 ratings points. Similar to Figure 1, the formatting reflects that most Washington, DC offices and multifamily buildings have ENERGY STAR ratings above 40.

Figure 2: 2023 ENERGY STAR ratings for multifamily in Washington, DC, based on data obtained on February 24, 2025.

Figure 2: 2023 ENERGY STAR ratings for multifamily in Washington, DC, based on data obtained on February 24, 2025.

According to Figure 2, about 25% of multifamily buildings (173 buildings) have an ENERGY STAR score between 31 and 66. While this is a much larger range of ENERGY STAR scores than for offices in Figure 1, once again Table 32 in Appendix D of the BEPS Guidebook indicates that this is about a distance of 20% from the BEPS. About 41 multifamily buildings, or 6%, have an ENERGY STAR rating below 31.

What can you do from here?

While this news is generally positive for District office and multifamily buildings, approximately one-third of office and multifamily buildings still have ENERGY STAR scores that are below the median BEPS threshold. Many of these buildings are on track and actively implementing measures to improve their ENERGY STAR scores to meet or exceed the BEPS threshold or reduce their site EUI adjusted to current year by 20% by the end of the compliance cycle. This is the last year to make performance improvements to ensure a full year of performance data to demonstrate compliance with BEPS Cycle 1. For the buildings that have not gotten started, here is some general guidance:

Benchmarking data

  • Revisit your building’s third-party verified benchmarking data which may have resulted in changes in your property’s ENERGY STAR score. Depending on how much the score may have changed relative to the standard, it may have an impact on the pathway chosen to meet BEPS. If a building is currently on a different pathway and you would like to change it, submit a Pathway Change Application to DOEE.

Energy audits

  • Look at your energy audit(s) and identify measures that you can likely implement by the end of December 2025. If you haven’t done an energy audit, use the Hub’s sample scope of work as a starting point. Most energy audits will include a mix of operational improvements, low-cost measures, and capital projects. Ideally you will be able to determine if those measures can help you meet the BEPS. Technical support, such as an energy auditor or energy management consultant, may be needed to help narrow the potential pool of measures. Note that for purposes of BEPS compliance, there may not be enough time for an in-depth energy audit and implementation measures, so discuss with your consultant your available options given the time constraints.

Financing

  • If those measures will help you meet BEPS, consider your access to capital, incentives, grants, or other financing mechanics to let you implement these measures. Local sources to help with funding and financing include:
    • Hub’s Funding & Financing Map hosts a database of major incentive and financing programs.
    • DC Green Bank offers innovative financing solutions that prioritizes making the clean economy inclusive and affordable for all DC residents, businesses, and community institutions.
    • DC Sustainable Energy Utility (DCSEU) provides incentives and rebates including business rebates and tailored assistance programs.

Additional resources

When all else fails

If those measures may not be enough to meet BEPS on their own by the end of the compliance cycle, then you may need to look at implementing intelligent measures to help reduce exposure to potential alternative compliance payments. If this is the case, the next two steps could also be considered.

  • BEPS delay mechanics may be available for qualifying buildings that demonstrate a good cause for a delay. The eligibility criteria and processes for a delay are defined in section 5.2 of the BEPS Guidebook. Additional circumstances for Qualifying Affordable Housing are covered in Section 5.3. The maximum allowable delay is 3 years so measures would need to be implemented by the end of 2028 to allow for a full year of data by the end of 2029 for compliance evaluation. This is not without its own risks, and there needs to be qualifying circumstances that warrant a delay. Ultimately, DOEE will decide the outcome of any delay requests.
  • You may also need to have a realistic discussion to assess if the property would be able to meet BEPS even with additional time. DC Council passed legislation in December 2024 which would allow buildings in financial distress and/or buildings that were unoccupied one of the two years prior to the Compliance Cycle to request a whole-cycle exemption rather than a delay. As of the publication of this piece, updated formal guidance has not been promulgated by DOEE. To orient yourself in the meantime, you can review the criteria for financial distress as defined under section 5.2.1 of the BEPS Guidebook. To determine if an exemption for low occupancy during one of the two years prior to the Compliance Cycle is applicable, you can review occupancy thresholds defined under Appendix B of the BEPS Guidebook. DOEE has not yet updated the Guidebook to reflect this legislation but it is likely the application process is similar to a request for a delay. Building owners would need to demonstrate good cause for exemption to the satisfaction of DOEE.

Notes on the data

Data used in this analysis was pulled from DC’s Energy Benchmarking OpenData website on February 24, 2025. Buildings were filtered based on:

  • If the reporting year of the data was 2023.
  • The EPA calculated  primary property type, including only offices and multifamily properties.
  • If they were listed as “In Compliance” with DOEE, which indicates DOEE has accepted the benchmarking submission.
  • If the property has an ENERGY STAR score, which filters out properties unable to obtain an ENERGY STAR score for whatever reason.
  • If the reported building gross floor area of the property was over 50,000 square feet, indicating the property would be subject to the current BEPS. (Tax record square footage data was considered but not used, as benchmarking submissions and corrections that impacted gross floor area would propagate as changes in reported building gross floor area.)
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