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Overview
Benchmarking helps building owners, investors, and tenants track and compare energy and cost performance year-over-year across similar buildings. Through this process, they can identify energy saving opportunities to reduce operating costs and prioritize investments. Benchmarking and disclosure of results to Washington, DC’s Department of Energy and Environment (DOEE) is a precursor to compliance with DC’s Building Energy Performance Standards (BEPS).
2026 is the last year of the DC BEPS Compliance Cycle 1 (Cycle 1). 2026 is also the evaluation year for Cycle 1, which means that energy being used in buildings subject to BEPS in 2026 will be used to determine compliance with BEPS. In anticipation of this, building owners and managers have been implementing performance improvements at their buildings during BEPS Cycle 1. The DC building industry is curious as to how buildings will succeed with these requirements.
While we do not have public 2025 or 2026 benchmarking data, we do have public 2024 benchmarking data. The Apartment and Office Building Association of Metropolitan Washington (AOBA) and the Building Innovation Hub (Hub) are interested in this data to help advise our stakeholders and members on how DC building stock are doing with respect to this current BEPS, similar to the 2023 benchmarking data series published last year. This 2024 benchmarking data series expands the breadth of last year’s series and will seek to provide insight a few questions:
- What additional BEPS relief options might be introduced later this year or early next year for buildings struggling to their BEPS requirements.
- What are the current median ENERGY STAR scores for major building types like offices, multifamily buildings, hotels, and worship facilities?
- How are buildings that did not meet the BEPS making progress on the primary compliance pathways—that is, the Performance and Standard Target Pathways?
- What additional details and insights might we be able to glean from benchmarking data for offices, multifamily, hotels, and worship facilities?
- What should buildings under 50,000 square feet be thinking about in the next year?
The data used in this analysis was based on publicly available disclosures with supplemental information provided by DOEE to enable the series’ methodology to be based on the evaluation metrics used by DOEE.
All observations in this series apply generally to the building typologies included in the dataset. Specific buildings will have their own unique challenges and may have different experiences.
Analysis Series
Our 2026 blog series explains local benchmarking trends based on analysis of 2024 data, which is the most recent complete and accurate dataset.
- Part 1: Building Performance Over Time: A Review of ENERGY STAR Medians
- Part 2: A Review of Buildings on the Performance Pathway
- Part 3: A Review of Buildings on the Standard Target Pathway
Stay tuned for further analysis of performance across different building typologies.
Upcoming DC BEPS Relief Options
As the District approaches the end of BEPS Cycle 1, DOEE has been considering updated guidance to help buildings meet the technical requirements. While this series will look at 2024 benchmarking data, it is also important to understand what changes may be coming and what their impact may be. These updates are a result of collaboration between DOEE and multiple building industry partners such as the BEPS Task Force and AOBA. As of today, this series cannot speak to the specific details of each of these relief options since these details haven’t been finalized yet. Additional resources will follow once updated guidance is finalized, so please stay tuned for updates.
| Financial Distress Exemptions | Per the BEPS Amendment Act of 2024, DOEE is required to develop exemptions for financial distress, with the intent that buildings which meet criteria set by DOEE can apply for a whole-cycle exemption. DOEE included draft criteria in their proposed BEPS Guidebook Revision v1.2 updates which were open for public comment earlier this year. Additional information will be forthcoming in the updated version of the BEPS Guidebook once it is issued by DOEE. |
| Alternative Compliance Agreements | Formally known as the Alternative Agreement for Building Improvements in the proposed BEPS Guidebook v1.2, this is an alternative enforcement mechanism. If a building does not meet the BEPS, this mechanism would enable DOEE and the building owner to enter into an agreement by which the building owner would invest all or part of an alternative compliance payment that DOEE would levy for a property which is has not met its BEPS requirements at the end of this Cycle into future building improvements in lieu of paying an alternative compliance payment to DOEE. Thus, this mechanism would have buildings invest into improvements in their buildings instead of paying the District if they do not meet their BEPS. Specifics of these agreements are not spelled out in the proposed version of the BEPS Guidebook. Similar to financial distress exemptions, public input was provided and additional information will be forthcoming in the updated version of the BEPS Guidebook. |
| Good Faith Efforts | This is the least defined of the three relief options, but the concept is explained by the name: credit for this BEPS Cycle for specific actions (or efforts) taken during this BEPS Cycle for properties that were unable to meet the BEPS. A subcommittee of the BEPS Task Force was formed to develop possible formulations of good faith efforts; the subcommittee has produced recommendations for the BEPS Task Force to review. These recommendations were presented on April 21 and are currently with the BEPS Task Force for consideration. The BEPS Task Force would then compile recommendations for DOEE, who could then incorporate either some or all of their recommendations into a Guidebook update later in 2026. |