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Common Errors in DC Energy Benchmarking

Avoid mistakes in measuring your building's energy performance.

The owners of the District’s large buildings (≥50,000 sq. ft. for privately owned buildings and ≥10,000 sq. ft. for District-owned buildings) have been required to benchmark their energy and water performance for over a decade, and private buildings ≥25,000 sq. ft. have been required to benchmark since January 2021. Private buildings ≥10,000 sq. ft. are required to start benchmarking in 2024. The District of Columbia enacted this requirement in order to increase the energy performance data available to owners and to the market in order to drive building efficiency improvements.

Buildings are responsible for more than 70 percent of the District’s greenhouse gas emissions, and energy benchmarking is critical to improving building performance and helping make the District the healthiest, greenest, and most livable city in the nation.

Why benchmarking matters to District building decision makers

Energy benchmarking is a valuable process for building owners and occupants to better understand how their buildings are using resources such as energy and water. It can be used to compare performance year-over-year, compare against peer buildings, and better identify when a property is underperforming.

Additionally, the District enacted building energy performance standards (BEPS), which use energy benchmarking data as a baseline and establish minimum energy performance thresholds. Benchmarking can help identify the level of action potentially required under BEPS.

The benefits of benchmarking, however, require starting with accurate data. It’s important to understand that not all data is good data. This is one reason the District now requires third-party benchmarking data verification every three years to ensure quality data. For annual benchmarking, this document provides critical insight on how to identify and avoid common errors in energy benchmarking to ensure that your energy benchmarking reporting is accurate and a reliable tool to use to track performance and compliance with BEPS.

Common errors in energy benchmarking

For an accurate picture of how your building operates, it is essential to verify building characteristics and utility data. Some energy data errors are easier to identify than others. Consistent reporting is important because it helps to uncover anomalies. Whether data is reported by an in-house staff member or with the support of a benchmarking vendor, it’s important to verify the following inputs:

Energy consumption data

This refers to annual utility data, including electricity, natural gas, and water use information.

Meter errors

Common error:

  • Not reporting data from all of the energy meters at a property.

How to avoid it:

  • Pepco and Washington Gas will provide access to energy data, as long as the proper meter numbers are provided. Ensure that the utility meter numbers are correct. With the use of Pepco’s Energy Usage Data System (EUDS) and Washington Gas’ Utilli tools, you can access historical utility data and set up automatic uploads of monthly data moving forward. In order for Pepco and Washington Gas to provide aggregated tenant data, there must be at least five different meters in order to protect tenant privacy.
  • If fuel is delivered to your property, rather than being metered, carefully review delivery documentation to ensure that usage is reported in the correct units and that it matches what is entered in ENERGY STAR Portfolio Manager, the District’s required reporting platform.

Not having all of the data

Common error:

Not including 12 full calendar months of data (ENERGY STAR Portfolio Manager requires data to cover the full period from January 1 through December 31).

How to avoid it:

  • Ensure that utility data is complete, with usage reported from January 1 through December 31.
Data InputWhat to CheckGuidance
Guidance energy consumption DataEnergy consumption data Ensure all meters are being reported and correctly.Review the number of meters reported with tenant lists and building documentation.
Ensure that you have uploaded a full year’s worth of utility dataENERGY STAR Portfolio Manager requires 12 full months of calendar data from January 1 to December 31 to generate accurate metrics. This means that, depending on your utility billing cycle, additional data may need to be included. Ensure that energy data you are providing covers the full calendar year.

Building size and use-type information

This includes gross floor area as well as the square footage for each individual use type.

The wrong total square footage

Common error:

  • Not reporting the total gross floor area, which includes all interior spaces, including, but not limited to, basements, back of house/mechanical spaces, and elevator shafts. Portfolio Manager provides specific guidance for entering parking areas.

How to avoid it:

  • Check your gross square footage against existing datasets and resources. The best source(s) for accurate square footage are as-built construction drawings or field-verified surveys. If those are not available, assumptions can be compared to estimates from the Office of Tax Revenue.

Mislabeled space use types

Common error:

  • Missing or misrepresented space use types, such as categorizing a building as 100% commercial office when there’s actually a retail space on the ground floor.

How to avoid it:

  • ENERGY STAR Portfolio Manager provides specific guidance for which spaces to include in the Gross Floor Area, as well as definitions for each property type in their Glossary. It’s important to verify that all interior spaces, such as mechanical spaces and basements, are included and that the Gross Floor Area metric is accurate.
  • ENERGY STAR Portfolio Manager provides specific guidance for reporting secondary uses such as parking, ground-floor retail, and data centers. Review all property use types along with their individual square footages to ensure accuracy. Additionally, follow Portfolio Manager guidance about when to create separate use types.
Data InputWhat to CheckGuidance
Gross floor areaAccuracy or consistency with existing documentationInvestigate if square footage is more than 30% more or less than the value listed by the Office of Tax Revenue or other sources, such as CoStar. These differences tend to result from not accounting for basement areas, or out of date information after recent renovations.
Use typeAccurate areas for secondary property use typesAccurate areas for secondary property use types ENERGY STAR Portfolio Manager provides specific guidance for reporting secondary uses like parking, ground-floor retail, and data centers. Review all property use types along with their individual square footages to ensure accuracy.

Property use details (business activity)

This includes information such as occupancy and operating hours.


Common error:

  • Occupancy is not accurately reported by not considering times of high vacancy or high occupancy.

How to avoid it:

  • Portions of the year with high vacancy should be factored into the occupancy percentage, and highly dense buildings with full occupancy throughout the year should be reported with 100% occupancy.

For commercial offices, office hours, workers, and computers

Common error:

  • Misrepresenting the hours of operation, number of workers on main shift, and the number of computers to not accurately reflect the operational patterns of each individual tenant.

How to avoid it:

  • Verify the operating hours, reported number of workers, and the number of computers for each individual tenant. For commercial offices, the ENERGY STAR Score is greatly affected by these property use details.

For multifamily buildings, bedroom counts

Common error:

  • Misrepresenting the number of bedrooms

How to avoid it:

  • Accurately report the number of bedrooms, which should be a larger value than the number of units if there are two- and three-bedroom units (or larger) present throughout the building. Verify this information from rent rolls or other similar documentation. Studio apartments should be considered one-bedroom units.
  • Review as-built building drawings for a true representation of bedroom counts.

For hotels, number of guest rooms, workers, commercial appliances

Common error:

  • Misrepresenting the number of guest rooms, the number of workers, the number of commercial refrigeration and/or freezer units, or the presence of a large kitchen.

How to avoid it:

  • Verify guest rooms by looking at building plans or online guest room tracking systems. Confirm number of workers by reviewing payroll information. Count all commercial refrigeration units; include ice machines that may be located on every floor.
Data InputWhat to CheckGuidance
Property use detailsOccupancy percentageTalk to the tenants to understand periods of high vacancy and high occupancy.
For commercial offices: hours of operation, number of workers on main shift, number of computersVerify these details with each individual tenant, especially if certain tenants have extremely high density.
For multifamily buildings: number of bedroomsVerify number of bedrooms with rent roll information. Number of bedrooms generally will be a larger number than the number of residential units. Remember to classify studio apartments as one-bedroom units.
For hotels: number of guest rooms, number of workers, number of commercial refrigeration/freezer units or presence of a large kitchenVerify number of guest rooms. Verify number of workers with payroll information. Include all commercial refrigeration units, including ice machines.

Use the following table to see if the results of the benchmarking for your property falls within typical, normal ranges. There may be valid reasons they do not, but this is a starting point for typical buildings in the District.

Data OutputWhat to CheckGuidance
ENERGY STAR scoreIf your ENERGY STAR score is extremely low or highInvestigate if your ENERGY STAR Score is below 10 (unless the building is extremely energy intensive) or above 95 (unless the building is largely unoccupied or unconditioned).
If you did not receive an ENERGY STAR scoreReview your data to ensure there are no error alerts listed in ENERGY STAR Portfolio Manager. The platform also has a button that says, “Why no score?” which will outline why a score was not given. Additionally, some property types are not eligible to receive a score.
Site energy use intensity (EUI)If your site EUI is extremely low or highInvestigate if your site EUI falls outside of the following, typical ranges: Commercial office: 20 to 200 kBtu/sq. ft.; Multifamily housing: 20 to 200 kBtu/sq. ft; K-12 Schools: 20 to 150 kBtu/sq. ft; Hotel, dormitory, lodging, other: 20 to 500 kBtu/sq. ft.

Tools that can help

Annual energy benchmarking data is reported to the Department of Energy & Environment (DOEE) using a platform called ENERGY STAR Portfolio Manager. This platform includes guidance on what types of information are required, per building type, to accurately benchmark a building. DOEE has an online Benchmarking Help Center with links to tools and videos to provide support.

Additionally, DOEE created a Data Collection Worksheet, a checklist and guidance document for the collection of energy benchmarking data in the District. Once data is submitted to the District for annual compliance, DOEE will send an email within a few days to confirm whether the submission is accepted or if errors must be corrected before the property is considered compliant. Any updates or corrections should be made directly in ENERGY STAR Portfolio Manager. You may reach out to DOEE  to confirm that corrections have been received.

Every three years, building owners or their designees are required to perform third-party verifications of their benchmarking data and submit the verification with their benchmarking reports. The first deadline for third-party verification is on July 1, 2024 (note that DC Council passed emergency legislation which extended the deadline for this cycle only from April 1, 2024 to July 1, 2024). The Hub has created a sample scope of work (SOW) to help with hiring an approved third-party verifier (which is different from a benchmarking vendor). The Hub also created a companion how-to-guide to help use the SOW and make it easier to navigate the process.

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