DC BEPS + ENERGY BENCHMARKING
Expert Strategies for Building Performance
Annual benchmarking and independent third-party verification for every covered building, and the cycle work that determines whether a building owes an alternative compliance payment — and how much. A single PE and Certified Energy Manager, independent of owner and preparer.
BEPS numbers have to be verified by someone who isn’t you. That’s us.
Independent of owner and preparer — the verifier relationship DC’s rules require.
The credential behind audits, verification reports, and improvement planning.
Builds and QAs the Portfolio Manager records all three programs run on.
DC requires that the person who verifies your benchmarking data is neither the building owner nor the person who prepared it. The engineer who checks your Portfolio Manager record is the one who signs the verification — no hand-offs, no subcontracted signatures.
Annual reporting and cycle compliance are separate requirements. Most covered buildings owe both.
One building or ten, the sequence is identical: benchmark, verify, establish the building’s position against the cycle standard — and, where that position is over the standard, select a pathway and close the gap. Each service is priced on this page.
Annual Reporting
Due every year: a complete ENERGY STAR Portfolio Manager record submitted to DOEE by May 1, with third-party data verification by a professional who is neither the owner nor the preparer. Flat fees from $450. See fees →
Cycle Compliance
Due once per cycle: a building over the standard for its property type must select a compliance pathway and close the gap by cycle end, or pay an alternative compliance payment proportional to the progress made. How the standard works →
One number governs the cycle: the median for the property type.
At the start of each compliance cycle, DOEE sets a standard for every property type — the median performance of DC’s covered buildings. It functions as a limbo bar: a building using less energy than the median for its property type is under the standard and compliant, while a building using more is over it and owes improvement by the end of the cycle.
Benchmark annually, verify, and file the cycle report. That is the full obligation.
Select a pathway and close the gap by cycle end, or pay an alternative compliance payment scaled to the progress made.
Performance
Cut adjusted site EUI 20% by the end of the cycle. A shortfall is credited as the reduction achieved ÷ 20% — a 10% reduction halves the payment.
Standard Target
Reach the median itself. Open only to “high-performing” property types. Credit is given for the distance closed.
Prescriptive
Four phases: an ASHRAE Level 2 audit, a DOEE-approved action plan of point-valued measures, implementation, then verification. Credit = points earned ÷ points needed.
Also available: a negotiated Alternative Compliance Pathway (deep retrofits, new construction, change of property type, adjusted baseline), a Delay of Compliance for low-occupancy and hardship cases, and six-month extensions on interim deadlines. Pathway selection is due about a year into the cycle.
The Prescriptive pathway requires a Level 2 audit. The Performance pathway is nothing but the measures one finds.
Where the cycle assessment finds a building over the standard, the remedy is engineered rather than estimated — ASHRAE Level 1 through Level 3, PE/CEM-led, with the cost-benefit analysis required to fund it.
Which rules apply to your building?
Documentation built to survive review. A gross floor area certification, page by page.
Third-party verification is completed inside ENERGY STAR Portfolio Manager as a checklist rather than a standalone report, so there is no document to preview. The standard of proof is better shown by the PE-stamped gross floor area certification produced when a building’s square footage is in question. What follows is a simplified view of its structure, not the full document.
ENGINEERING
Certification Memorandum
Prepared for BEPS benchmarking & verification
Kevin Sheehan, PE, CEM — Professional Engineer of record
- Purpose and Regulatory Basis1
- Property Identification & MDE Building IDs2
- Methodology (field measurement · records · reconciliation)3
- Gross Floor Area Tabulation by Building5
- Use-type breakdown for area-weighted standards6
- Exclusions (parking · unconditioned · shafts)7
- Comparison to Assessor Records8
- Certification Statement & PE Seal9
- Appendix — Field Measurement Sketches & Photos10
This memorandum certifies the gross floor area of each covered building for benchmarking under a building energy performance standard. Gross floor area, excluding parking, determines coverage, the denominator of every intensity metric, and — for mixed-use buildings — the area-weighted standard applied.
| Source | Role in this certification |
|---|---|
| Field measurement | Exterior laser measurement of each building footprint; story counts verified on site |
| County records | Assessor GFA and permit history, used as a cross-check — not as the basis |
| Drawings | Where available, used to reconcile interior exclusions and unconditioned area |
Where sources disagree, the field measurement governs and the discrepancy is documented in Section 8.
| Bldg | Footprint (SF) | Stories | Gross (SF) | Excl. (SF) | Certified GFA |
|---|---|---|---|---|---|
| A | 9,420 | 3 | 28,260 | 1,180 | 27,080 |
| B | 9,420 | 3 | 28,260 | 1,180 | 27,080 |
| C | 12,610 | 3 | 37,830 | 1,640 | 36,190 |
| D | 12,610 | 3 | 37,830 | 1,640 | 36,190 |
| E | 7,880 | 2 | 15,760 | 620 | 15,140 |
| Clubhouse | 4,210 | 1 | 4,210 | 0 | 4,210 |
| Property | 152,150 | 6,260 | 145,890 |
Assessor record for this property: 158,400 SF. Certified GFA is 7.9% lower — the difference is unconditioned breezeways and mechanical rooms the assessor counts and the standard excludes. Every downstream number inherits the smaller, defensible figure.
I certify that the gross floor areas tabulated herein were determined by field measurement and records review under my direct supervision, using the methodology described in Section 3, and that they represent the gross floor area of each building for the purposes of the applicable building energy performance standard to the best of my professional knowledge.
ENGINEERING
Region BEPS
Playbook
The Capital Region playbook, aligned to the latest program guidance.
All three regional programs on one timeline: which one covers the building, the metric each grades on, the District’s proportional penalty math, Maryland’s five-year compliance period, Montgomery County’s baselines and deadlines, and the documentation each program requires.
- Three clocks — MD, MoCo and DC — on one timeline
- Who covers what, by gross floor area
- The penalty math: progress is the discount
- Verification and GFA certification, explained
Flat-rate fees, published.
Two services for every covered building — benchmarking and verification — and one for buildings over the bar. No pricing behind a sales call.
- The building’s position against the standard for its property type, quantified
- Alternative compliance payment exposure modeled at current and improved performance
- Pathway selection and the District Benchmark Results & Compliance Report, prepared and filed
- Improvement sequence, and the audit scope where measures are required
- Annual data collection and Portfolio Manager updates
- Third-party verification checklist by an independent PE/CEM
- DOEE submission by May 1
- Verifier independence documented — not owner, not preparer
- Meters, months, use details and floor area checked against source documents
- Corrections made in Portfolio Manager, documented
- Independent PE/CEM sign-off for submission
- Portfolio Manager setup or annual maintenance
- Utility data entry and QA
- DOEE submission by May 1
Flat-rate fees for standard commercial buildings with complete utility data access, matching the schedule published for our Maryland practice. The Cycle Readiness Assessment bundles with verification and scales with building complexity. Improvement measures are scoped separately once verified numbers are in hand — see energy assessments for ASHRAE Level 1 through Level 3 audits, the engineering work that closes a gap to the standard.
Estimate alternative compliance payment exposure
Buildings in Maryland or Montgomery County?
Same engineer, same verification file — Maryland’s statewide BEPS and the county program run on the same ENERGY STAR record, and we serve both from the same practice.
Washington, DC BEPS FAQ
Does DC BEPS apply to my building?
Cycle 1 covers private buildings over 50,000 SF and runs through December 31, 2026. Cycle 2 begins January 1, 2027 and expands coverage to buildings over 25,000 SF; 10,000 SF follows in 2033. DOEE publishes the covered building list — but coverage is defined by the building, not by whether you noticed the letter.
What is “the bar”?
DOEE’s standard for your property type — the median ENERGY STAR score (or median site EUI for types without a score) among DC’s covered buildings, set at the start of each cycle. Better than the median and your obligation is benchmarking and verification. Worse, and you owe improvement through a pathway by the end of the cycle.
What does “third-party verification” actually involve?
It is a checklist inside ENERGY STAR Portfolio Manager, completed by a qualified professional who is neither the building owner nor the person who prepared the benchmarking. The verifier checks meters, months of data, use details, and floor area against source documents and corrects what doesn’t hold up.
What is an ACP?
Two things, confusingly. The Alternative Compliance Payment is the penalty for missing your pathway: up to $10 per square foot, capped at $7.5 million per building, reduced proportionally by your progress (20 DCMR 3521) — reach 80% of the way and you pay roughly 20%. The Alternative Compliance Pathway is a negotiated custom route to compliance for special cases such as deep retrofits or a change of property type.
What are the options for a building over the standard?
Three principal pathways: Performance (a 20% reduction in adjusted site EUI by cycle end), Standard Target (reaching the median, available to high-performing property types), or Prescriptive (an ASHRAE Level 2 audit, a DOEE-approved action plan, implementation, then verification). Delays of Compliance are available for low-occupancy and hardship cases. Pathway selection is due approximately one year into the cycle, and each pathway earns proportional credit toward the payment if the target is not fully met.
When is the Cycle 1 report due?
The third-party-verified District Benchmark Results and Compliance Report for calendar year 2026 is due May 3, 2027. Annual benchmarking is due May 1 each year.
How much does it cost?
Annual reporting is flat-rate per building: benchmarking with third-party verification from $795, verification alone from $550, and benchmarking alone in non-verification years from $450. Cycle compliance is priced separately — the Cycle Readiness Assessment, covering the building’s position against the standard, pathway selection, alternative compliance payment exposure, and the cycle filings, starts at $950 and bundles with verification. Portfolio pricing is available.
When should I start?
Now. Cycle 1 performance is graded on data already in your record, the verified report is due May 3, 2027, and Cycle 2 opens January 1, 2027 with a new set of buildings. A clean, verified record at the end of Cycle 1 is the baseline that makes Cycle 2 a plan rather than a scramble.
YOUR ROADMAP TO COMPLIANCE
Get in Touch
Whether you know your needs or have questions on the requirements, we are here to help.
Fill out the form or get in touch below:
Email kevin@sheehan-eng.com
Call (773) 312-2898
