Assisting Benchmarking Policy Development

The Hub Provides Guidance for Implementing Benchmarking


CBEI and its partners, the Institute for Market Transformation (IMT) and the National Resource Defense Council, are teaming up to provide technical and educational resources for cities throughout the United States that are looking to implement building energy benchmarking  legislation. CBEI’s May 2013 convening on the topic of Urban Energy and Benchmarking was proof that cities across the United States are concerned about the energy use of their building stock and see benchmarking as a necessary step in increasing buildings’ energy efficiency.

The convening brought together representatives from three cities that have already passed benchmarking legislation (Seattle; Washington, D.C.; and Boston) with government officials from over twenty cities that are considering benchmarking legislation and are eager to learn from others’ experiences.
In addition to the public sector representatives, participants included people in research fields. Together, the speakers offered practical, research-driven insights into the nuts and bolts of passing and implementing benchmarking legislation. They included

  • Rebecca Baker, Energy Benchmarking Program Manager, Office of Sustainability & Environment, Seattle;
  • Carl Spector, Director, Air Pollution Control Commission, Boston;
  • David Good, Program Analyst, Washington, D.C.; and
  • David Hsu, Assistant Professor of City & Regional Planning, University of Pennsylvania.

Laurie Actman, former Deputy Director of CBEI, moderated the discussion.

The public sector speakers suggested a set of “best practices” based on their experiences. These testimonies complemented IMT’s 2011 report on this topic, which categorized recommended best practices into six main topics: 1) Outreach, Education, and Training; 2) Guidance for Complying with Ordinance; 3) Managing Compliance; 4) Data Quality Assurance; 5) Access to Utility Data; and 6) Disclosure of Collected Data. IMT has worked for years in an advisory role to help cities pass energy benchmarking legislation [1].

Outreach, Education, and Training

Representatives from Washington, D.C., Boston, and Seattle all emphasized the importance of outreach. All three of these cities essentially lead by example: each disclosed the energy use of its municipal properties before requiring benchmarking for privately owned buildings. All representatives from these cities agreed that reaching out to building and real estate groups was very important, although they did acknowledge that some faction will always remain unsupportive of the legislation. David Hsu, who performed detailed analysis on New York City’s 2011 benchmarking data, expanded on this testimony, noting that New York City approached building owners directly in the early days of forming its legislation, which was pivotal in passing that city’s legislation.

Guidance for Complying with Ordinance

Seattle rolled out its legislation in waves beginning with commercial buildings larger than 50,000 square feet and dropping to buildings of 20,000 square feet over four years. Rebecca Baker reported that staggering implementation in this way allowed the City to work through the details of writing guidance for compliance (the guidelines that outline what kinds of data must be submitted and how to submit that data). David Hsu emphasized the importance of clearly communicating this information, pointing to Seattle’s website and NYC’s call center as prime examples of how this information can be communicated.

Managing Compliance

Rebecca Baker explained that, as one of the first cities to pass benchmarking legislation, Seattle had to learn a lot throughout their process. One important lesson related to managing compliance with the new law: when stakeholders said that they needed a longer time to comply with the new regulations than the ordinance allowed, the City revised the ordinance to accommodate them. Baker said that acknowledging that the law was not perfect initially was important to its success.

Data Quality Assurance

David Hsu shared an important lesson learned in New York City. He explained that the benchmarking data revealed that the majority of building benchmarking was being filed by only a handful of firms. The City used this knowledge to target its training and education to those firms in an effort to efficiently improve data quality.

Access to Utility Data

David Good, from Washington, D.C., brought up the importance of obtaining data in a form that is easy to transfer into EPA’s Portfolio Manager. In the District’s case, they worked with the local utility, PEPCO, which agreed to provide building owners with aggregated whole-building energy use information. Typically, a utility only provides energy use information upon request for a single customer. However,  one building may have many utility customers, which makes the process of collecting whole-building data very arduous. Philadelphia has been working with PECO [RD report] , the local electric utility, to set up systematized data access for building owners to comply with the new benchmarking legislation.

Further, IMT, in a 2013 report commissioned by CBEI, has established guidelines to aid utilities in establishing data access for building benchmarking programs [2].

Disclosure of Collected Data

Many, though not all, benchmarking laws require that the data collected be publicly disclosed. IMT strongly encourages that public disclosure be written into the laws from the start, as this provision makes the information much more broadly useful. Seattle does not require public disclosure; however, the legislation does require energy data to be disclosed during real estate transactions. New York City, on the other hand, requires disclosure of annual benchmarking data; it released its first year of benchmarking data in a 2012 report [3].

Next Steps

The phrase, “you can’t manage what you don’t measure” inevitably gets used in conversations about benchmarking and really expresses the importance of these laws. CBEI and its partners will continue to engage stakeholders on a national level to guide them in setting up programs for the measurement of and, ultimately, management of the energy use in the commercial building stock.


[1] Burr, A. C., Keicher, C., & Leipziger, D. (2011). Building Energy Transparency: A Framework for Implementing U.S. Commercial Energy Rating and Disclosure Policy. Institute for Market Transformation, from

[2] Krukowski, A., & Majersik, C. (2013). Utilities’ Guide to Data Access for Building Benchmarking. Institute for Market Transformation, from {filedir_8}IMT_Report_-_Utilities_Guide_-_March_2013.pdf

[3] Kerr, L., Beber, H., & Hope, D. (2012). PlaNYC: New York City Local Law 84 Benchmarking Report, from