5 Things Learned During Year 1 of DC BEPS

By Laura Morder, PE, LEED Green Associate

Local jurisdictions, like the District of Columbia (DC) and Montgomery County, Maryland, require building energy benchmarking requirements as a part of their energy performance programs. If you’re a building owner or operator in DC and are feeling overwhelmed in the face of these new requirements, GHT has prepared the following observations after helping building owners, just like you, to navigate these new requirements.  If you’re a building owner or operator in Montgomery County, MD, these lessons can help you prepare for your upcoming BEPS process.

As the first year of compliance cycle 1 for the Building Energy Performance Standards (BEPS) program in DC ends, the primary efforts of the District’s Department of Energy and the Environment (DOEE) has been to educate DC building owners and engineers on the program’s new requirements which were introduced in 2019 as required by law in the 2018 Clean Energy DC Omnibus Amendment Act. The DC BEPS program is approaching its first mandatory compliance deadline on April 1, 2023, when building owners are expected to select a compliance pathway. This pathway selection will lay the groundwork for energy efficiency projects throughout DC.

GHT has supported more than 25 projects through the initial BEPS process and is providing compliance services for many building owners throughout DC. As GHT’s lead engineer guiding clients through the BEPS process, I’m sharing the lessons we’ve learned from our first year of supporting owner compliance in the program:


  1. ASHRAE Energy Audits are key to understanding your options for pathway selection.

ASHRAE Energy Audits based on ASHRAE’s Procedures for Commercial Building Energy Audits provide accepted levels of building operations review. Audits consist of reviewing the existing building conditions, equipment operations, and the building’s utility consumption to provide Energy Conservation Measures (ECMs).  These ECMs can range from simple no-cost operational changes to capital-intensive building modifications. Insight Construct is able to provide rough order of magnitude (ROM) pricing to support the development of cost proposals for ECMs and capital outlay planning.

An audit is a tool used to select a mix of ECMs that result in energy and cost savings that match the owner’s needs. There are three levels of audits ranging from simple to complex.  Here’s what you should know about each Energy Audit:

  1. ASHRAE Level I Energy Audit: This Audit includes a walk-through survey. Building energy costs and efficiency are assessed by an engineer through an examination of energy bills. Low-cost and no-cost energy conservation measures are identified in a report to the owner.
  2. ASHRAE Level II Energy Audit: This involves a more detailed building survey to include consumption and peak demand analysis. Energy end uses are broken down by use type and user within the building. Level II Audits identify and provide cost and savings analysis of all practical energy efficiency measures, including proposed changes to O&M procedures, which meet the owner’s given constraints and economic criteria. The goal at this level is to equip the owner with detailed information to act upon recommendations.
  3. ASHRAE Level III Audit: In addition to the items from the Level II Audit, Level III includes a detailed analysis of cost-intensive modifications. Following the Level II Audit, GHT will focus on higher dollar improvements and provide rigorous engineering and economic analysis (to include detailed field data, energy performance modeling/simulation, and vendor pricing). A Level III Audit equips the owner with detailed cost-savings calculations sufficient to engage in major capital investment decisions.


  1. 3rd party verification of ENERGY STAR Portfolio data is essential if you’re on the threshold for compliance.

By having GHT examine and verify your building’s ENERGY STAR Portfolio Manager data, an owner can potentially improve a building’s score when the score is on the threshold for compliance. A review by our team may uncover and address data entry errors between benchmarking data and actual utility usage and ensure that the building’s physical characteristics are appropriately classified.  Improperly entered property parameters such as space types, hours of operation, occupancy, and the number of computer workstations can drastically alter the building’s reported performance.

GHT reviews of the property data include:

  1. Reviewing ENERGY STAR Portfolio Manager Data
  2. Reviewing monthly utility bills
  3. Confirming that BOMA calculations or drawings match the physical building
  4. Reviewing building occupancy rates
  5. Conducting a site walkthrough to confirm building usage


  1. A keen understanding of your building’s operational schedule is critical to success.

For our BEPS projects, we understand that a successful outcome begins with in-depth interviews with the building facilities team. During this interview, a GHT engineer will educate your staff about the energy audit process while gaining insight into your building’s actual operations vs. original design intent.

Following this interview, a walkthrough with the facilities team can identify discrepancies between the original design intent, perceived operations, and actual field conditions. During this walkthrough, I, or another GHT team member will review building control systems’ configuration alongside on-site equipment to verify all systems are correctly identified in system graphics, and that control sequences and set points, are configured to match design intent.

After the walkthrough, plant operations will also be compared to utility bills to identify discrepancies or opportunities for additional energy savings. Our team’s knowledge of various mechanical system configurations and experience with commissioning, controls systems and building operations allows us to discover unusual operating patterns which may contribute to excessive energy consumption. Our expertise in energy modeling provides a reliable avenue for evaluating alternative system configurations or modes of operation, which can save operating and maintenance costs over time.


  1. Owners who are new to the process may require additional assistance gathering data for their first compliance milestone.

If this is your first time complying with benchmarking requirements, don’t worry – our team is here to help! We will ask you to provide the following information:

  1. Size of the property (SF)
  2. Year built
  3. General age and condition of the property and its’ mechanical systems
  4. Access to utility bills from 2018-2021
  5. Access to the property’s ENERGY STAR portfolio account
  6. Access to existing MEP drawings including base building, tenant plans, controls schematics, and sequences of operation
  7. Plans for recent or planned capital improvement projects


You may also need to provide access to the site and back-of-house spaces for a walkthrough with your GHT engineer and your facilities team.

Lastly, our team will consult with you on:

  1. Your Goals – are there any specific ECMs you want to be reviewed or prioritized?
  2. Your Budget – are there known limits or opportunities for any ECMs reviewed as part of the audit process?
  3. Your Constraints – are there any restrictions that would prohibit certain ECMs (i.e., historical preservation requirements which dictate building modifications)?

This way our recommendations on your compliance path and potential methods of reducing your building’s energy consumption are tailored to suit your needs


  1. Prepare for the energy modeling process.

The GHT team employs a group of experienced energy modelers who also serve as engineers in our Operations and Energy Services (OES) studio. This means your project benefits from their well-rounded mechanical design expertise and understanding of the function of building systems.  Energy modeling can be challenging, especially for certain building geometries or for large-scale properties with a campus of buildings. We recommend engaging with our team early to include adequate time to develop and normalize the energy model. This time will ensure the baseline model is an accurate representation of the existing conditions and allow for a reasonable comparison to proposed ECMs. The study phase for a Level II or Level III Audit may include several iterations of ECM review with an owner; equipment selections and pricing with manufacturer representatives; and payback analyses, making it important to engage with our team early.


As owners plan for their first round of compliance, here are important schedule milestones to consider:

  1. Audits can take 4-8 weeks or more, depending on the level of audit selected.
  2. Annual DC Benchmarking is due April 1, 2023.
  3. The deadline to submit a compliance pathway selection for BEPS Cycle 1 is April 1, 2023.


If you have questions or want additional information from our team, reach out to us at OES@ghtltd.com. In addition, if you’re ready to receive a proposal, give us your project parameters, and you’ll have the support you need to achieve compliance in 2023!


As a Mechanical Design Engineer for GHT’s Operations & Energy Services (OES) Studio, Laura Morder, PE, LEED Green Associate provides project management services and detailed mechanical engineering design solutions for commercial building projects in the Washington, DC Metropolitan area. With more than a decade of experience, Laura’s ingenuity has shaped countless commercial interior fitouts, central plant designs and building modernizations. Laura is also co-founder of Women in ASHRAE for the National Capital Chapter and an advocate for future generations of female engineers in the industry. She can be reached at lmorder@ghtltd.com