On February 5, 2025, our Energy and Sustainable Programs Practice Leaders took the ASHRAE National Capital Chapter audience on a deep dive into the evolving Building Energy Performance Standards (BEPS) landscape in the DMV region. We explored program cycles, dissected several ongoing case studies, addressed the biggest operational challenges for building owners, and laid out the critical next steps for owners and operators looking to stay ahead of the compliance curve.
Local BEPS Program Updates
DC BEPS Program Update:
Cycle 1 Recap: Covered the first compliance cycle’s requirements for benchmarking, energy targets and third-party verification.
Cycle 2 Adjustments: BEPS Cycle 2 has been pushed to 2028, with the annual benchmarking deadline shifting to May 1 and the next third-party verification due in 2027. A new trajectory pathway and whole-cycle exemptions for vacant or financially distressed buildings were introduced. Third-party verification will be required every 6 years in Cycle 2.
Maryland BEPS Program Update:
State of Maryland: We reviewed the finalized BEPS Technical Support Document (dated December 5, 2023) and its implications for statewide compliance pathways.
Montgomery County: Highlighted the regulations, the interactive performance map and the building lookup tool that empowers owners to track compliance readiness and provides transparency in the market.
Real-World Case Studies:
Government-Leased Office Complex: From initial audit through energy modeling and prescriptive pathway selection, we illustrated how targeted retro-commissioning and equipment upgrades can drive a building from below-average ENERGY STAR scores to BEPS compliance.
Confidential Campus Portfolio: Showing how systematic SCU replacements, VRF installations, VFDs and enhanced metering between 2020-2024 laid the groundwork for successful data verification – even when campus configurations introduced third-party benchmarking complexities.
Top Challenges for Area Stakeholders:
Owners: Balancing capital investment with sustainability goals; prioritizing projects under tight capital improvement budgets; working around tenant priorities.
Operators: Managing new technologies and varied occupancies while compiling supporting documentation, like BOMA calculations.
Design Teams: Integrating sustainable concepts; navigating value-engineering pressures; and continuing to push innovation.
Key Compliance Milestones:
The annual benchmarking report for 2024 performance was due May 1, 2025 for properties in the District of Columbia. The annual benchmarking report for 2024 performance is due on June 1, 2025 for properties in Montgomery County, Maryland.
Next Steps:
For D.C. buildings: Submissions under the Prescriptive Pathway – including Phase 2 requirements – should now be underway. Continue to keep ESPM profiles updated with monthly utility bills to track performance as improvements are implemented. For all other projects in the compliance cycle – tracking efficiency improvements and preparing the Completed Actions Report.
DC Building owners! Be aware that CY 2025 is the opportunity to implement building improvements and energy efficiency upgrades prior to the CY 2026 performance year. To satisfy the May 1, 2027 third-party verification deadline for 2026 calendar year operating data, you need a full year of post-improvement operations logged and verified.
For Montgomery County buildings: Obtain the building identifier. Connect with MDE through ENERGY STAR Portfolio Manager and share the property so that benchmarking reporting data can be transmitted directly through ESPM.
For Maryland BEPS program: Update as of 5/16/25 – House Bill 49 was passed on April 7, 2025 altering the requirements of the Maryland State BEPS program. Links here: 2025 Regular Session – House Bill 49 Enrolled and Legislation – HB0049
Don’t wait – start planning, modeling and implementing today to ensure your building not only meets today’s standards but thrives in tomorrow’s energy-efficient future.