City of St. Louis
Benchmarking and BEPS Compliance
Benchmarking Requirements – Building Energy Awareness Ordinance (2017) BEPS- Building Energy Performance Standards Ordinance (2020)
News and Upcoming Deadlines
2024 Benchmarking Due MAY 1st 2025
EXTENDED! 2024 Data Verification Due JULY 31st 2025
What are Benchmarking and BEPS?
St. Louis requires many buildings over 50,000 square feet to report energy use and improve performance over time. These laws help lower utility costs, protect occupant health, and position your building for long-term success.
The City of St. Louis has two building energy laws:
Building Energy Awareness (Benchmarking) Ordinance (2017): Requires large buildings to report energy and water use annually.
Building Energy Performance Standards (BEPS) Ordinance (2020): Requires those same buildings to meet energy efficiency targets every 5 years (7 years for houses of worship and qualified affordable housing).
BEPS helps building owners:
> Reduce utility bills
> Increase property value
> Improve tenant comfort and health
> Future-proof buildings against energy price volatility
Buildings not in compliance with the ordinance will not be eligible for issuance of new residential or commercial occupancy permits. Fines also apply.
Benchmarking and BEPS Frequently Asked Questions (FAQ)
Annual Reporting Requirements
Benchmarking- All covered properties must report their energy and water use by May 1 each year using ENERGY STAR Portfolio Manager, a free tool used by the real estate industry nationwide.
BEPS- Reporting is done through benchmarking compliance. It is that simple.
Data Verification
Once per compliance cycle, you must have your benchmarking data verified by a qualified third-party.
Verification is due in the second-to-last year of each cycle (e.g., for 2025 compliance, data from 2024 must be verified).
Verification consists of:
Downloading a Data Verification Checklist from Portfolio Manager
Having a qualified verifier complete and sign it
Entering the information in ENERGY STAR Portfolio Manager
- Qualified verifiers include professionals with certifications like CEM, PE, BEAP, and others. See full list
Understanding and Improving Building Performance
Compliance is based on your Energy Use Intensity (EUI) – a measure of how efficiently your building uses energy.
EUI = Energy Use / Building Size (reported in kBtu/ft²/year)
Targets are based on how similar buildings perform locally
Lower EUI = better performance
Use these steps to improve:
Review your building’s Portfolio Manager data
Get an energy audit or start with a free Treasure Hunt
Identify and prioritize Energy Conservation Measures (ECMs)
Create an improvement plan and engage tenants
Meeting Your Target (Compliance Paths)
Buildings can meet their targets in several ways. Four approved paths exist to achieve compliance.
Path 1: Performance — Hit your Target by the deadline.
Path 2: Early Adopter — Exceed your Target by 20% or more and skip the next cycle.
Path 3: Narrow the Gap — Reduce EUI halfway between your starting point and the Target (CYCLES 1&2 ONLY).
Path 4: Custom Alternative Compliance Path (CACP) — Apply for a flexible plan if you’re unable to meet other paths.
Use the Energy Efficiency Checklist and BE-Ex STL resources to get started.
Exemptions, Extensions, & Appeals
Some buildings may qualify for deadline extensions or exemptions due to construction, hardship, or special circumstances.
Exemptions may apply for new construction, telecom providers, manufacturing, or extreme hardship.
Extensions may be granted for reporting issues, lack of verifier availability, etc.
Appeals are available if your exemption or compliance path is denied.
Understanding Targets and Timelines
Targets are set based on how similar buildings perform. Most buildings are in 5-year cycles.
Compliance cycles: Most buildings follow a 5-year cycle; affordable housing and houses of worship follow 7-year cycles.
Baseline year: Typically 2018, or your first verified year
Your building’s target is set so that the worst-performing 65% of buildings must improve
Property Types & Their Assigned Targets
Your compliance target depends on your building’s property type.
Select your building’s property type in Portfolio Manager
Targets are based on the average EUI for each property type
Check your assigned target in the full property type list
