Building Energy Benchmarking



In 2022 the benchmarking law was amended by Bill 16-21, Building Energy Use Benchmarking and Performance Standards. The amendments drop the benchmarking square footage threshold to 25,000 gross square feet and add multifamily and previously-exempted building types like warehouses and self-storage facilities. Group 3 commercial buildings 25k – 50k GSF + previously exempted commercial buildings of all sizes and Group 4 multifamily properties 250k+ GSF must begin reporting calendar year 2022 data by June 1, 2023. Read about the changes to the benchmarking law here: Covered Buildings Guide. View the Covered Buildings Inventory for a list of covered buildings and their groups.

Energy Benchmarking is the process of tracking a building's annual energy use and using a standard metric to compare the building's performance against past performance and to its peers nationwide. Benchmarking improves our understanding of energy consumption patterns; helps identify energy saving opportunities within a portfolio of buildings; and manages business bottom line through consistent data collection and tracking. Please review the Benchmarking Overview and Benchmarking Checklist to get started.

Montgomery County's Energy Benchmarking Law requires building owners to:

  • Track the energy use of buildings 25,000 gross square feet and greater in the county in ENERGY STAR Portfolio Manager,
  • Have data verified by a Recognized Data Verifier the first year and every three years thereafter, and
  • Report data to the County annually for public disclosure.
  • Meet long-term site energy use intensity performance standards. For more information on compliance with Building Energy Performance Standards, visit DEP’s BEPS website.

The submission deadline for all County, Group 1, Group 2, Group 3, and Group 4 covered buildings (commercial buildings 25,000 sq. ft. and greater and multifamily buildings 250,000 sq. ft and greater) is Thursday, June 1, 2023.  

CY 2022 building energy benchmarking data can be reported to DEP using this link:

**Calendar Year 2022 Reporting Link **

To report data for previous years, please contact DEP for the reporting link. Check your building's CY 2022 reporting status on the Benchmarking Compliance Status Report.

The Department of Environmental Protection (DEP) is responsible for the implementation of this law. Email us or call 240-777-7707.


Table of Contents

Information and resources are provided below to aid compliance. To download an overview of the program and reporting:

  • Official Guide:  DEP has put together a comprehensive, set-by-step guide for complying with the Building Energy Benchmarking Law in Montgomery County, which includes background information, clarifying instructions, and details about reporting benchmarking data to the County. Download the Official Guide for Building Energy Benchmarking (PDF, 1.56MB) in Montgomery County 
  • Benchmarking How-To Guide: Guide with screenshots of how to create a Portfolio Manager account, create a property, create meters, and enter energy data. Download the How-To Guide (PDF, 1.39MB).

Scroll down or jump to a section using these links:


Buildings Covered by the Benchmarking Law


Building Coverage and Deadlines

Public and privately-owned buildings 25,000 gross square feet and larger are covered by the energy benchmarking requirement and must report energy data to DEP by June 1 each year. 

Beginning with calendar year 2022 reporting, for benchmarking purposes a “building” is a single structure that can be individually metered and share no interior common area OR a group of buildings that share an energy meter, have a common heating or cooling system, share interior common areas, or otherwise cannot attribute energy use to a single building.

Buildings first begin benchmarking per the following timeline:

Building Benchmarking Timeline

Group Building Coverage First calendar year benchmarking period First benchmarking deadline
County County-owned buildings 50k+ gsf 2014 June 1, 2015
Group 1 Commercial buildings 250k+ gsf 2015 June 1, 2016
Group 2 Commercial buildings 50k – 250k gsf 2016 June 1, 2017
Group 3 Commercial buildings 25k – 50k gsf;
County buildings 25k – 50k gsf;
Previously exempted buildings of all sizes
2022 June 1, 2023
Group 4 Multifamily residential buildings 250k+ gsf 2022 June 1, 2023
Group 5 Multifamily residential buildings 25k – 250k gsf 2023 June 1, 2024



Special Cases:

  • Reference DEP’s guide on benchmarking amendment updates to coverage, building definitions, and reporting scenarios in the Covered Buildings Guide (PDF, 1.39MB).
  • Owners of properties that were previously benchmarking at the property level may opt to begin reporting individual buildings 25,000+ gross square feet. These newly reported single structures will be grouped into “Group 3” for timing and compliance and be given 3 years of benchmarking data before beginning Building Energy Performance Standards compliance. Please contact DEP for guidance if you are planning to begin reporting individual buildings on your previously-benchmarked property.
  • For more information on compliance with Building Energy Performance Standards, visit DEP’s BEPS website.

Covered Buildings List

DEP provides a Private Covered Buildings Inventory which is created with current Maryland tax assessment records and Costar data. This inventory is an approximation, meant to raise awareness about the law and help identify the buildings covered by the law. Each building owner will need to confirm their own building square footage to determine coverage under the law.

Beginning with calendar year 2022 reporting, for benchmarking purposes a “building” is a single structure that can be individually metered and share no interior common area OR a group of buildings that share an energy meter, have a common heating or cooling system, share interior common areas, or otherwise cannot attribute energy use to a single building.

The inventory contains the Montgomery County Building ID and best known gross square footage of individual buildings covered under the benchmarking law, both of which will be needed to benchmark your building.

Additional Resources:

  • Claim Your Building: So that DEP can email you updates and reminders about the benchmarking program, please Claim Your Building to store your contact information with your building. 
  • Get Help: If you have any questions about building coverage or feel that your square footage is incorrect, contact us.

Montgomery County Building ID (MBID) Number

The Montgomery County Building ID (MBID) is your building’s unique identification number.

DEP’s Private Covered Buildings Inventory lists the MBID for each covered building.

Enter this MBID number in Portfolio Manager (Under the Details tab, locate the “Unique Identifiers (IDs)” box. Select “Montgomery County (MD) Building ID” from the “Standard IDs” drop-down menu, and enter your MBID. Screenshots to help you enter your MBID can be found here (PDF, 381KB).

Without entering the MBID in Portfolio Manager exactly as it appears, your property may be deemed non-compliant.

Special cases:

  • If you have a building spanning multiple tax parcels, contact us for guidance on which MBID to use in your submission.
  • If you are separately reporting multiple buildings on one parcel, please refer to the Covered Buildings Inventory for each building’s ID or contact us for guidance on which MBID to use in your submission.


  • DEP’s Private Covered Buildings Inventory.
  • The Building Look Up tool allows you to search by address to view the building's ID, estimated floor area, and benchmarking status.
  • Online GIS map created from current Maryland tax assessment records to locate the parcel that your building sits on, and see what other buildings share your parcel.

Exemptions and Waivers

Please note that as of calendar year 2022 reporting, exemption and waiver criteria have changed.

An exemption can be filed for a covered building for which more than 50% of total gross square footage which is used for:

  1. public assembly in a building without walls;
  2. industrial uses where the majority of energy is consumed for manufacturing, the generation of electric power or district thermal energy to be consumed offsite, or for other process loads;* or 
  3. transportation, communications, or utility infrastructure (refer to definition of uses on p. 3 of land use coding manual for definitions).

* Buildings with at least 10% warehousing, self-storage, and manufacturing/industrial uses were previously exempted.

A waiver can be applied for in the cases where the property:

  • Is in financial distress, defined as the building is subject of a tax lien sale or public auction due to property tax arrearages; is controlled by a court appointed receiver; or was recently acquired by a deed in lieu of foreclosure;
  • On average, less than one full-time-equivalent employee occupied the building during the calendar year being reported;*
  • The covered building is newly constructed and has received its certificate of use and occupancy during the calendar year for which benchmarking is required; or
  • The covered building was demolished or received its demolition permit during the calendar year for which benchmarking is required

* Buildings with average physical occupancy of less than 50% throughout the calendar year were previously waived

Exemptions and waivers are valid for one year. Building owners must submit a Building Exemption/Waiver Application to DEP no later than May 1 of each deadline year.

Special cases:

  • Submit one form per property. Enter the Montgomery County Building ID exactly as it appears in the covered buildings list (with any leading zeros or underscore with capital letters). Submit any relevant supporting documentation along with the application to justify the exemption/waiver. Exemptions and waivers must be reviewed and approved by DEP.
  • Contact us if you have a special case to discuss.


  • Use the Exemption and Waiver Form if you are requesting an Exemption or Waiver for calendar year 2022 or later.
  • If you need to report an Exemption or Waiver for calendar year 2021 or earlier, please contact DEP for instructions.

Request an Extension

If you would like to request an extension for benchmarking and reporting to the County's Benchmarking Law, please submit the Benchmarking Extension Application. Extensions are available for periods of 14 days or 30 days.

Benchmarking Law Compliance

Compliance with the County's Benchmarking Law is a multi-step process that must be completed annually. By following the steps below, you’ll be able to benchmark your building, have the data verified, and report data to DEP.

DEP requires the use of ENERGY STAR Portfolio Manager to enter and report data each year.

The How-To Guide (PDF, 1.39MB) contains screenshots of how to create a Portfolio Manager account, create a property, create meters, enter energy data, verify data, and report to DEP.

To compile a complete report, ENERGY STAR Portfolio Manager will require:
  1. Building information including address, Montgomery County Building ID, gross floor area, occupancy and space types within the building, and others, depending on the space type.
  2. Energy data for all fuels used in the building (e.g. electric, gas, steam, chilled water, generator power, solar, etc.) covering January 1 through December 31 of the reporting year

Step 1: Collect Building Data

The Private Covered Buildings Inventory contains the Montgomery County Building ID and best known gross square footage, both of which will be needed to benchmark your building.

Required Property Uses and Use Details

Portfolio Manager requires accurate property use and operating information to help normalize energy use. Depending on the space type, this could number of workers and computers for offices, number of cash registers and refrigerators for retail, and number of beds for a hospital.

You must select the property type that most accurately represents your building’s usage and operations. 
  • If you are unsure what type of property your buildings is, view Portfolio Manager’s property type definitions of the 18 broad building type categories and, within those, 80 choices for property type. 
  • For buildings with different space types within one building, Portfolio Manager has guidance for entering separate property use types (and when not to).
  • Selecting the most accurate property type is critical as this informs the Building Energy Performance Standards your building will eventually be held to.
Use Portfolio Manager to find out what information will be required for your property type and to download a Data Collection Worksheet.

Have Tenants?

Building owners must request any space data needed in writing to the tenant no later than March 31 of each compliance year. Tenants must respond within 30 days of a request, per the Benchmarking Law. 

Step 2. Collect Energy Data

Energy Data

You will need whole-building energy data from all energy meters supplying the building in order to benchmark properly in Portfolio Manager. There are two ways to obtain your energy data:

(A) Gather your utility bills

  • If you are the account holder of all your meters and all your energy data is available to you, you can collect your bills for manual input. (Portfolio Manager also provides spreadsheet upload options to easily upload one meter or multiple meters at the same time.)
  • If you have tenants, you can request that they share/send their energy data to you for the purposes of benchmarking. Or, read below for information on requesting aggregated data from your utility/utilities.

(B) Request data from your utility/utilities

If you have multiple meters in your building, it is possible to request whole building, aggregate data from your utilities for benchmarking purposes. This service is most beneficial to building owners of buildings with 5 or more meters, particularly where tenants pay the utility bills.
  • If you have 5 or more meters, you can request whole building/aggregate data without tenant authorization.
  • If you have 4 or fewer meters, you can request data from your utility but must obtain authorization from tenants to obtain their energy data. Building owners will need to receive authorization from each tenant, which are available on each utility's energy benchmarking pages below.

Utility-Specific Information

  • Pepco customers can find information on getting their Pepco data at Pepco Energy Benchmarking. The basic steps are outlined here:
    • To request data, email the Energy Usage Data System (EUDS) enrollment form to Pepco. The form must list all service addresses associated with the property that will be included as part of the benchmarking reporting AND at least one known account or meter number at the property, such as the house meter, to verify these addresses. 
    • Pepco will process the enrollment form send a welcome email inviting you to verify your email and create a password for the EUDS platform.
    • Once in the EUDS platform, you will create a usage request and verify your tenants. Pepco will review your request.
    • Once your request has been approved, you are then able to sync EUDS to Portfolio Manager so that data is automatically sent to Portfolio Manager. This syncing process will transfer the data historically and as new bills become available. 
  • Washington Gas customers can find information on getting aggregated gas bill data at Washington Gas Energy Benchmarking. The basic steps are outlined here:
    • Set up your account at the Washington Gas Benchmarking Portal
    • Upload a list of all gas meter numbers servicing the building. The street address of the building is not acceptable.
    • You are then able to sync your Washington Gas data to Portfolio Manager so that data is automatically sent to Portfolio Manager. This syncing process will transfer the data historically and as new bills become available. Reference the Washington Gas user-guide (p. 9 to 19) for detailed step-by-step instructions.
  • Potomac Edison account holders can log-in to their account on the First Energy website to retrieve their data electronically or send an  email for commercial aggregated usage data requests. The basic steps are outlined here:
    • Send an email with a list of meter numbers servicing your property and the time period for which you are requesting data. You must send an email to request updated data each year.
    • Potomac Edison will email you back a spreadsheet containing aggregated, monthly electricity usage which you can then enter or upload into Portfolio Manager. 
  • BG&E offers information on getting electronic BGE energy data at Automated Benchmarking.  

When to Request Utility Data

Utilities will take up to 30 business days to provide your data, but typically complete requests within 10 business days. The wait can be longer as we approach compliance deadlines. Building owners are encouraged to request their data early.

Additional Resources:
  • Portfolio Manager Assistance: EPA offers a variety of resources to help users navigate the ENERGY STAR Portfolio Manager tool. The ENERGY STAR Help Desk offers an extensive list of searchable FAQs as well as different avenues to contact EPA staff with questions. EPA also offers Portfolio Manager Trainings that include full-length or short training videos, either in pre-recorded or live viewing formats. 

Step 3: Benchmark Property in Portfolio Manager

DEP requires the use of ENERGY STAR Portfolio Manager to enter and report data each year.

Method 1: Do-It-Yourself Benchmarking

Portfolio Manager is built to be user-friendly and accessible for in-house staff to benchmark their buildings. In many cases, ENERGY STAR has found accounting, operations, and building management staff are entering data into Portfolio Manager. If you choose to Do-It-Yourself, below are some helpful tools to guide you.

Portfolio Manager Resources:
  • How-To Guide: Guide with screenshots of how to create a Portfolio Manager account, create a property, create meters, and enter energy data (PDF 1.39MB). 
  • Portfolio Manager Quick Start Guide (PDF, 508KB) offers the basics to setting up your Portfolio Manager account, including adding your property, entering your energy data, and seeing your results.
  • Details on Entering Your Utility Bill Data (PDF, 567KB) walks you through the steps to set up a meter and correctly enter data, add data to an existing meter, complete spreadsheet uploads, and information on Web Services (automated benchmarking).
  • Portfolio Manager Trainings offers both live and recorded webinars, written and video tutorials, and how-to’s for specific functions of the software.
  • Portfolio Manager Technical Support offers expert advice and guidance on how to benchmark your building(s) in Portfolio Manager.

Montgomery County DEP is working very closely with ENERGY STAR and defers to their technical support for guidance in benchmarking in the software.  Benchmarking per the ENERGY STAR Portfolio Manager guidelines is a best practice for compliance with the Benchmarking Law.

Method 2: Hire an Energy Service Company to Benchmark

Benchmarking is a common and regular practice for any energy efficiency or conservation project. Montgomery County and the region are home to many energy service companies that offer an array of services to help you manage your energy use. Many of these same companies are experienced in benchmarking and can help you benchmark your building.

What to Look for in an Energy Service Company: DEP cannot endorse a particular company or business, but we recommend asking a few companies about their experience for benchmarking, data verification, their ability to help deliver energy savings, and other services they offer. You can ask for quotes from multiple companies, and they may be able to help you benchmark, and access to improve your building's energy performance. 
Where to Look for an Energy Service Company: DEP does not endorse a particular company or business, but we can direct you to existing lists of energy service companies that do similar work.

Utilities’ service provider lists offer a list of companies that assist utilities with energy efficiency improvements, many of which can offer benchmarking services:

Step 4. Complete Data Verification

Verification is considered an industry best practice and ensures that building and energy data entered into Portfolio Manager are accurate. The purpose of verification is to enhance the quality of data being reported collectively through the Benchmarking Law. Verification requires a second pair of eyes from someone with knowledge about Portfolio Manager and building energy performance.

The Benchmarking Law requires that building owners complete a verification process the first year of compliance and every 3 years after.

How to Complete Verification

DEP’s How-to Guide for Data Verification (PDF, 160KB) provides step-by-step guidance on how to complete data verification.

The Recognized Data Verifier should review the Data Verification Checklist provided by Portfolio Manager (under the Reports Tab and in the top right box, here is a sample checklist). The verifier will confirm the building profile information and meter data. The required verification does not include looking at water metrics or indoor air quality, nor does it require a site visit.

This Data Verification Checklist must be printed and signed and given to the building owner. This signed Verification Checklist does not need to be submitted to DEP, unless it is requested by DEP (DEP is authorized to request documentation). Therefore, building owners must retain the most recent signed Data Verification Checklist for at least three years.

Once verification is completed, the building owner must enter the following details about the Recognized Data Verifier in the Verification fields on the Details tab for each covered building in Portfolio Manager:
  • Period Ending Date for Year Verified and date of verification 
  • Verifier name, title, organization, phone, email, and postal code
  • The professional designation/credential held by the verifier
  • Credential identifier (ID or license number)

Who May Complete Data Verification - Acceptable Recognized Data Verifier Credentials

Building owners must demonstrate that reported benchmarking information is verified by a "Recognized Data Verifier." Building owners can use any in-house or third-party professional who holds an active credential listed on the Acceptable Verification Credentials list.

See page 2 in the How-to Guide for Data Verification (PDF, 160KB) or below for a list of acceptable verification credentials:


Finding a Recognized Data Verifier

Building owners can use any in-house or third-party professional who holds an active credential listed on the Acceptable Verification Credentials list above. While DEP cannot recommend or refer you to a Recognized Data Verifier directly, we do have a list of Benchmarking Ambassadors – these volunteers have received training on the Benchmarking Law and Portfolio Manager, and some of the Ambassadors hold an acceptable Recognized Data Verifier credential.

Alternative Compliance Path

Alternatively, covered buildings can meet the verification requirement if the owner can demonstrate that the building has achieved the ENERGY STAR building certification for at least 6 months of the calendar year being benchmarked.

If a building owner is using this verification path for a covered building, please indicate this in the Property Notes field by stating “ENERGY STAR Certification used for verification” and the month and year certification was achieved.


Step 5. Submit Data to DEP

We recommend that you run the Data Quality Checker for each property to highlight any potential issues before you submit your benchmarking report.

DEP publishes a new reporting link each year. Please use the yellow-highlighted link below to submit your calendar year 2021 building energy benchmarking report to DEP. The submission deadline for all covered buildings (50,000 sq. ft. and greater) is June 1, 2022.

**Calendar Year 2022 Reporting Link **

This link will take you to the ENERGY STAR Portfolio Manager account log-in screen—after logging in, you’ll see step-by-step instructions on the Data Request page.

Additional Resources:
  • How to Submit Data to DEP: Review our how-to guide with screenshots of how to submit data to DEP to close out your reporting. 
  • Reporting Revisions to Previous Years' Benchmarking Reports: If you need to amend prior year benchmarking reports, email us for prior reporting links. 
  • Common Issues: Review common issues that building owners may experience that prevent a benchmarking report from being accepted: Common Issues with Montgomery County Benchmarking Reports
  • EPA’s Data Quality Checker can help surface any potential issues before you submit your benchmarking report. (Note that waste and water data are NOT required for Montgomery County benchmarking.


The Benchmarking Law is enforceable under Method 2 regulations (including fines for noncompliance), and any violation of the law is a Class A violation. DEP will send out Notice of Violation to any building owner of a covered building who does not comply with the Law. Note that DEP is available to assist any building owner to help them comply with the law.

Benchmarking Help

Email the Benchmarking Helpdesk or call us at 240-777-7707 for questions about the benchmarking law, building coverage, and to be connected with resources at EPA’s Portfolio Manager or at local utilities.

Sign-up for the Commercial Energy News, a newsletter that includes all of the Benchmarking Law updates, as well as Commercial PACE financing news, green building news, and commercial energy events.

While DEP cannot recommend or refer you to specific companies for benchmarking help, Montgomery County Benchmarking Ambassadors (PDF, 311 KB) have attended training about complying with Montgomery County's law and learned how to access data from utilities.

Disclosed Data and Reports

Compliance Status

Unsure if your building is in compliance this year? Look-up your Montgomery County Building ID to see if your building(s) still needs to comply in the Benchmarking Compliance Status Report. The report has two tabs, one showing buildings that are in compliance and the other showing buildings that are not yet in compliance. This report is updated weekly.

About Reporting and Disclosure

The Benchmarking Law requires the County to make reported benchmarking information readily available to the public. The first year's data of each reporting group will not be disclosed. Disclosure will begin the 2nd year of each building group's reporting.

DEP requests information to fulfill the Benchmarking Law’s reporting requirements and provide helpful information to guide benchmarking and energy efficiency program and policy planning. As such, DEP collects a broader set of data than is disclosed. However, DEP will only disclose the list of metrics listed in the glossary of terms (PDF, 119 KB). The collected data will be used to provide aggregate metrics and portfolio-wide benchmarks for reporting purposes.

Annual Reports

Disclosed Data

Other Reports & Tools

After Benchmarking: Resources to Save Energy 

Once your building has been benchmarked, you may find that there is room to improve energy efficiency, or you may need to save energy to meet the required Building Energy Performance Standards (BEPS). Simple adjustments to equipment start time, operations, occupant behavior, and controls can reap significant energy and cost savings.

Learn about utility incentives, financing for energy efficiency improvements and renewable energy, and recognition opportunities.

Legislative Background

In May 2014, the Montgomery County adopted a Building Benchmarking Law (PDF, 580 KB) and amended the original legislation by Bill 35-15 Environmental Sustainability – Benchmarking – Amendments in November 2015.

On August 1, 2022, benchmarking amendments went into effect following passage of Bill 16-21, Building Energy Use Benchmarking and Performance Standards - Amendments. The latest amendment expanded the number of buildings covered by the benchmarking requirement and established a building energy performance standard.