DC and Maryland Energy Benchmarking: Portfolio Manager Guide

Picture a small owner with four buildings. An 18,000-square-foot office on a DC commercial corridor. A 40,000-square-foot apartment building in Silver Spring. A 60,000-square-foot office building in Howard County. A 30,000-square-foot office in Arlington. Three of them carry an energy benchmarking obligation, each with its own regulator, building ID, filing steps and verification cycle. The Arlington building has no mandate at all.

The DC building is the one that bites. It was not covered until calendar year 2025 data, so its first report was due May 1, 2026. The tenants pay their own Pepco bills, and nobody knows the Portfolio Manager login.

This guide covers the annual benchmarking duty in the DMV as of October 2026: who is covered in DC, Montgomery County and the rest of Maryland, and what Virginia does not require. It then walks through ENERGY STAR Portfolio Manager, from setup to the score. Levaru runs this work for owners as part of ESG reporting for commercial buildings. This is general guidance, not legal advice. Confirm your building’s status with the program office before you rely on it.

What is energy benchmarking, and how is it different from BEPS?

Energy benchmarking is the annual job of measuring a building’s whole-building energy use (and in DC, water use) and reporting it to a regulator through ENERGY STAR Portfolio Manager. It is a reporting duty. A building that performs badly but reports on time and accurately is compliant with benchmarking.

Building energy performance standards (BEPS) are different. BEPS laws take the benchmarking data and grade it against a target, with penalties for buildings that fall short. All three DMV programs use the benchmarking report as the data source for their standards. We cover the targets, cycles and compliance pathways in BEPS deadlines in DC and Maryland, so this guide stays on the filing itself.

That link is the reason to take benchmarking seriously. A wrong floor area or a missing tenant meter does not just risk a reporting fine. It can put a building on the wrong side of a performance standard. The same report also feeds lender questionnaires and investor requests, as we explain in ESG reporting for mid-market landlords.

Which DMV buildings must benchmark, and when?

In DC, private buildings over 10,000 square feet. In Montgomery County, commercial and multifamily buildings of 25,000 square feet and up. Elsewhere in Maryland, 35,000 square feet and up. Virginia has no private-building mandate. The table compares the programs as of October 2026, from each regulator’s own pages.

Item	Washington, DC	Montgomery County, MD	Maryland (statewide)	Northern Virginia
Regulator	DOEE	County DEP	MDE	None
Who	Private buildings over 10,000 sq ft	Commercial and multifamily, 25,000 sq ft and up	Commercial and multifamily, 35,000 sq ft and up, outside Montgomery County	No private mandate
Deadline	May 1	June 1	June 1	—
Data	Energy and water	Energy	Energy	—
Where to file	Portfolio Manager, shared with DOEE	Portfolio Manager plus county portal	Portfolio Manager, shared with MDE	—
Building ID	DC Real Property Unique ID	Montgomery County Building ID (MBID)	Unique Building ID (UBID)	—
Verification	2027, then every 6 years	First year, then every 3 years	2026, then every 5 years	—
Annual fee	No fee listed	No cost to file	$100 per building	—
Penalty	Up to $100 per day	$500, then $750 (Class A)	Warnings to fees, case by case	—

Every program reports the previous calendar year. A report due in spring 2027 covers January 1 to December 31, 2026.

What does DC’s energy benchmarking law require?

In the District, every privately owned building over 10,000 gross square feet must report its prior-year energy and water data to the Department of Energy and Environment (DOEE) by May 1. The Clean and Affordable Energy Act of 2008 started with private buildings over 50,000 square feet. The Clean Energy DC Omnibus Act of 2018 lowered the threshold in steps, and buildings of 10,000 to 24,999 square feet first reported 2025 data, due May 1, 2026.

Some older DOEE pages still show April 1 and 50,000 square feet. The current DOEE benchmarking helpdesk states May 1 and 10,000. Go by the helpdesk.

How you file. In Portfolio Manager, connect to DOEE’s “District of Columbia Annual Reporting” account and share each property with exchange-data permissions. Each property needs its DC Real Property Unique ID, the Square-Suffix-Lot (or Square-Suffix-Regime for condominiums) from the tax records. DOEE matches reports to its covered building list by that ID, so a wrong ID can leave a building marked non-compliant even though you filed. Enrollment carries over, but you still update use details and load the full calendar year of utility data before each May 1.

Tenants. Non-residential tenants must give the owner their energy, water and space-use data within 30 days of a request. Residential tenants are not required to provide data.

Exemptions. DOEE accepts documented requests for buildings that were unoccupied (less than one full-time-equivalent occupant on average), newly built in the reporting year, demolished, or sensitive for national security. Absence from the covered building list does not mean you are exempt.

Verification. An Approved District Data Verifier must check the data in set years. The first round was 2024. The next is due with the May 1, 2027 report (2026 data), then every six years under 20 DCMR § 3515, as explained in DOEE’s third-party verification FAQ. The verifier needs a PE or architect license, a CEM or a Building Energy Assessment Professional credential, and cannot be the owner, an employee, or whoever prepared the report. Keep the signed checklist for three years.

Disclosure and fines. DOEE publishes results on its building performance map and DC’s open data portal, except for a building’s first required year. Buildings without complete, accurate data by May 1 get a notice. If they still do not comply, DOEE can fine up to $100 per day.

What does Montgomery County’s benchmarking law require?

Montgomery County requires most public and private commercial and multifamily buildings of 25,000 gross square feet and larger to benchmark and report to the Department of Environmental Protection (DEP) by June 1 each year. The program began with Bill 2-14 in 2014. Bill 16-21, effective in 2022, expanded coverage and added the county’s own BEPS.

The county program covers energy only, not water or waste. Since October 1, 2025, House Bill 49 exempts Montgomery County buildings from the statewide Maryland program, so a county building reports to DEP alone. DEP also notes that some jurisdictions have not opted into the county law. If your building sits in an incorporated city or town, confirm with DEP which program applies.

How you file. Filing takes two steps, and the second is easy to miss. First, connect to the “MontgomeryDEP” account in Portfolio Manager and share the property, with its Montgomery County Building ID (MBID) entered exactly as DEP’s inventory shows it, leading zeros included. Second, claim the building in the Montgomery County Benchmarking Portal and submit there. DEP does not pick up later Portfolio Manager edits, so any change after submission means resubmitting through the portal.

Floor area. DEP accepts gross floor area backed by blueprints, architectural plans or BOMA documents. It does not accept property tax records or GIS measurements alone.

Extensions and waivers. The portal accepts extension requests of up to 30 days past June 1. Longer extensions need documented reasons, such as utility data delays. Waivers (financial distress, less than one full-time-equivalent occupant, new construction, demolition) last one year and are due by May 1.

Verification. Data must be verified in the building’s first reporting year and every three years after. The verifier must hold a credential on DEP’s list, which includes PE, registered architect, CEM, CFM and LEED AP O+M, among others. Unlike DC and the state, the county allows an in-house verifier. The portal shows a “Data Verification Due By” date for each claimed building.

Disclosure and fines. DEP publishes data on its public building energy performance map, except for a building’s first required year. Any violation of the law is a Class A civil violation. The county enforcement page lists $500 for an initial citation and $750 for a repeat, and county code treats each day of a continuing violation as a separate offense.

What does Maryland’s statewide BEPS benchmarking require?

Outside Montgomery County, Maryland requires owners of commercial and multifamily buildings of 35,000 square feet or more (excluding parking garage area) to submit an annual benchmarking report to the Maryland Department of the Environment (MDE) by June 1. The requirement comes from the Climate Solutions Now Act of 2022 and the BEPS regulation, COMAR 26.28. Reporting started in 2025.

For 2026, MDE accepted benchmarking reports and exemption requests submitted by June 30, 2026 as timely. Do not assume that extension repeats. Watch the MDE BEPS page each spring.

Exemptions. MDE lists individually designated historic buildings, K-12 schools, manufacturing, agricultural and federally owned buildings, hospitals and demolished buildings. Request them on the BEPS Portal. Nonprofit ownership is not an exemption.

How you file. Find your building’s UBID on the MDE BEPS Portal and enter it in Portfolio Manager. Load 12 months of whole-building energy data for every fuel. Then connect and share the property with MDE’s “MD-BEPS” account. Water data is not required. The regulation requires you to run Portfolio Manager’s Data Quality Checker and correct what it finds before you submit. If MDE flags an inaccuracy, you have 30 days to fix and resubmit.

The fee. Since 2026, each covered building pays a $100 annual reporting fee, due by June 1 through the BEPS Portal. From 2027 the fee is adjusted each year for inflation.

Verification. A third party must verify the report for calendar year 2025 (due in 2026), then calendar year 2030 (due in 2031), and every five years after. New buildings verify their first report. The verifier must be external and hold one of nine credentials MDE lists, including PE, licensed architect, CEM, Certified Energy Auditor, BEAP and LEED AP O+M. Keep the records for five years.

Disclosure and penalties. MDE has posted a preliminary building-level spreadsheet of 2024 data with each building’s name, county, property type, floor area, weather-normalized site EUI and direct emissions intensity. On penalties, the MDE BEPS FAQ says MDE’s compliance program reviews each violation case by case, and the outcome can range from a warning to fees.

Does Virginia require energy benchmarking?

No. As of October 2026, Virginia has no benchmarking mandate for privately owned buildings, and we found no Northern Virginia county or city near DC with an ordinance that requires it. Two 2022 bills that would have let localities require benchmarking, HB 379 and SB 452, died in committee. Fairfax County’s Environmental Quality Advisory Council was still proposing that the county seek that authority in its 2024 legislative proposals.

Three things in Virginia do touch benchmarking:

• State agencies must track buildings over 5,000 square feet in Portfolio Manager under Va. Code § 2.2-604.2.
• Site plan conditions. Arlington’s Green Building Incentive Policy asks projects that receive bonus density to report Portfolio Manager data each year for 10 years after occupancy. Check your site plan or proffers for reporting conditions.
• Voluntary use. Many owners benchmark Virginia buildings anyway, for certification, investor questionnaires and operating insight.

How do you set up a building in ENERGY STAR Portfolio Manager?

You create the property, enter its uses and floor area, add meters for every fuel, load the calendar year of data and share it with the regulator. Portfolio Manager is EPA’s free tool, and every DMV program requires it. Start with EPA’s data collection worksheet, which lists the use details for your property type.

1. Create the property. Enter address, year built, number of buildings, occupancy and documented gross floor area, excluding parking.
2. Break out property uses. Montgomery County DEP recommends a separate use for any space of 10% or more of floor area and for high-intensity uses such as data centers, labs and restaurants. DC does not let you exclude any score-eligible space type. Use areas must add up to the building total.
3. Enter use details. Operating hours, workers, computers and multifamily unit counts drive the score. Take them from rent rolls and tenant records, not guesses.
4. Add the jurisdiction ID. DC Real Property Unique ID, MBID or UBID, entered under Unique Identifiers.
5. Create meters for every fuel, including steam, delivered fuel and on-site solar. With whole-building aggregate data, use one meter per fuel. With bills, use one meter per account. Check units (kWh, therms or CCF), and set “date meter became active” to the first day of the first bill, often the prior December.
6. Mark the meters as whole-building. Check the box confirming the meters account for the building’s total energy use. DC buildings also need water meters.
7. Run the Data Quality Checker and fix every alert before you connect and share with the regulator.

How do you get whole-building data from Pepco, BGE, Washington Gas and Dominion?

Ask the utility for aggregated whole-building data instead of chasing every tenant’s bills. In DC and Montgomery County, buildings with five or more meters can get aggregated data from Pepco and Washington Gas. Montgomery County DEP notes that with four or fewer meters, you need each tenant’s authorization. Maryland’s regulation draws a similar five-tenant line and requires utilities to deliver monthly aggregated data within 30 days of a request made in 2026 or later.

Utility	Area	Whole-building tool	Notes
Pepco	DC, MD	Exelon Energy Usage Data System (EUDS)	Enroll by form, then sync to Portfolio Manager
BGE	MD	EUDS	Similar process to Pepco
Washington Gas	DC, MD	Utilli benchmarking portal	Needs meter numbers, not addresses
Washington Gas	VA	Benchmarking portal, automated upload	Five or more gas accounts
Potomac Edison	MD	FirstEnergy Benchmarking Tool	Renew the usage request each year
Dominion Energy	VA	Email request with a letter of authorization	No automatic feed; returns a spreadsheet
DC Water	DC	None	Most buildings are master-metered

Two practical points. First, the utility aggregates only the meters you list, so a missing tenant meter means missing energy. Walk the meter rooms once and keep the list current. Second, start early. Montgomery County DEP says Pepco, BGE and Washington Gas often return data quickly, while other utilities typically take about 10 business days. Turnaround can reach three to four weeks, and longer near deadlines.

How do you clear the Data Quality Checker and avoid common errors?

Run Portfolio Manager’s built-in Data Quality Checker, then fix the issues regulators reject most often. Maryland requires the checker by regulation. Montgomery County DEP recommends it and says county filers can ignore water and waste alerts. DEP’s list of issues that get reports rejected:

• No property use, or floor area of zero. Use areas must sum to the building total.
• Missing or wrong building ID. One missing leading zero breaks the match.
• Fewer than 12 full months of data. Bills must cover January 1 to December 31, which may take the prior December’s bill.
• Partial-building data. Only house meters entered, with tenant use missing.
• Gaps or overlaps in meter read dates.
• A single bill over 65 days long. This blocks the weather-normalized metrics.
• Estimated data left checked. DEP does not accept estimated values in a submitted report.
• Missing verification details in a verification year. The verifier’s name and credential go in the Verification fields on the property’s Details tab.

Two errors the checker may not catch: a wrong property type, and stale use details after a big lease change. A verifier will look for both, and both move the score.

What do the ENERGY STAR score, site EUI and source EUI mean?

The ENERGY STAR score is a 1-100 percentile ranking of your building’s energy performance against similar buildings nationwide. A score of 50 is the national median. A score of 75 or higher marks a top performer and makes the building eligible for ENERGY STAR certification. Certification is annual, and a licensed PE or registered architect must verify the application.

EPA builds the peer group from national survey data, mainly the Commercial Building Energy Consumption Survey (CBECS), not from other Portfolio Manager users. To get a score, more than half the floor area must be a score-eligible type, with 12 full consecutive months of data for all fuels. Most types also have size and operating-hours minimums, and multifamily needs at least 20 units.

The other metrics:

• Site EUI is the energy on your bills divided by gross floor area, in kBtu per square foot per year.
• Source EUI adds the losses in producing and delivering that energy, using national source-site ratios. EPA bases the score on it. EPA lists the national median office at 116.4 kBtu per square foot source EUI and 52.9 site EUI.
• Weather-normalized EUI estimates what the building would have used under average weather. Use it to compare your own building year over year.

Which number matters depends on where the building is. DOEE’s public map shows each building’s estimated distance from its BEPS in percent of source EUI. Montgomery County’s performance standards use site EUI. Maryland’s standards center on direct emissions, and MDE’s published data reports weather-normalized site EUI.

A score well below peers, or a weather-normalized EUI that rises year over year, points to an operating problem. The measures with the best standalone payback, such as schedules, setpoints and controls, are often the same ones that close a BEPS gap, which is why our energy management work starts from the Portfolio Manager record.

What does a year-round benchmarking calendar look like?

Work backward from the May 1 and June 1 deadlines: coverage and meter checks in the fall, data collection in January and February, quality checks and verification in March and April. Put each deadline on the same compliance calendar as your other inspections.

When	Task	Applies to
October–December	Confirm coverage, IDs and logins. Book the verifier if next year is a verification year.	All
October–December	Update the meter list. Renew utility data requests. Add data clauses to new leases.	All
January–February	Request December bills and aggregated data. Send tenant data requests (30-day response).	All
February–March	Update use details. Run the Data Quality Checker. Fix floor area and meter gaps.	All
March–April	Complete third-party verification in verification years.	DC 2027; MD 2031; MC by due date
May 1	Report due	DC
By May 1	File waivers	Montgomery County
June 1	Report due (30-day extension on request)	Montgomery County
June 1	Report and $100 fee due	Maryland
Summer	Answer agency correction requests within 30 days.	DC, Maryland

Lease language is the quiet lever. A clause that requires tenants to share utility data, or to authorize release to the utility, removes the hardest part of the job. MDE accepts a lease provision as tenant authorization. Whoever handles your lease administration should put that clause in every renewal.

For buildings Levaru manages, meter swaps and equipment changes are recorded as photo-documented work orders in our CMMS, so a verifier’s “why did this meter change in July” has an answer. We prepare the data. Where a program requires an independent verifier, that is a separate credentialed professional, not us.

Frequently asked questions

What is the energy benchmarking deadline in Washington DC?

May 1 each year, for the previous calendar year’s energy and water data. As of 2026 reporting, every privately owned building over 10,000 square feet is covered. You file by sharing your Portfolio Manager property with DOEE’s automatic annual reporting account, using the correct DC Real Property Unique ID. Late buildings get a notice first, then DOEE can fine up to $100 per day.

Does a Montgomery County building also report to the state?

No. Since October 1, 2025, House Bill 49 exempts Montgomery County buildings from the statewide Maryland benchmarking and BEPS program, so covered buildings report only to the county’s Department of Environmental Protection by June 1. DEP notes that some jurisdictions inside the county have not opted into the county law. If your building is in an incorporated city or town, confirm with DEP which program applies before you skip a filing.

Is there a fee to benchmark in Maryland?

Yes, for the statewide program. Since 2026, each covered building of 35,000 square feet or more pays a $100 annual reporting fee to MDE, due by June 1 through the BEPS Portal. From 2027 the fee is adjusted for inflation each year. Montgomery County states there is no cost to file a benchmarking report with DEP, though you may pay a verifier in verification years.

Can our property manager verify our benchmarking data?

It depends on the program. Montgomery County allows an in-house verifier who holds a credential on DEP’s list. DC requires an Approved District Data Verifier who is not the owner, an employee, or the firm that prepared the report. Maryland requires an external verifier with one of MDE’s listed credentials. If your manager prepares the report, plan on a separate verifier for DC and Maryland.

How long does it take to get aggregated utility data?

Anywhere from days to a few weeks. Montgomery County DEP reports that Pepco, BGE and Washington Gas often provide data soon after a request, barring data issues, while other utilities typically take about 10 business days. Turnaround can reach three to four weeks, and longer near deadlines. Maryland’s regulation requires delivery within 30 days of a request made in 2026 or later. Request December data in January.

What happens to benchmarking when a building is sold?

The duty moves with the building. In DC, the seller must give the buyer the information needed to file. In Montgomery County, whoever owns the building on June 1 files, and the prior owner must hand over the Portfolio Manager and verification records. In Maryland, the seller must disclose BEPS coverage and transfer the benchmarking record before the buyer signs a contract. Put the Portfolio Manager transfer on the closing checklist.

What ENERGY STAR score do I need to comply?

None. Benchmarking laws require accurate and timely reporting, not a minimum score. A score of 75 or higher makes a building eligible for ENERGY STAR certification, which is voluntary. Performance targets come from BEPS, and each program sets them differently. Montgomery County uses site EUI targets, Maryland uses direct emissions limits, and DC sets its own standards. Our BEPS guide covers those targets in detail.