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Am I Required to Benchmark

By 2014, all commercial and multifamily buildings over 50,000 gross square feet will be required to report benchmarking data to the District on a yearly basis. In 2013, all buildings over 100,000 gross square feet have to report 2012 data. Larger buildings will have to report additional years of benchmarking data; however, DDOE is requiring less detail in these reports. Below is a guideline for the initial reporting phases based on a building’s gross square footage. Once the initial report is made, continue to report every following April 1.

Initial Benchmark Reporting Requirements

Building Size

Utility Year Data


# of buildings (approximate)

Over 200,000 sq. ft.

2010 – 2012

April 1, 2013*


150,001-200,000 sq. ft.

2011 – 2012

April 1, 2013*


100,001-150,000 sq. ft.


April 1, 2013*


50,001-100,000 sq. ft.


April 1, 2014


Covered Building List

DDOE had published a list of buildings covered by the benchmarking regulation. The DC Real Property ID, square footage (as listed in the tax records), premise address, owner of record, and ward are provided. You need to include the District of Columbia Real Property Unique ID when you report your building.

- New: Download the New 2014 Covered Building List

- Download the 2013 Covered Building List


DDOE regulations allow exemptions from the benchmarking regulations under certain conditions. Major exemption categories are listed below; these are largely not new, but are listed here for clarity.  All exemption requests should be made in writing to info.benchmark@dc.gov. DDOE has final authority on whether to grant any exemption.

  • Unoccupied: A building may apply for an “unoccupied” exemption if on average less than one full-time-equivalent employee (less than 40 person-hours per week/2080 person-hours per year) worked in the building, exclusive of security guards, janitors, construction workers, landscapers, and other maintenance personal during the year being reported. (20 DCMR 3511.2(d))
  • National Security: If you believe the disclosure of the energy use of the building would be harmful to the public interest and national security, you may apply for an exemption from reporting or public disclosure. (20 DCMR 3511.2(b))
  • Sale: If your building was sold in the year being reported then reporting will recommence once a full calendar year of utility data can be collected. (20 DCMR 3513.11(b))
  • New Construction: If your building received its Temporary or Permanent Certificate of Occupancy in the year being reported then reporting will commence once a full calendar year of utility data can be collected. (20 DCMR 3513.11(a))
  • Demolition: If your building was demolished in the year being reported, then reporting is not required, as the building no longer exists. (20 DCMR 3513.1)
  • Under the threshold: If your building is smaller than 50,000 gross square feet, then it is not required to benchmark, unless it shares energy use with other buildings. (20 DCMR 3513.1)

Now that you know if you are covered by the regulation, find out how to collect the data you need.