Benchmarking Requirements

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Benchmarking Basics

One of the key parts of the Energize Denver program is your annual Benchmarking Report. This report verifies that you are meeting your performance requirements. You do not need to submit extra documentation to show compliance.

Your Benchmarking Report helps you keep track of your energy performance. It lets you easily see whether you are on track to meet your Performance Requirements. If your current building EUI is higher than your Performance Target, you must take action to reduce energy use. Failure to act could result in fines or other penalties from the city.

Buildings must submit their annual Benchmarking Report by June 1 of every year. You will use the ENERGY STAR® Portfolio Manager tool for this. We make the energy data you report available to the public. This way, they can be better informed about energy efficient buildings in Denver. Xcel Energy offers a Benchmarking Services Guide to help you.  

Unsure if you you completed benchmarking for your building this year? Look-up your Denver Building ID or address in the Performance Requirements Lookup Tool. The tool will show you if your building(s) still needs to comply. Need help with your Benchmarking report? The list of service providers who have taken our Benchmarking Training is a good place to start.

First-time Set-up of your Portfolio Manager Account

If this is your first time benchmarking, start here.

  1. Create an ENERGY STAR® Portfolio Manager account.
  2. Click “Add a Property” to set up your building. 
    1. Answer questions about your property. Use the links to ensure you understand how to enter accurate information.
    2. You will need to know the building’s Gross Floor Area. This is the total property square footage between the exterior walls of the building. It includes all finished areas inside the building including supporting areas. 
  3. Click "Add Meters" under the “Energy” tab to set up automatic or manual meter readings.
    1. Add last year’s Whole-Building Energy Consumption Data.
    2. Electricity and Natural Gas. Choose auto-upload or manual entry.
      1. Auto-upload option: We recommend this option. Xcel Energy will automatically upload aggregated whole-building data for electricity and natural gas. In Portfolio Manager you will create only one virtual electricity meter (kwh) and one virtual natural gas meter (therms). Name these meters "whole building electricity" and "whole building natural gas". From there, follow the steps in Xcel’s Benchmarking Services Guide to have Xcel auto-load your data. 
      2. Manual Entry option: You will have to manually enter any natural gas purchased from transport providers. Check the units on your transport bill. They are often in MMbtu, which Portfolio Manager labels as MBtu/MMBtu/Dth. You also have the option to manually enter your electricity data as long as you have access to data for the whole building.
      3. You must use the auto-upload option if you are benchmarking a multi-tenant building with more than one meter that Xcel will need to aggregate. 
    3. Steam and Chilled Water. If your building uses these, you will have to manually add these data. When setting up meters, steam units are kLbs and chilled water units are ton hours.
  4. Enter the Building's Denver Building ID.
    1. Each building has a unique 4-digit Denver Building ID given in your compliance notice so we can track compliance.
    2. If you lost your ID number, you can look it up with the Lookup Tool.
    3. If you do not add the Denver Building ID to your building's property details, we cannot see your report and you will not be in compliance.  

Once you have set up your account, follow the directions to submit your annual Benchmarking Report. 

Special Considerations

Benchmarking for Normalized Targets

ENERGY STAR® Portfolio Manager benchmarks similar property types against each other on a national level. It does this by assigning one property type per building. This is not always appropriate for all buildings. Buildings that contain both that mix high- and lower-intensity property types (like strip malls or hotels) may struggle. You can assign several different property types to you building by square footage. If you do this, you should break out the square footage of each building sub-type when you submit your report. This will allow us to apply a more appropriate mixed-use target. Campuses, particularly colleges and universities, should always break out their sub-types. The table below lists examples of building types that may have high-intensity sub-types that you should break out.

Building Type

Possible High-Intensity Sub-types


Laboratories, Restaurant, Food Services, Fast Food, etc.

Enclosed Mall, Strip mall, Other - Mall

Retail Store, Restaurant, Fast Food, Food Services


Restaurant, Fast Food, Swimming Pool


Restaurant, Fast Food, Retail Store

Residence Hall/Dormitory

Food Service, Fitness Center

Stadiums (open or closed)

Restaurant, Fast Food, Food Service

If you are a building owner that is currently on or are planning to join the Denver District Cooling Loop, please reach out to the Help Desk at after the submission of your first benchmarking report with district chilled water usage. Because you are on this loop, we will apply a target adjustment to your 2030 target. Current Denver District Cooling Loop users will automatically have a target adjustment applied in February 2024. This adjustment does not require an application.

Swimming Pools

If you can sub-meter the energy use for the pool, the energy use could be excluded from your benchmarking data. If you can't sub-meter it, there are target adjustments available, so benchmarking is important. When you list swimming pools as a property use type, you should include detailed information on: 

  • Approximate pool size
  • Location of the pool
  • The months the pool is in use


Data Centers

The Benchmarking Report should reflect the accurate square footage of your data center. We will determine the classification of your building based on what you enter in ENERGY STAR® Portfolio Manager. Smaller data centers may qualify for a target adjustment.

For the performance requirements, Data Centers have been split into two categories based on the square footage it occupies in the building:

  • Class A: 15% or more of the square footage of the building. Buildings with Class A data centers are part of the Manufacturing, Agricultural, or Industrial buildings category.
  • Class B:  Less than 15% of the square footage of the building. Buildings with Class B data centers are eligible for a target adjustment based on the square footage the data center occupies.

Use this definition from the IECC to determine data center square footage:  

“A room or series of rooms that share data center systems, whose primary function is to house equipment for the processing and storage of electronic data and that has a design total Information Technology Equipment (ITE) power density exceeding 20 watts per square foot (20 watts per 0.092 m2) of conditioned area and a total design ITE load greater than 10 kW.”



If parking is part of the building, and you are unable to exclude its energy use from the Benchmarking Report following ENERGY STAR® Portfolio Manager guidance, you can apply for a target adjustment. If the parking structure is a stand-alone building and considered to be 100% of the building’s property type, the building will receive a 2030 target as an individual building.

If you have to include parking in ENERGY STAR® Portfolio Manager, you should include:

  • Square footage
  • Configuration:
    • Open
    • Partially enclosed
    • Completely enclosed
  • Whether or not there is supplemental heating.

Electric Vehicle Charging Stations

You should exclude electric vehicle charging stations or other transportation-related charging devices or power uses to the extent possible based on how it is metered:

  • If the energy use is on the main meter, but you submeter it, exclude it from your building by entering an additional meter with negative entries
  • If the energy use is on its own meter (not sub-metered), leave out the charging stations altogether and exclude the meter from your benchmarking.
  • If a third-party vendor provides the charging stations, you should look at the monthly reports from the vendor and exclude the total kWh charged.
  • If your EV energy is on the main meter and not sub-metered, then you currently have to include this energy when benchmarking. In 2023, ENERGY STAR® Portfolio Manger will be adding an adjustment to estimate your EV energy and subtract it from your building. This will work similarly to how parking and swimming pools are handled.

Third-party Loads

If the building is a host for third-party items like antennas or cell towers, and you do not want this energy included in your EUI score, you will have to sub-meter the energy and exclude it from the benchmarking report.  


Benchmarking MAI Buildings

Manufacturing, Agricultural, and Industrial (MAI) Buildings should benchmark their buildings just like all other commercial and multifamily buildings. If you are using a production efficiency metric for your Alternate Compliance Option, you will need to enter "custom metric" information.


Exemptions exist for some buildings for occupancy, construction, and financial distress. Details for each exemption are included in the form below.  

  • If you believe you qualify for an exemption, you can fill out the 2023 Benchmarking Exemption Form by June 1. Please include a detailed description of why your building qualifies. 

Please note: We will no longer offer exemptions to buildings where energy performance is a confidential commercial practice. You must submit annual benchmarking data, but you can submit a Confidential Data Request so that this information is not made public. 


You should request a demolition exemption for the benchmarking and performance requirements if:

  • A demolition permit has been issued for the entire building, and
  • Demolition work has commenced on or before the date the benchmarking report or next performance target is due.

If you plan to demolish a building within two years after performance requirements are due, you can apply for a timeline adjustment. Use the Demolition Timeline Adjustment application.  

A demolition exemption application would be approved for a building in which: 

  • A demolition permit for the entire building has been issued and for which demolition work has commenced on or before the date the Benchmarking report for the performance period is due
  • A demolition permit for a portion of the building has been issued in which the remaining building will be less than 25,000 sq. ft. This would shift the building to the building performance requirements for buildings 5,000-24,999 sq. ft. 


Data Verification


You will need to verify your data with a third party:

A data verifier can also assist with adjusting your benchmarking report so it is normalized for your building performance targets. The data verifier would make these adjustments to the building’s benchmarking report before signing off on the Data Verification Checklist. You will submit this third-party data verification with your Benchmarking Report.

Your third-party verifier must have one of the following licenses, credentials, or certifications, and be in good standing: 

  • Professional Engineer (PE) issued within the United States 
  • Registered Architect (RA) issued within the United States 
  • Certified Energy Manager (CEM from AEE) 
  • Building Energy Assessment Professional (BEAP from ASHRAE)  
  • Energy Management Professional (EMP from EMA) 

A data verifier CANNOT be:  

  • The building owner or an employee of the building owner; or 
  • The building owner’s designee who prepares or submits information in Portfolio Manager.
  • A designee's employee who prepares or submits information in Portfolio Manager. For example, if a company is hired by the building owner to complete the benchmarking submission, an employee of that company cannot be the third-party data verifier. That company could sub-contract another company to serve as the verifier to make it easier for the building owner to contract this service.

The following licensees can perform third-party data verification on benchmarking they have previously completed for the building owner: 

  • Professional Engineer (PE) issued within the United States
  • Registered Architect (RA) issued within the United States 

You will have to complete the data verification by following these steps:  

  1. Find a third-party data verifier. You can find trained vendors in our Service Directory.   
  2. Follow the instructions in the Data Verification Process Guide(PDF, 608KB)
  3. Turn in the paperwork to Denver Climate Action:
    1. For benchmarking data verification, enter the data verifier’s information inside ENERGY STAR® Portfolio Manager before submitting that year’s benchmarking report
    2. For target adjustments, a signed PDF file needs to be submitted with the application 

We understand that this adds an extra step to your benchmarking process, but it ensures data quality. The Data Verification process will help you complete this step correctly and avoid penalties. 

Still have questions? 

Important guidance for Data Verifiers:

  • Data verification does not require an on-site visit, but it is up to the Data Verifier if they feel confident enough to sign the document without an on-site visit.
  • Building owners can choose to benchmark their building as one property type following EPA guidance, or they may break down high-intensity property types by square footage. Ask the building owner which methodology they followed before verifying the information.
  • For the Indoor Environmental Quality section, Data Verifiers can write in “N/A” for benchmarking report submissions for performance evaluation years. If the data verification is for a target adjustment, the Data Verifier can write in “N/A” if they feel those questions do not apply to the target adjustments requested.
  • We will not be defining a percent accuracy of verified square footage that would trigger the building owner to submit a mandatory target adjustment. If you are uncomfortable with the difference between what you think the square footage of the building is based on documentation compared to what the building owner records in Portfolio Manager, you are in your right to refuse verification of the building. 

Submitting Your Annual Benchmarking Report

  1. Verify or Update your Portfolio Manager Account
    1. Look up your building's Denver Building ID number on our Lookup Tool.
    2. Log into your Portfolio Manager Account and click on the "Details" tab.
    3. Scroll down to the “Unique Identifiers (IDs)” box on the left, click “Edit.”
    4. Within the “Standard IDs” box find “Standard ID- City/Town”. Verify that "Denver Building ID" is selected from the drop-down menu and the number here matches the one you looked up.
    5. If the numbers do not match, call our help desk 


  2. Verify Your Annual Data is Complete  
    1. In the "Energy" tab, verify that all energy data from the previous calendar year (January-January) is there
    2. If data is missing, please enter the missing data
    3. Click over to the "Details" tab. Add any information about your building you'd like to appear in the details we publish for the public
  3. Run Data Checker 
    1. In the "Summary" tab, run the Data Quality Checker
    2. Download the Energize Denver Benchmarking Data Request 
  4. Load the annual Denver Benchmarking Data Request  
    1. See the 2024 Request
  5. Generate and Send your Report to the City
    1. Open the Denver Benchmarking Data Request in your Portfolio Manager account. From there you can generate, preview, and send your response to the city
    2. You will receive a confirmation email from within 24 hours. The letter will let you know that your building is either "In Compliance" or "In Progress"
    3. Your building is not in compliance until you have received confirmation from the city

If you need to submit historical benchmarking information for performance requirement purposes, complete this form

The State of Colorado requires benchmarking for buildings 50,000 sq. ft. or larger under Building Performance Colorado (House Bill 21-1286). In 2024, the process has changed in that you must submit your report in a separate process than Denver’s submission.

Learn More


Data Use and Privacy Statement

The Office of Climate Action, Sustainability, and Resiliency respects your confidentiality. The information we collect is only used and made available for the intended purposes of the program.    

We publish basic building information and energy performance metrics on the Energize Denver map and the Open Data Catalog.  We do not include any personally identifiable information in these data sets. The information we publish includes:  

  • Building ID
  • Benchmarking Compliance Status
  • Building Name
  • Building Address
  • Property type(s)
  • Gross Floor Area   
  • Year Built
  • ENERGY STAR® Score 
  • Weather normalized site EUI
  • Energy Use by Fuel Type
  • Total Greenhouse Gas Emissions 
  • ENERGY STAR® certification years
  • Performance Targets and Years

We may include other information fields relevant for a specific building type. See a full list of the fields that we publish(PDF, 104KB).   

Energize Denver Confidentiality Request

You may request that the city not publish your building data if you can demonstrate that the energy performance in your building is a confidential business practice. We will review your request and determine whether you meet the confidentiality request criteria. If we approve your confidentiality request, we will continue to use and maintain your data internally, but it will not be publicly accessible through the Energize Denver Map or Open Data Catalog.

ln order to submit a request for confidentiality, fill out the Confidential Data Request form. We will need for you to:

  • Identify the specific information you believe to be confidential.
  • Provide a written statement describing how public disclosure would cause substantial harm to your competitive position.
  • We do not consider inefficient energy usage alone confidential commercial information. 

Enforcement and Citation Payment

Denver’s Office of Climate Action, Sustainability, and Resiliency will review your data for quality problems, such as:

  • Energy Alerts from Portfolio Manager
  • Property use detail alerts from Portfolio Manager
  • A reported EUI of less than 10 or more than 500 
  • Portfolio Manager scores of less than 5 or greater than 95 
  • Gross Floor Area significantly different from that in the tax assessor’s records
  • Number of workers, operating hours, or other building use details that are outside of the expected range for your building type

We will reach out to identify and assist in resolving any errors. In years when you are required to send data verification, we do not consider the report to be complete unless you have included the data verification. Reports must have all errors resolved before we can accept the report for compliance.

A maximum civil penalty is permitted under D.R.MC. § 4-9. Buildings not in compliance with benchmarking requirements after June 1 are assessed a penalty of $2,000. If you do not bring the building into compliance or pay the citation within 180 days of the citation notice, the inaction may result in a perpetual lien on the property until the civil penalty owed, delinquent interest, and recording fees have been paid in full.

While we have discretion to issue penalties, our goal is to help you complete your Benchmarking Report every year. There is a lot of help to ensure you complete your report correctly: 

Frequently Asked Questions

How should I benchmark multiple buildings that share a meter?

When several buildings share one energy meter, they should benchmark together as a single building. This will let you take advantage of Xcel Energy’s automatic upload function. They will upload your monthly energy data into Energy Star Portfolio Manager for you. You can then benchmark your buildings at the level that makes sense for your strategy.  

You may have good reasons to benchmark these shared-meter buildings separately. We encourage you to explore your options. You may want to benchmark these buildings separately if:

  • You have separate electric meters but a shared gas meter.
  • One building might have completed an upgrade while the other(s) have not
  • You want to understand the energy performance of each building on its own. 

If you have multiple buildings sharing both electric and gas meters, we urge you to consider sub-metering. This will help you better understand your energy usage. If you do not sub-meter the buildings, you must report the buildings as one account on ESPM. 

If you are benchmarking multiple buildings together because they share a meter, please email This way, we can update our covered buildings list. 

How can I get whole-building data if energy meters are owned by tenants?

Xcel Energy offers monthly auto-upload of utility data into customers' ESPM accounts. For buildings with more than one account holder, Xcel Energy can provide aggregated whole-building data. The data can go straight to the building owner’s ESPM account through the auto-upload service. You don't need to provide additional documentation if: 

  • There are four or more Xcel Energy tenants in the building
  • No one tenant uses more than 50 percent of the building’s total energy

If you meet one of these conditions, Xcel Energy's Energy Benchmarking User Guide can help you set up auto-upload. If your building does not meet the above criteria, you must request customer consent to use auto-upload. If you have access to tenant bills, you can enter monthly energy meter data by hand.  

What can I do if one or more tenants will not release consent?

Start by confirming that you need consent. Consent is required from tenants if: 

  • There are three or fewer Xcel tenants in the building
  • One tenant uses more than 50 percent of the building's total energy

If you need consent and a tenant is refusing to provide it, there are some options: 

  1. Provide more context. The building owner is legally required to benchmark annually. ESPM aggregates the energy use of all tenants to protect privacy. No specific proprietary information is reported. Benchmarking is a widely implemented practice in the United States. It is a proven way to reduce overhead costs related to energy use as well as improve the air quality within a community. 
  2. Share the Ordinance and Rules
  3. Leverage current lease agreement terms. All leases contain basic language requiring tenants to abide by local laws and work with the owner to meet the legal requirements of the building or they could risk eviction.  
  4. Update or establish “green leasing” agreements with tenants to set terms related to data sharing, data access, and or complying with City/State/Federal regulations.  

How can I access meter data if I am not the building owner?

If you are not the building owner, Xcel Energy will need to:  

  • Verify that you have a relationship with the building owner.
  • Get you authorized on the building owner’s Xcel Energy account at the property. This can be done by completing a consent form with the building owner as the customer of record. 

The building owner can also contact Xcel Energy at 1-800-481-4700 and request to add you as an authorized contact.  

Please reach out to the team at for help with your consent form.  

How can I access whole-building data for my condominium building?

Xcel Energy will treat the condominium owner’s association as the property owner in these cases. Ensure the property manager/benchmarker is an authorized user on the Xcel account for the common areas. Consent might be needed by the HOA to release the energy data to the property manager or benchmarker. Please reach out to if you have any questions.

How do I request new or updated energy data to be uploaded into my ENERGY STAR Portfolio Manager meters as an Xcel Energy customer?

In situations where you find the energy data is not up to date, missing data, or includes a meter that does not contain whole building data, please reach out to to address the issue. In your email, describe the issues you are experiencing, provide the property address(es), and the 7-digit ENERGY STAR Portfolio Manager Property ID(s).

How do I correctly enter the number of units in a low-, medium-, or high-rise setting for multifamily properties?

Most multifamily properties are categorized as one of the following: 

  • Low Rise (1-4 floors)
  • Medium (5-9 floors)
  • High (10 floors or more) 

If a building has 11 floors, all units in that building are in a high-rise setting. If a building has eight floors, all units in that building are in a medium-rise setting. The only time a building would have units in more than one setting is if there are two parts of the same building that are of different heights. for example, one section is a high-rise tower and the other section only has three floors. 

How should I benchmark a building with multiple uses, like a strip mall?

Strip malls or mixed-use buildings are generally benchmarked as one building. You should break out the different building types by square footage. You can get aggregated whole-building electricity and natural gas usage data from Xcel Energy. You do not need to collect energy usage information from individual tenants.  

Special considerations for strip malls:  

If one strip mall falls on more than one parcel, as defined by the tax assessor, each parcel should benchmark as a separate building. 

If a driveway divides the strip mall on a single parcel into two distinct buildings, each of those buildings should benchmark separately. 

Individual retail stores within a strip mall may benchmark and report to the city as a separate building if it qualifies for an ENERGY STAR® score. In this case, the rest of the strip mall should still benchmark together. For example, if a grocery store in a strip mall is benchmarking independently, it should notify the owner of the strip mall. This way, the building owner can remove the energy use from the rest of the strip mall’s Benchmarking Report.  

Each building should use its own Denver Building ID. If the city only assigned one Denver Building ID to a property that will now benchmark as two separate buildings, you request an additional Denver Building ID. Call the Building Performance Help Desk at 844-536-4528.  

What energy units do electric and gas meters need to be set to?

Units for electricity are kWh and units for gas are Therms for Xcel Energy gas customers.

How should I enter District Steam and Chilled Water?

If you get district steam and chilled water, Xcel Energy is not currently able to automatically transfer this data to Portfolio Manager for you. District steam and chilled water customers should configure their meters in Portfolio Manager as follows:  

  • District Service, Meter Type, Units 
  • Steam, District Steam, kLbs (thousand pounds) 
  • Chilled Water, District Chilled Water from an electric-driven chiller, ton hours  

Note: Steam is billed by Xcel in Mlbs. This is the English system in which Mlbs means thousand pounds. This corresponds to kLbs in the metric system used by Portfolio Manager. Please make sure you select your units as kLbs in Portfolio Manager. The Mlbs option is metric and means million pounds. Do not select Mlbs in Portfolio Manager! 

If you are a new District Chilled Water customer or are leaving the district system, you must notify the help desk at We will need to add or remove a target adjustment for your 2030 performance target.


How should I enter onsite solar or wind generation?

You will need to create an additional Electric Solar Meter or Electric Wind Meter. Then, you need to enter the production data for that system with that meter. Xcel Energy is able to automatically upload Electric Solar Meter data into Portfolio Manager. The meter should be set up the same way as your other auto-upload meters. They are not are not able to transfer the wind turbine data to Portfolio Manager. Your Xcel Energy billing statements will have the information you need to enter into Portfolio Manager. Xcel Energy will still transfer the electricity you purchased from the grid to the Electric Grid Meter in Portfolio Manager. 

What if I make an error and need to resubmit my building information?

If your building is already in compliance and you realize you made an error in your submission and need to resubmit information, please call the Building Performance Help Desk first at 844-536-4528. We must prepare our system to receive your new data, otherwise it will not register.

How can I find a vendor to help me comply?

You could start with Denver’s list of Service Providers who have taken our training. These individuals have completed our training but have not been pre-vetted on their qualifications.

My property is mixed use and does not fit under one building use. How detailed should I be when entering my use details?

When benchmarking to normalize a building’s EUI target, we recommend entering Building Use Details as specific and granular as possible. Please add each use type that exists in your building, even if those spaces are under 5,000 sq. ft.

See Special Considerations

Watch Benchmarking for Normalized Performance Targets

If you did not previously break out your high-intensity spaces you might need a Target Adjustment. This will ensure your EUI targets accurately reflect your property.  

When is third party data verification required?

You will need to verify your benchmarking data with a third party before submitting it: 

  • In the years in which your performance is evaluated
    • 2024 (or 2025 if you received the timeline extension), 2027, and 2030
    • In adjusted years if we have approved a timeline adjustment
  • If you submit a target adjustment application

Watch Third-Party Data Verification

See Data Verification

The square footage or use details I previously reported were incorrect. What do I do?

  1. First you will want to update your property use(s), use details, and square footage in ESPM. 
  2. Once your property is up to date in ESPM, you will need to resubmit the benchmarking report for the current year and historical years (if applicable). Contact the Help Desk before resubmitting. 
  3. If your property types or square footage details changed from the data used to set your baseline EUI, you will need to submit a target adjustment application so that your targets can be corrected.