Benchmarking Requirements

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Benchmarking Basics

One of the key components of Energize Denver compliance is your annual Benchmarking Report. The city uses this report to verify that you are meeting your interim and final performance requirements. You do not need to submit extra documentation to show compliance.

Completing your Benchmarking Report every year helps you keep track of your energy performance. It will let you easily see whether you are on track to meet your interim and final Performance Requirements. If your current building EUI is higher than your Performance Requirement, you will have to take action to reduce your energy use. Failure to act could result in fines or other penalties from the city.

All large buildings in Denver 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 reporting data available to the public so they can be better informed about energy efficient buildings in Denver. Xcel Energy offers a Benchmarking Services Guide to help you.  

Unsure if your building is in compliance with benchmarking this year? Look-up your Denver Building ID or address in the Performance Requirements Lookup Tool to see if your building(s) still needs to comply.

Need help with your Benchmarking report? See the list of service providers who have taken our Benchmarking Training and completed the comprehension quiz.

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 given in Portfolio Manager 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, as measured 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, look it up in the annual Compliance Status Report.
    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 is designed to benchmark similar property types against each other on a national level by using one property type per building. This is not always appropriate for buildings that mix high-intensity property types with lower-intensity types in an individual building (like strip malls or hotels). You can choose to benchmark your building as one property type following EPA guidance or you may break down high-intensity property types per square footage. When you complete your benchmarking report, if you have high-intensity spaces in your building, you should break out the square footage of each sub-type. 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

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 classification of your building and a possible target adjustment for smaller data center based on what you enter in ENERGY STAR® Portfolio Manager.

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. You will need to include additional information provided in ENERGY STAR® Portfolio Manager if you are using a production efficiency metric for your Alternate Compliance Option.


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. The manufacturing and agricultural (MAI) exemption is not available in 2023. If you have not registered your building for MAI designation, go to our MAI page for more information.  


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 are planning to demolish a building within two years after performance requirements are due, you can apply for a timeline adjustment through 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. 

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 (DBID) number on our annual Compliance Status Report
    2. Log into your Portfolio Manager Account and click on the "Details" tab. Verify that the DBID number here matches the one you looked up in our compliance report. Make sure that it is labeled as a "Standard ID"
    3. 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 2023 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 now requires benchmarking for buildings 50,000 sq. ft. or larger under Building Performance Colorado (House Bill 21- 1286). To learn more visit


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:  

  • Property name
  • Property address
  • Property type
  • Gross Floor Area   
  • Year built
  • ENERGY STAR® Portfolio Manager score 
  • Previous Portfolio Manager scores
  • Weather normalized site EUI 
  • Total greenhouse gas emissions 
  • ENERGY STAR® Portfolio Manager certification years
  • Any notes the owner or property manager submitted to explain building energy performance

We may include other information fields relevant for a specific building type. See a full list of the fields that we publish.   

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.

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: