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 this year? Look-up your Denver 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. We update this report every Monday.

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. 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). When you complete your benchmarking report, 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

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 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 property and enter 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 the energy use is on the main meter and not sub-metered, you will have to include the energy from the charging station.
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.  


Exemptions exist for some buildings for manufacturing and agricultural processes, low 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 Benchmarking Exemption Form by June 1 each year. 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.

Data Verification

When you submit your Benchmarking Report for calendar years 2024, 2027 and 2030, or if you submit a target adjustment application, you will need to verify your data with a third party. 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)  

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. 

You will have to complete the data verification by:  

  1. Generating a Data Verification Checklist within ENERGY STAR® Portfolio Manager (ESPM)
  2. Following the ESPM directions
  3. Having a third-party data verifier confirm the information.  

You can find a sample of a Data Verification Checklist on the “Reporting” tab within ESPM. If the building is already ENERGY STAR® Certified for the calendar year requiring data verification, if the time frame overlaps by six months or more, then the submission can be the verified application.

Once you complete the data verification, you should keep the signed checklist on file. You will need to enter the information into ESPM by going to the Details tab and clicking on “add verification information.” The form will ask for: 

  • The calendar year of the verified data
  • The date of verification
  • The name of the verifier
  • The verifier’s professional designation.  

Once the form is saved in your ESPM account in 2024, the information will be submitted to the Office of Climate Action, Sustainability and Resiliency with your benchmarking submission. You will need to update this form for 2027 and 2030.

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

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 2022 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 buildings 50,000 ft2 and larger to submit benchmarking data (by December 1st each year) through the Colorado Energy Office and pay a $100 annual filing fee. If you benchmark in Denver, the City will pass along the submitted benchmarking report, but you are still required to go to to pay the fee to be considered compliant at the state level. Email <" href="" target="_blank" rel="noreferrer noopener"> with questions on the state requirements.

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: