State and Local Energy Benchmarking and Disclosure Policy

State and local governments are expanding the practice of benchmarking energy use beyond their own facilities to include nongovernment buildings. Benchmarking and disclosure is a market-based policy tool to increase building energy performance awareness among key stakeholders and create demand for energy efficiency improvements. It represents an effort by policymakers to overcome barriers that prevent the commercial real estate marketplace and public sector institutions from identifying and valuing the energy efficiency of existing buildings.

Benchmarking and disclosure policy applies to public-sector state and local government leaders charged with improving the energy efficiency of both public- and private-sector buildings in their community.

Benchmarking and Disclosure Policy Design

Governments are best positioned to create a common market-based currency for building energy performance. Recognizing this, some local governments have moved to encourage or require benchmarking and performance information disclosure in their own portfolio of buildings and in private real estate markets. State and local governments can start by benchmarking a sample of their own buildings, using the results to develop a more encompassing policy that requires all public buildings to be benchmarked at least annually. Governments can also reach private markets with mandatory benchmarking and disclosure policies and voluntary public-private partnerships, such as energy challenges.


Tools for Benchmarking and Disclosure Policy

A number of benchmarking tools exist today that are used by commercial real estate stakeholders to measure building energy performance. Many of these tools are offered by private companies and nonprofit organizations while some are administered by state and local governments or the federal government. Jurisdictions interested in developing benchmarking and disclosure policy should work with local stakeholders to identify the benchmarking tools that best address policy needs.


Support for Post-Launch Activities

To most effectively earn market acceptance, benchmarking and disclosure policies should be supported with education, outreach, and technical assistance. There is a learning curve with using Portfolio Manager and other benchmarking tools, and it may take more than one cycle before users are proficient in data entry. The many players in the affected markets need repeated opportunities to learn about and become familiar with the concept of benchmarking, new requirements, technical tools, and processes. It is especially helpful if government agencies can facilitate enhanced access to energy data by working with utilities and energy service professionals. Conversely, benchmarking data can be invaluable to utilities in improving existing energy efficiency programs and designing new ones. Providing ongoing support for compliance and quality control can also be vital.


  • Benchmarking Help Center Guide: This guide provides recommendations for establishing a benchmarking help center based on experiences and lessons learned in New York City and Seattle.

  • This hub for global activity in building energy rating and disclosure policy outlines how energy rating works, compares local policies, and provides access to resources on rating and disclosure.

Defining the Scope and Mechanics of Data Collection

Consider what building types will be covered, the ownership type and size of affected buildings, the implementation timeframe, disclosure requirements, and possible exemptions. If you will use specific analytical tools or software, define such technical requirements and how they will be administered and supported. Many of these details are not necessary to enable legislation but can be worked out through agency proceedings.


Quality Assurance/Quality Control and Data Verification

Policy implementers must ensure that benchmarking information and energy ratings meet a high level of quality. Inaccurate or unreliable data undermine the ability of real estate consumers to use benchmarking information to value buildings and compromises other policy goals. When verifying data, consider these aspects:

  • Range checking (energy use intensity against national median values; high or low scores)

  • Expected footprint versus reported

  • Rounded values (square feet and meter data)

  • Space type and facility name comparisons

  • Address confirmation

  • Third-party verification

  • Tool alerts (energy use and space use)

  • Statistical analysis.


Analyzing and Interpreting Results

Analyzing and interpreting benchmarking results facilitates data-driven decision-making for policymakers and program administrators. This analysis is critical to ensure program success by helping decision makers:

  • Understand system-wide building inventory and energy use profiles

  • Quantify data quality and gaps

  • Determine program impacts and validate savings estimates

  • Determine compliance and facilitate enforcement of non-compliance

  • Inform the design, development, implementation, and evaluation of demand-side management programs and other ratepayer-funded programs

  • Use benchmarking as an entry point for recruiting participants for energy-efficiency programs.


Find more tools and resources for analyzing and interpreting results.

Disclosing Results

Making energy ratings and benchmarking information available to the marketplace is the final consideration for policy implementers. Although the mechanics of public and transactional disclosure are very different, the question facing jurisdictions is the same: How can disclosure maximize consumer awareness and market demand for energy efficient buildings?