San Francisco Energy Benchmarking and Audit Ordinance: What Commercial Buildings Must Know

San Francisco’s Push Toward Energy Efficient Buildings

San Francisco continues to lead in urban climate policy with its Existing Buildings Energy Performance Ordinance (EBEPO), a citywide mandate designed to improve energy efficiency and transparency across the commercial building sector. Originally adopted in 2011 and updated in 2021, the ordinance supports San Francisco’s broader climate goals to reduce greenhouse gas emissions and promote sustainable development.

For commercial building owners, understanding the details of this ordinance is essential. The EBEPO requires annual benchmarking of energy usage, periodic energy audits, and targeted improvements to boost building efficiency and performance.

What Is A Building Performance Standard?

A Building Performance Standard (BPS) is a set of legal requirements that mandates energy efficiency improvements in existing buildings over time. These standards are not optional—they’re enforceable by law and require action from building owners.

In San Francisco, BPS policies are implemented through benchmarking, performance assessments, and audit requirements that ensure buildings are operating efficiently and with minimal environmental impact.

Key Elements of San Francisco’s Existing Buildings Ordinance

The EBEPO outlines specific requirements that commercial building owners must follow to remain compliant:

• Annual Benchmarking: Owners must measure and report their buildings’ energy use using ENERGY STAR Portfolio Manager.
• Energy Performance Disclosure: Benchmarking data is submitted to the San Francisco Department of the Environment and shared publicly.
• Energy Audits and Retro-Commissioning: Buildings must undergo energy assessments every five years to identify opportunities for system upgrades and efficiency improvements.
• Compliance Timeline: Reports are due annually by April 1, and audit cycles are determined based on building type and performance.

Who Must Comply With San Francisco’s Ordinance?

The EBEPO applies to non-residential buildings over 10,000 square feet, which includes:

• Office buildings.
• Hotels and hospitality properties.
• Retail and mixed-use facilities.
• Institutional and industrial buildings.

Owners of these properties are required to benchmark energy use and submit their reports yearly. Buildings larger than 50,000 square feet must also complete energy audits and retro-commissioning every five years.

Steps To Ensure Compliance With San Francisco’s Ordinance

1. Benchmark & Report Energy Use Annually

The cornerstone of the EBEPO is annual energy benchmarking, which provides transparency and enables data-driven decisions.

• Use ENERGY STAR Portfolio Manager to measure building energy use.
• Submit benchmarking data to the San Francisco Department of the Environment each year by April 1.
• Keep historical records to track performance trends.

This process not only ensures compliance but also helps identify areas for cost-saving improvements.

2. Undergo Energy Audits & Retro-Commissioning

For buildings 50,000 square feet and larger, the ordinance requires an Energy Efficiency Audit and Retro-Commissioning every five years.

• Audits must be conducted by qualified professionals and follow ASHRAE Level II standards.
• Retro-commissioning involves evaluating and optimizing building systems like HVAC, lighting, and controls.

These efforts reveal inefficiencies and provide actionable recommendations for improvements.

3. Disclose Performance & Improvement Measures

San Francisco mandates that buildings not only benchmark energy use but also disclose their performance. This promotes accountability and aligns with the city’s sustainability goals.

• Benchmarking scores and energy performance are made public.
• Property owners must submit a confirmation of compliance with audit and retro-commissioning requirements.
• Regular updates ensure transparency and progress tracking.

4. Plan & Implement Upgrades

Audit and benchmarking results may highlight the need for system upgrades, such as:

• HVAC optimization or replacement.
• LED lighting retrofits and smart lighting controls.
• Building automation upgrades.
• Insulation and envelope improvements.

Making these improvements can reduce energy costs and boost performance scores, aiding in compliance and long-term savings.

Why Businesses Should Comply With San Francisco’s Ordinance

1. Reduce Operational Costs

Energy-efficient buildings are less expensive to operate. Through audits and upgrades, owners can uncover and resolve inefficiencies that drive up utility bills.

2. Access Incentives & Rebates

Compliant buildings may be eligible for:

• Energy efficiency rebates from utility companies.
• Federal or state tax credits.
• Green building certifications like LEED or ENERGY STAR.

3. Avoid Penalties & Legal Action

Failure to comply with San Francisco’s energy ordinance can result in:

• Financial penalties.
• Legal citations.
• Delays in future permitting or inspections.

Timely compliance helps businesses avoid these risks.

4. Enhance Market Competitiveness

Energy-efficient buildings attract tenants, investors, and buyers. Public benchmarking disclosure means better-performing buildings enjoy increased market value and stronger brand reputation.

Overcoming Compliance Challenges

1. Managing Audit Costs

Audits and retro-commissioning can be costly, especially for large buildings. However, businesses can:

• Use incentive programs to offset costs.
• Phase upgrades over time.
• Prioritize improvements with the highest ROI.

2. Understanding Reporting Requirements

The benchmarking and audit reporting process can be complex. To simplify it, building owners can:

• Use automated energy tracking platforms.
• Work with consultants or energy service providers.
• Stay ahead of the annual April 1 reporting deadline.

3. Adapting To System Recommendations

Audits may reveal outdated equipment or systems in need of overhaul. It’s important to:

• Develop a long-term building performance plan.
• Budget for phased implementation.
• Monitor post-upgrade performance.

Preparing for San Francisco’s Energy Compliance

San Francisco’s Existing Buildings Ordinance is reshaping how businesses manage energy use. To remain compliant, commercial property owners should:

• Benchmark energy use annually using ENERGY STAR Portfolio Manager.
• Complete required energy audits and retro-commissioning.
• Make system improvements based on audit results.
• Submit required documentation and confirm compliance.

By taking a proactive approach, businesses can improve building performance, reduce costs, and contribute to a greener San Francisco.