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City of St. Louis’s Energy Benchmarking Ordinance
City Energy Project
The Benchmarking Process
Benefits of an Energy Benchmarking Ordinance
Benefits to Building Owners
How to Comply
Requesting Utility Data
Violations & Enforcement
Energy Star Portfolio Manager
Determining Applicability & Compliance
Violations & Enforcement
Entering Building Information Questions
Ameren Missouri’s BizSavers
Spire Commercial & Custom Rebates
Energy Star Portfolio Manager Resources
U.S. Green Building Council - Missouri-Gateway Chapter
Ameren Missouri Trade Ally Network
Missouri Division of Energy
Set the PACE STL
City of St. Louis Sustainability
Better Buildings Financing Navigator
Utility Release Forms
Covered Buildings List
Annual Benchmarking Report
What is benchmarking?
Benchmarking means measuring a building’s energy use and comparing it to that of similar buildings. Making this information publicly available will allow owners and occupants to understand how their building’s energy performance compares to that of their peers, as well as identify the extent of the opportunity available for improvement.
How will my building benefit from benchmarking?
By providing information about a building’s energy use and comparing its performance to similar buildings, energy benchmarking empowers building owners, managers, and other stakeholders to make more informed decisions, identify opportunities to improve energy use in their buildings, and save money. Evidence of these benefits is already available: by analyzing data from over 35,000 buildings that Used Portfolio Manager and received an ENERGY STAR score from 2008 to 2011, US EPA found that average energy use declined by 7%. For more benchmarking trends, visit US EPA’s DataTrends Series, found at
Does the ordinance require mandatory improvements, audits or retrofits?
No. This ordinance will help building managers and owners make their own choices about whether and how to save money by becoming more energy efficient.
Energy Star Portfolio Manager
What is ENERGY STAR Portfolio Manager?
ENERGY STAR Portfolio Manager
is a free online tool developed by the U.S. Environmental Protection Agency (US EPA) that allows you to track and assess energy and water use across your entire portfolio of buildings in a secure online environment. With Portfolio Manager, you can calculate the building’s energy performance, compare it with similar buildings and monitor it over time. When you benchmark the building in Portfolio Manager, one of the key metrics you’ll see is energy use intensity, or EUI. Essentially, the EUI expresses a building’s energy use as a function of its size or other characteristics. For most property types in Portfolio Manager, the EUI is expressed as energy per square foot per year. It’s calculated by dividing the total energy consumed by the building in one year by square footage. For many building types, Portfolio Manager calculates the ENERGY STAR rating, which indicates how efficiently buildings use energy on a 1-100 scale, where a score of 50 indicates average energy performance. Buildings with a score of 75 or better are top performers and may be eligible for the ENERGY STAR certification. Some building types are currently not eligible to receive an ENERGY STAR score, but can still benefit from benchmarking, as Portfolio Manager calculates other energy performance metrics such as EUI.
How is the performance of my building evaluated in Portfolio Manager?
Once utility information and basic building characteristics are entered into Portfolio Manager software, the tool calculates the building’s source Energy Use Intensity (EUI) expressed in kBTU per square foot. The EUI is then normalized for local weather patterns using data from the National Oceanic and Atmospheric Administration. If your building falls into one or more of the 15 building categories, then Portfolio Manager will automatically compare the normalized EUI to the national dataset of that category or mix of categories. Your building then receives a score between 1– 100. A score of 50 indicates your building is performing at the national average for that building type. A building with a score of 80, however, performs in the top 20th percentile of buildings in its category. A score of 35 would indicate a building within the bottom 35th percentile of energy performance nationwide. As mentioned, building performance scores are not available for all building types.
How do I access and use Portfolio Manager?
Portfolio Manager is free and easily accessible at EPA’s energy benchmarking site
. The easiest way to get started is to download the Portfolio Manager Starter Kit. Once you have reviewed the guidelines it is easy to log on and open an account. If you are new to Portfolio Manager, it is best to take a live or recorded webinar training for Portfolio Manager before starting actual benchmarking. You can access the training section of Portfolio Manager by going to
How do I create a Portfolio Manager Account?
Click here to create a Portfolio Manager account
and go to the "Create a New Account" button on the homepage. You will then fill out an Account Information form and complete the requested information, and your account will be created!
What is the difference between LEED and ENERGY STAR?
ENERGY STAR is a U.S. Environmental Protection Agency (EPA) program that focuses on improving energy performance in buildings as a method of reducing greenhouse gas (GHG) emissions. Leadership in Energy and Environmental Design (LEED) is a green building certification offered by the nonprofit U.S. Green Building Council (USGBC).
ENERGY STAR is a technical assistance and recognition program that offers owners and managers of All buildings access to free tools and resources to help them evaluate their energy performance and reduce energy use and GHG emissions. Organizations are encouraged to begin by benchmarking the performance of their buildings using ENERGY STAR’s Portfolio Manager online energy tracking tool. For certain types of buildings that perform in the top 25% compared to their peers nationwide, the ENERGY STAR label is available as an indicator of superior energy performance. Buildings carrying the ENERGY STAR label consume on average about 35 percent less energy than their non‐ENERGY STAR counterparts. The ENERGY STAR label is not automatic; to earn an ENERGY STAR label, building owners must apply to EPA by submitting a Statement of Energy Performance, validated by a Professional Engineer or Registered Architect. St. Louis is NOT requiring any buildings to become ENERGY STAR labeled.
LEED is a building certification process that looks at various aspects of “green building” and awards recognition to buildings that meet certain standards. Users of the LEED process earn credits in several categories associated with green buildings. These differ by the type of LEED certification, but generally include: sustainable sites, water efficiency, energy & atmosphere, materials & resources, indoor environmental quality, and innovation. While each category may have required prerequisites that must be met, for the bulk of the credits required for certification users can choose in which categories they wish to focus based on their own priorities. Energy efficiency may or may not be one of those priorities, depending on the user. It is possible for a LEED‐certified building to use energy very inefficiently; this is particularly true of older LEED‐buildings, as USGBC has started to require buildings seeking certification to meet a minimum energy performance standard in addition to having enough credits overall.
I am purchasing green power generated and delivered by my local utility. Will this improve my 1-100 score?
No. The ENERGY STAR rating is a measure of the thermodynamic performance of your building, which is determined by the amount and type of fuel your building consumes. The rating is designed to reflect the energy efficiency of the building, not the efficiency of the utility (or source) supplying energy to your building. Each fuel in Portfolio Manager is assigned one national source-to-site factor, which does not provide either a credit or a penalty to a building due to efficiency of the local grid. This provides an equitable evaluation of the building’s performance relative to the national building stock.
Determining Applicability & Compliance
Is my building required to benchmark, and what are the deadlines for reporting?
All municipal, institutional, commercial and multifamily buildings equal to or greater than 50,000 square feet will be required to report benchmarking data to the City of St. Louis on a yearly basis. The compliance deadline for private buildings is May 1 annually. Below is a timeline for the initial reporting phases. All buildings will fall into 2 groups of cover properties:
“Group 1 covered property” means a covered property:
That is a building that is greater than or equal to 50,000 gross square feet in total combined floor area; and
That is owned by the City; or
For which the City regularly pays all or a majority of the annual energy bills.
“Group 2 covered property” means a covered property, other than Group 1 covered property,
That is a building that is greater than or equal to 50,000 gross square feet in total combined floor area; or
That has a building that is held in the condominium form of ownership that is governed by the same board, and that is greater than or equal to 50,000 gross square feet in total combined floor area.
The program is phased in by building ownership:
All municipal buildings of at least 50,000 square feet must comply no later than December 31 of each year.
Owners of non-municipal buildings (institutional, commercial, & multifamily residential) of at least 50,000 square feet must comply no later than May 1 annually.
Are there exemptions and/or extensions mentioned in the ordinance?
The Commissioner may grant an extension of the benchmarking submission date or an exemption from the benchmarking requirements to the other of a covered property that submit a request, together with documentation, in a form prescribed by the Commissioner’s rule, at least 30 days prior to any benchmarking submission deadlines, establishing any of the following criteria:
Building is under the minimum 50,000 square feet size threshold for gross floor area.
A demolition permit was issued during the prior calendar year, provided that demolition work has commenced and energy-related systems have been significantly compromised.
The owner is unable to benchmark due to the failure of either a utility or a tenant (or both) to report the information necessary for the owner to complete any benchmarking submittal requirement.
Due to special circumstances unique to the applicant’s facility and not based on a condition caused by the actions of the applicant, strict compliance with provisions of this ordinance would not be in the public interest.
Building is owned by the State of Missouri or the federal government.
Building had arrears of property taxes or water or refuse charges that resulted in the property’s inclusion, within the prior two (2) years, on the city’s annual tax lien sale list.
Building had a court appointed receiver in control of the assets due to financial distress.
Building is owned by a financial institution through default by the borrower.
Building has been acquired by a deed in lieu of foreclosure.
Building has a senior mortgage subject to a notice of default.
The property is primarily used for manufacturing or other industrial purposes for which benchmarking results would not meaningfully reflect covered property energy use – characteristics due to the intensive use of process energy.
Building is a Group 2 covered property and all or substantially all of the property is used for communications infrastructure.
The property does not have a certificate of occupancy or temporary certificate of occupancy for all 12 months of the calendar year being benchmarked.
The building had average physical occupancy of less than 50 percent throughout the calendar year for which benchmarking is required.
Any owner requesting such an extension or exemption shall provide the Commissioner any and all documentation request to substantiate the request or otherwise assist the Commissioner in the extension or exemption determination. Any extension or exemption granted shall be limited to the benchmarking submission for which the request was made and shall not extend to past or future submittals
Violations & Enforcement
What happens if a building owner fails to comply?
Any person who fails to comply with any benchmarking information submittal requirement mandated by this article or misrepresents any material fact in a document or report prepared as required by this article shall result in the following:
A written warning shall be issued by the Commissioner to an owner who fails to submit any required benchmarking information. Such warning letter shall be effective on the date of issuance and shall be mailed to the owner’s last known address as determined by county record.
In the event required benchmarking information is not reported within sixty (60) days of the date the written warning is issued, said failure shall constitute an offense and shall be punishable, upon conviction, by a fine of not less than $50.00 and not more than $200.00. For any continuing violation of this article, each day of the violation shall be considered a separate offense. In no event shall the cumulative fine imposed hereunder exceed $1000.00 annually.
To view SECTION SIX: Violations & Enforcement in the ordinance, click here to download a PDF:
*Buildings not in compliance with the ordinance would NOT be eligible for issuance of new residential or commercial occupancy permits*
Entering Building Information Questions
What building information do I need to collect?
Portfolio Manager requires basic building information, including:
Year built, occupancy level, and total gross floor area (including any parking areas that consume energy).
Primary function, gross floor area, and property use details for each specific space use (including weekly operating hours, number of computers, percent heated / cooled, etc). Find a list of required information by building type in the
Portfolio Manager Data Collection Worksheet
St. Louis Building ID: a seven-digit number found by clicking on the “
” button located on the homepage of this website.
Potential sources of this information include building management and operations staff, architectural drawings and other building documents, direct measurements or – as a last resort – tenants or other occupants.
HOW DO I BENCHMARK A BUILDING THAT ISN'T INDIVIDUALLY METERED?
The City of St. Louis has provided additional guidance for properties that contain multiple buildings that share water and energy meters
Occasionally, buildings aren't individually metered; one energy or water meter may measure the usage of several buildings. In this case, these buildings should be benchmarked together as a campus, following instructions outlined in ENERGY STAR Portfolio Manager’s
Campus Benchmarking Guide
. In some cases, buildings not covered by the ordinance may be benchmarked with the buildings that are covered by the ordinance. For example, if one building covered by the ordinance (such as a building over 50,000 square feet) shares energy-consuming systems with a building not covered by the ordinance (such as a building less than 50,000 square feet), both buildings should be benchmarked together as a campus.
If separate buildings are sub-metered, or if it’s possible to make reasonable calculations / assumptions to allocate energy use to each individual building, the buildings may benchmark and report separately.
If you are benchmarking and submitting multiple buildings together as a campus, contact
to confirm that your St. Louis Building ID is associated with the correct property or properties.
HOW DO I BENCHMARK GREEN POWER THAT IS GENERATED ONSITE?
Properties that generate green power onsite with solar PV or wind turbines should refer to
How to Benchmark Green Power Generated Onsite (PDF)