Performance Requirements - Buildings 25,000 sq. ft. and larger

The Energize Denver ordinance(PDF, 985KB) establishes energy use intensity targets for buildings over 25,000 sq. ft.

Energize Denver will provide over $1 billion in benefits to the City through avoided social cost of carbon, which is the cost of the damages created by carbon dioxide emissions, while providing co-benefits such as improved local and indoor air quality and reduced energy bills. As the buildings improve their energy use and lower the cost of operations, Denver will become a more competitive, attractive city for businesses and residents. As outlined in the FAQs below, the compliance pathways are flexible enough for building owners to choose the method that best suit their needs and budgets. 

Feedback Sessions

The Energize Denver team is holding multiple feedback sessions in late June and early July 2022 to present the draft performance requirements processes and procedures and gather feedback from our stakeholders. The sessions have been broken into 2 parts, with different topics covered in each part, and each part given multiple times. The sessions will not cover benchmarking or data correction, or small building and electrification requirements. Click on the links below to sign up for one of the sessions. 

Part 1: Asset Score and energy audit minimum requirements, target adjustments, timeline adjustments

Part 2: Asset Score and energy audit minimum requirements, data centers, prescriptive option, solar credit

 

FAQs – Overview, Applicability, Performance Requirements, and Penalties

What are the Energize Denver Performance Requirements for buildings 25,000 square feet and larger? 

Buildings 25,000 square feet and larger must meet long-term energy performance targets by 2030. A performance target has been set for each building type. Every individual building will have its own trajectory to achieve the target for its building type, with binding 2024 and 2027 interim targets. Energy performance targets are Weather Normalized Site Energy Use Intensity (EUI) targets specific to different building types (e.g., multi-family housing, office, hotel, medical office, retail store, etc.).  

 

Do I need to comply with both the Performance Requirements and the Green Buildings Ordinance?

Yes, buildings over 25,000 square feet are required to comply with both ordinances. Energize Denver Performance Requirements are ongoing performance requirements for existing buildings. The Green Building Ordinance is triggered by roof replacement, at which time buildings have a number of options to comply. Please visit the Green Buildings Ordinance site for more information.

 

When does a new building become an existing building?

After the building is constructed and has been in operation for 12 months in one calendar year (e.g., a building that received its certificate of occupancy in June 2022 would become an existing building, and would have to submit its first benchmarking report by June 1, 2024).

 

Are new buildings required to comply with the Energize Denver requirements?

Once a new building becomes an existing building, it will be required to comply with the Energize Denver requirements. New buildings coming in under Denver's current building code should easily be performing at or below the target EUI because Denver’s building code is designed to at least meet the 2030 targets.

 

How do I comply with the Performance Requirements? 

Owners of buildings 25,000 square feet and larger will demonstrate compliance with the energy performance targets by continuing to submit their annual Energize Denver Benchmarking Report. The submission reports the building’s annual energy performance and will be used to verify that interim and final energy performance targets are met. Building owners do not need to submit additional documentation to show compliance. 

Building owners will need to monitor their energy performance to ensure they are on track to meet their interim and final energy performance targets and take necessary actions to improve their energy performance. Buildings must be performing at or below their interim target EUIs in each interim target year (i.e., 2024 and 2027) and maintain performance each year until the next target is due. Below is a sample timeline of the compliance process.  

3 timelines in one.jpg   

15% of buildings in Denver already perform better than the final targets so these high performers will only have to maintain their current performance and continue to submit annual benchmarking reports to comply with the Energize Denver ordinance. 

 

What is the energy performance target for my building? 

CASR published final 2030 site energy use intensity (EUI) targets by building types as part of the rulemaking that was finalized in the public hearing on January 13, 2021. CASR will set interim targets for each building and notify building owners by mail and email in March 2022.  

15% of buildings in Denver already perform better than the final targets, so these high performers will only have to maintain their current performance and continue to submit annual benchmarking reports to comply with the Energize Denver ordinance. 

 

What is Energy Use Intensity (EUI)? 

Energy Use Intensity is a measure of your building’s total energy usage, measured in kBtu, divided by its square footage. It is a standard metric that enables a comparison of different sized buildings. The more energy efficient a building is, the lower its EUI will be. For example, an office building with an EUI of 35 performs better and is more efficient than an office building with an EUI of 90. 

The energy performance targets were created using Weather Normalized site EUI measurements, meaning energy use is measured as energy consumption on-site, during 30-year average weather conditions.  A building’s EUI will be calculated and displayed in the building owner’s ENERGY STAR® Portfolio Manager® Account, which is the platform used to submit the annual Energize Denver benchmarking report.  

The following image visually demonstrates how EUI is calculated:

Site Energy Use Intensity (EUI) graphic.jpg

How were the energy performance targets determined? 

CASR conducted an analysis of all benchmarked buildings in Denver and reviewed national EUI data available through the 2012 Commercial Building Energy Consumption Survey (CBECS) to determine a list of building types and target EUIs for each building type in the City.  

For 30% energy savings to be achieved across all large buildings in the City, all large buildings in the City must perform at the same efficiency as the 15th percentile performer. The 15th percentile performer means that 85% buildings in that building type use more energy per square foot.  

For building types with 25 or more buildings in the 2019 Denver Benchmarking data set, the EUI target was set based on the 15th percentile weather normalized EUI for that building type.  

For building types with fewer than 25 buildings in the Denver Benchmarking data set, 2012 CBECS data was utilized to determine the target EUI. To set the target EUI for these buildings, a 30% savings rate was applied to the regionally adjusted 2012 CBECS Median EUI for each building type.  

For a more in-depth explanation, review the Building Typology and EUI Targets methodology(PDF, 327KB)

 

How were the baseline and interim targets established? 

CASR has calculated baseline EUIs for each covered building based on 2019 benchmarking data. Notices will be sent out in March. CASR will establish interim targets for 2024 and 2027 by drawing a straight line from a building’s 2019 baseline EUI to the final 2030 EUI target for that building type. This ensures that the EUI reduction between each target is gradual. For example, if your baseline EUI is 100 and your final target EUI is 48, you need to reduce your building’s EUI by a total of 52 (or 52%) by 2030. At each interim target you would need to reduce your building’s EUI to a specific level. Buildings must maintain interim targets each subsequent year, and must maintain the final energy performance target indefinitely. Please see the “EUI Target Example” drop-down for an illustrated example.

 

How does the policy affect buildings that are campuses?

For campuses, compliance has to be achieved for every building (unless the buildings are metered together and therefore cannot be separated). Of note, renewables owned on-site can be allocated or distributed to any building as needed to bring the campus as a whole into compliance. If there are individual buildings for which it is not possible to reach the EUI targets due to inherent characteristics of the building, then there will be alternative compliance options to adjust the targets or timelines for compliance by individual buildings.

 

How does the policy affect historic buildings?

In most cases, a building’s historic status does not interfere with its ability to meet the energy performance requirements. See below for a graphic demonstrating this concept. CASR may approve an alternate compliance option for these buildings, same as any other building.

ENERGY STAR by building age.PNG

 

What is the City doing in municipal buildings to comply with Energize Denver requirements?

The City is developing detailed plans to bring all City buildings into compliance so that we can lead by example.

 

Will my targets associated with the Building Performance Policy be publicly disclosed?

Building energy benchmarking information is publicly available now through the Energize Denver Map and Denver’s Open Data Catalog. The Map will be updated to reflect Site EUI and targets more clearly in 2022.

 

Why do different building types have different EUI reduction targets?

Some building types have higher EUI targets because their operations require more energy per square foot than others. For example, a laboratory uses significantly more energy per square foot than an office building. A more energy-intensive building will have a different EUI target based on the energy intensity required for the operations conducted in the building.

 

If the building changes ownership, which owner is responsible for meeting the goal?

The owner of the building at the time of each compliance deadline is responsible for complying with the Performance Requirements. If a covered building is sold, its compliance status will transfer to the new owner.

According to 10-404(e) of the municipal code, “Disclosure upon sale. The owner of a covered building shall disclose the covered building's compliance status, including all performance targets, any approved alternate compliance pathways, and any penalties assessed, to a prospective buyer prior to the sale of the building. The owner shall disclose to all prospective buyers the covered building's compliance status in all documentation or advertising concerning the sale of the covered building including, but not limited to, any listings, notices, advertisements of sale, term sheets, and contracts of sale.”

 

How can heat pumps lower my building’s EUI? 

Heat pumps move heat instead of creating it, achieving 200-300% better efficiency. Depending on the type of existing heating in your building (rooftop unit, furnace, boiler, PTAC, etc.) and on the type of heat pump installed, the EUI of the building will be reduced 5-30%. Replacing rooftop units and furnaces with heat pumps will result in the greatest EUI reduction (24-30%). Heat pumps can also replace water heaters. For example, replacing a gas water heater with a heat pump water heater can reduce EUI by up to 15%. Heat pumps are often similar in cost to comparable gas systems, with the added benefits of reduced EUI, lower gas bills, and improved indoor air quality. 

 

How does CASR plan to update the policy to account for changes in technology over time?

CASR is committed to performing a review of the technology landscape every four years. This will allow us to determine whether any adjustments are required to account for changes in technology within this ordinance. CASR may also make adjustments to the policy based on implementation and stakeholder feedback.

 

What is the penalty for not complying with the Energize Denver Performance Requirements or not reaching an energy performance target? 

CASR is committed to supporting building owners in their efforts and exploring the flexibility that alternate compliance options can afford. Buildings that do not achieve the EUI Targets could be subject to penalties based on kBtu reduction not achieved. 

FAQs – Alternate Compliance Options (ACOs)

Are there options for owners of buildings that might have difficulty meeting the energy performance targets?  

If a building cannot reasonably meet interim or final energy performance targets, an owner may apply for an alternate compliance option. Alternate compliance options will be available for the following reasons.  

  • Different compliance timeline: Owners may apply for a different compliance timeline if capital improvements will be most cost effective if they wait until end of system life, the time of a major renovation, or other similar reason.   
  • Different compliance timeline for under-resourced buildings: The owner of an under-resourced building with limited access to capital may apply to adjust the timeline to coincide with refinancing of the building or other similar reasons.  
  • Target adjustment: A building owner may apply to adjust the building’s target EUI due to a few specific reasons, such as the inherent characteristics of the building that make achieving the target challenging, a substantial change in the use of the building (e.g., a new data center or 24-hour call center moved in), or some other significant variations in operations of the building. To adjust the target, you must submit an application that includes the proposed final energy performance target EUI based on an analysis or energy model from a professional engineer. The application must include a narrative explaining why the building cannot meet the target assigned to its group and why the new target represents the maximum energy performance, from energy efficiency and solar on-site or off-site, possible for the building. 
  • Prescriptive: Building owners may apply to take a prescriptive option that is available for buildings 25,000 – 100,000 square feet. This option requires electrification of at least 70% of heating and water heating equipment and replacement of all lights in the building with LEDs. The prescriptive option only satisfies the requirement of meeting the 2024 and 2027 interim targets. A building that chooses this option will still be required to meet its final 2030 EUI target. When a building chooses the prescriptive alternate compliance option, it is estimated that a 25-35% energy savings will be achieved, helping the building reach its final 2030 target.
  • Manufacturing/Agricultural: This designation applies only to a facility where the majority of energy is utilized for manufacturing, agriculture, or for other industry-type process loads. Buildings used mainly as distribution centers and warehouses DO NOT qualify. CASR will develop rules for these buildings with manufacturing and agricultural stakeholders by December 1, 2023.  

If a covered building owner cannot reasonably meet one or more of their interim or final energy performance targets, then the owner of a covered building may apply for an alternate compliance option. Applications will be reviewed by CASR on a case-by-case basis. More information on minimum requirements to apply for an alternate compliance option and how to apply will be available in late Spring 2022. 

FAQs – Solar, Renewable Energy

Does solar energy generation count towards my performance target?

Yes, any solar power generation on-site or off-site will be fully credited towards energy use, effectively lowering your building’s EUI. The building owner must submit proof of solar generation and include solar energy usage in the benchmarking report. Of note, renewable energy credits (RECs) are not subtracted from your EUI. This is because generating new renewable energy capacity, and not buying into existing capacity, helps to further reduce emissions from buildings.

 

Do other types of renewable like geothermal or wind count towards compliance?

Not at this time. Though, geothermal is likely to help lower the EUI of a building through efficient heating and cooling. 

FAQs – Financing, Incentives, and Assistance

What assistance will be available to building owners?  

The Energize Denver Hub staff are available to serve as a one-stop shop to help you understand the Energize Denver requirements and provide extensive compliance support for building owners and managers. The Hub will also provide advanced technical support for under-resourced buildings mid-2022, and in late 2022 begin providing incentives for electrification. 

 

Are there any incentives or rebates available for energy efficiency upgrades?

Please see Xcel Energy’s website for current incentives and rebates that they offer. CASR is currently developing additional incentives and rebates for electrification.

 

Are there any financing options available for energy efficiency upgrades?

Please see Colorado’s Commercial Property Assessed Clean Energy (C-PACE) website for one type of financing option.

 

How can building owners get started?  

  • Understand your building’s current and historic energy usage in ENERGY STAR® Portfolio Manager®  
  • Go to the Energize Denver Hub  
  • Check available rebates from Xcel Energy
  • Get an on-site energy audit to understand areas of improvement  

 

What assistance will be available to building owners? 

The Energize Denver Hub (Hub) staff will be available in mid-January to serve as a one-stop shop to help you understand the Energize Denver requirements and provide extensive support for building owners and managers with compliance. The Hub will also provide advanced technical support for under-resourced buildings and in late 2022 begin providing incentives for electrification.

 

Still have questions?

The Energize Denver Hub is available to support building owners and managers through the compliance process. The Hub provides assistance via phone calls, emails, or scheduled phone appointments for more in-depth walkthroughs with the use of screen share technology.

 

Energize Denver Hub

Operating Hours: 8am-5pm MST, Monday through Friday

Phone: (844)-536-4528

Email: energizedenver@denvergov.org

To schedule a phone appointment with the Hub, please click here.

EUI Targets

What are the energy performance targets for buildings 25,000 square feet or larger? 

The 2030 site EUI targets for all building types are listed below. CASR will notify building owners of the interim targets in compliance letters that will go out in March 2022.  

15% of buildings in Denver already perform better than the final targets so these high performers will only have to maintain their current performance and continue to submit annual benchmarking reports to comply with the Energize Denver ordinance. 

EPA Portfolio Manager Building Type

Target weather normalized site EUI (kBtu/sq.ft./yr)

Adult Education

37.2

Ambulatory Surgical Center

60.7

Aquarium

30% EUI Reduction

Automobile Dealership

42.8

Bank Branch

63.6

Bar/Nightclub

86.6

Barracks

46.3

Bowling Alley

50.5

College/University

60.6

Convention Center

30% EUI Reduction

Courthouse

51.2

Data Center

30% EUI Reduction

Distribution Center

25.4

Drinking Water Treatment & Distribution

30% EUI Reduction

Enclosed Mall

45.6

Energy/Power Station

30% EUI Reduction

Fast Food Restaurant

311.3

Financial Office

48.3

Fire Station

45.6

Fitness Center/Health Club/Gym

50.5

Food Sales

144.3

Food Service

76.9

Hospital (General Medical & Surgical)

165.2

Hotel

61.1

Ice/Curling Rink

30% EUI Reduction

Indoor Arena

53.2

K-12 School

48.0

Laboratory

153.9

Library

52.9

Lifestyle Center

66.6

Mailing Center/Post Office

46.5

Medical Office

69.0

Movie Theater

53.2

Multifamily Housing

44.2

Museum

30% EUI Reduction

Non-Refrigerated Warehouse

27.2

Office

48.3

Other

49.2

Other - Education

37.2

Other - Entertainment/Public Assembly

53.2

Other - Lodging/Residential

51.3

Other - Mall

60.3

Other - Public Services

49.2

Other - Recreation

50.5

Other - Restaurant/Bar

194.1

Other - Services

34.6

Other - Specialty Hospital

165.2

Other - Technology/Science

49.2

Other - Utility

30% EUI Reduction

Outpatient Rehabilitation/Physical Therapy

60.7

Parking

30% EUI Reduction

Performing Arts

53.2

Personal Services (Health/Beauty, Dry Cleaning, etc.)

34.6

Police Station

45.6

Pre-school/Daycare

38.9

Prison/Incarceration

83.0

Refrigerated Warehouse

63.9

Repair Services (Vehicle, Shoe, Locksmith, etc.)

32.3

Residence Hall/Dormitory

46.3

Residential Care Facility

63.3

Restaurant

194.1

Retail Store

43.5

Roller Rink

50.5

Self-Storage Facility

7.7

Senior Care Community

63.3

Senior Living Community

63.3

Social/Meeting Hall

33.0

Stadium (Closed)

75.3

Stadium (Open)

75.3

Strip Mall

66.6

Supermarket/Grocery Store

164.4

Swimming Pool

30% EUI Reduction

Transportation Terminal/Station

75.3

Urgent Care/Clinic/Other Outpatient

60.7

Veterinary Office

60.7

Vocational School

37.2

Wastewater Treatment Plant

30% EUI Reduction

Wholesale Club/Supercenter

43.5

Worship Facility

42.1

Zoo

30% EUI Reduction

 

Mixed-use buildings will have a blended target based on the percentage of gross floor area assigned to each building type. Owners of mixed-use building will be notified of their interim and final targets in the compliance letters that will go out in March 2022. 

EUI Target Example

To help buildings progress towards their final 2030 performance targets, required interim targets have been set for 2024 and 2027. 15% of buildings in Denver already perform better than the final targets so these high performers will only have to maintain their current performance and continue to submit annual benchmarking reports to comply with the Energize Denver ordinance. The graphic below shows an example in the Office building type.

EUI targets and maintenance.png

The Office building type has a final 2030 EUI target of 48.3. While each building will need to achieve a final EUI of 48.3 by 2030, building that currently have an EUI less efficient than the 2030 target will need to take action.

  • Office A has a baseline EUI of 100 and a final target EUI of 48. The building will need to reduce its EUI by a total of 52 (or 52%) by 2030. At each interim target, the building would need to reduce its EUI to a specific level. Buildings must maintain interim targets each subsequent year, and must maintain the final energy performance target indefinitely. 
  • Office B (not in the chart) currently has an EUI of 45. It will need to maintain an EUI more efficient that 48.3 to stay in compliance. 

Data Corrections

My building’s square footage or use type is wrong. How do I fix this?

CASR will review claims that a building has been incorrectly designated on a case-by-case basis. If it is found that a building type has been incorrectly assigned, CASR will reassign the building with an accurate building type and the building owner will have the opportunity to verify this new building type. CASR has the final authority in these cases. Please fill out the data correction form on the Forms page.

My building is new. What is my baseline EUI?

For new buildings, the baseline will be the predicted EUI that was submitted as part of energy code compliance. If no predicted EUI was submitted, CASR will establish a reasonable baseline based on the building type. 

 

My building did not benchmark in 2019. What is my baseline EUI?

For existing buildings that did not benchmark in 2019, the building type was assigned through research and a 2019 baseline was established by using the median EUI in Denver for that building type. If you would like to correct the absence of data so that CASR can assign a more accurate baseline and interim targets, please fill out the data correction form on the Forms page.

Background Information

The Energize Denver Performance Requirements were passed by the Denver City Council on November 22nd, 2021 and are based on recommendations from the Energize Denver Task Force.

Energize Denver Task Force Recommendations

Energize Denver Ordinance(PDF, 985KB)

Energize Denver Rules and Regulations(PDF, 522KB)

The Energize Denver Performance Requirements began with the formation of the Energize Denver Task Force. The City charged this diverse group with designing a building performance policy for Denver that improves health and equity, creates jobs, and brings existing buildings to net zero energy by 2040. The group reached full consensus on their recommendations to the City. The task force included representatives of offices, apartments, condos, warehouses, hotels, Xcel Energy, energy producers, affordable housing, tenant and non-profit experts, labor unions, and environment and clean energy experts. They started their process by setting guiding principles for the outcomes of their work including that it be equitable, implementable, effective, flexible, and achieve eager compliance. They met 8 times over 8 months. They built on best practices and lessons learned from other cities. They engaged with their own communities to get input on their work, and collected broader input from the community. 

Using the recommendations given by the task force, the Energize Denver performance requirements were created as a bold yet practical way to move Denver and its built environment forward in its climate goals. 

Colorado State Benchmarking and Performance Requirements

Colorado State Benchmarking Requirements

New in 2022, the State of Colorado now requires buildings 50,000 ft2 and larger to submit benchmarking data through the Colorado Energy Office and pay a $100 annual filing fee. The 2022 filing deadline is December 1st; each subsequent year, the filing deadline will be June 1st. If you benchmark in Denver, the City will pass along the submitted benchmarking report, but the building must go to www.buildingperformanceco.com to pay the fee to be considered compliant at the state level.

Email benchmarking@buildingperformanceco.com with questions on the state requirements. 

 

Colorado State Performance Requirements

The State of Colorado is developing its own Performance Policy (Colorado House Bill  21-1286) which applies to buildings
50,000 square feet and larger. The State Task Force is developing the performance standards to reach a minimum of 7% greenhouse gas (GHG) savings by 2026 and 20% GHG savings by 2030 across covered buildings. Please visit www.buildingperformanceco.com for more information.