Introduction
2026 will be a significant year for building energy standards in Washington, DC; it marks the end of the first five-year Building Energy Performance Standards (BEPS) compliance cycle, it is a substantial expansion in the number of buildings reporting energy and water efficiency data, and is the implementation deadline for DC’s net-zero building standard.
In addition to BEPS compliance measurements occurring next year, 2026 is the first benchmark reporting year for all privately owned buildings between 10,000 and 50,000 square feet (sf), and December 31st, 2026 is the implementation deadline for Washington DC’s net-zero building standard or the adoption of Appendix Z of the DC Energy Conservation Code, an existing net-zero standard. Appendix Z includes two key provisions: a ban of on-site combustion of fossil fuels for thermal energy and a requirement for on-site renewable energy generation.
The result – by the end of 2026, buildings greater than 10,000 sf will be reporting energy benchmarking data for the first time, buildings greater than 50,000 sf will have submitted compliance data for Cycle 1 of BEPS, and all new building permits will restrict the use of fossil fuels and require renewable energy generation.
A note – Unless otherwise specified, “buildings” refers to privately owned buildings within the District of Columbia. Government owned buildings either District or Federal are not subject to the same legislation.
Energy Benchmarking for Small Buildings
The first development in 2026 is the new requirement for privately owned buildings greater than 10,000 sf to report annual energy and water efficiency benchmarks, per the Clean Energy Omnibus Act of 2018. Buildings larger than 50,000 sf have been reporting annual energy and water benchmarks since 2013, and buildings larger than 25,000 sf have been reporting benchmarks since 2021. While 2026 simply expands the pool of buildings that must report performance data, more than half of the buildings larger than 10,000 sf in Washington, DC are between 10 and 50 thousand square feet. As a result, 2026 will more than double the number of buildings that report publicly available building energy and water efficiency data.
Benchmark data is a critical foundation for all building energy efficiency initiatives. Without a benchmark month or year, the process of evaluating improvements or changes to a building becomes much harder. Electricity, gas, and water usage bills can be used as a proxy, but are subject to fluctuating rates, peak hours and, in general, are noisier than directly measuring consumption. In addition to evaluating the performance of a building over time, benchmark data is also useful when comparing a building to others of a similar usage. It’s much easier to enforce penalties on poor performing buildings or reward high performing ones with third-party verified, public data available across dozens or hundreds of comparable buildings. Energy benchmark data also has direct value to consumers in a marketplace, allowing individuals and businesses to gauge building performance – and potential utility and improvement costs – before buying or leasing building space.
BEPS Cycle 1 Compliance Deadline
In contrast to the energy benchmarking requirement – which has been established for buildings greater than 25,000 sf – the end of the first BEPS compliance cycle is new territory. As a quick refresher on BEPS compliance – the Cycle 1 standards were established on 1/1/2021. Buildings are required to meet or exceed the median local ENERGY STAR score* for buildings of that property type, as established using 2019 benchmarking data. For example, the standard for office buildings is a minimum ENERGY STAR score of 71 and the standard for multifamily residential buildings is a minimum ENERGY STAR score of 66.
*If a building doesn’t qualify for an ENERGY STAR score, source Energy Use Intensity (EUI) is used as an alternate benchmark. I will largely ignore this scenario in this review.
If a building met or exceeded that median ENERGY STAR benchmark, no further action was required in Cycle 1. However, if a building’s score was lower than the benchmark value, there are four available compliance pathways to meet BEPS requirements.
- Standard Path – Raise building energy performance to meet the benchmark standard
- Performance Path – Reduce site energy usage by 20% as measured by EUI
- Prescriptive Path – Implement one or more recommended energy efficiency measures from the Department of Energy Efficiency (DOEE)
- Alternative Compliance Path – Custom pathway as agreed upon by DOEE and the building owner
The standard and performance path both rely on energy usage benchmark data to measure improvements to building energy performance. For Cycle 1 of BEPS, the measurement period for this benchmark data is 1/1/2026 to 12/31/2026, and data collected over the next year will be evaluated to determine if applicable buildings do or do not comply with BEPS. Functionally, this also means that any improvements or changes to buildings should be completed in the next two months in order to see maximum benefits in the 2026 data.
Given the steep penalties for BEPS non-compliance (fines of up to $10.00/sf), building owners will likely be very conscious of energy usage in 2026. This may result in additional restrictions or requests on tenants, more urgency for maintenance or repair of equipment, and different building conditions – all in the aim of lowering energy consumption.
While results of energy performance won’t be submitted and verified until mid-2027, the data collected in 2026 will influence the perceptions of the BEPS program as we approach the start of Cycle 2 in 2028. If building owners are generally successful at improving the performance of their buildings and DC can tout energy savings, lower utility costs, reduced stress on the electric grid, cleaner air, and other benefits, expect momentum going into Cycle 2. If DC can demonstrate that efficiency requirements do not restrict the economics of building owners, it may also bolster a lagging construction market in the District. On the other hand, if building owners are unsuccessful at meeting the BEPS requirements and instead are subject to compliance fines, as well as the costs of the building upgrades themselves, the BEPS program may face revision – or even cancellation.
DC is already facing unique economic headwinds due to reductions in the federal workforce and the record setting Government Shutdown . These challenges are in addition to broader difficulties affecting the commercial real estate market, such as high inflation, interest rates, and lagging return to office. Given these existing obstacles for building owners, the DC Government may have to be reactive to feedback from building owners, especially in the first year of a new mayoral and council term.
Net-Zero Building Standard
The final update in 2026 slides in under the wire, as 12/31/2026 is the legislative deadline for the mayor to issue regulations regarding a net-zero building standard equivalent to, or more restrictive than, Appendix Z of DC Energy Conservation Code 2017. While the standard wouldn’t go into effect until 1/1/2027, the standard requirements will be defined in 2026. It is likely that DC will not write an entirely new standard for net-zero buildings and will adopt most, or all, of Appendix Z.
Appendix Z supports the design, construction, and operation of net-zero energy buildings through three required approaches.
Reduce Building Energy Demand – The code establishes a maximum energy consumption threshold that is equivalent to 30% of the energy consumption of a baseline building from the benchmark year 2000. Additionally, it establishes a maximum annual heating and cooling demand per square foot of interior conditioned area. Building owners must also commission their buildings and conduct airtightness testing of the building envelope.
Use of Renewable Energy – The most impactful change in Appendix Z is a prohibition of on-site combustion of fossil fuels for thermal energy. It also requires the building and building site to receive 100% of projected annual energy usage from renewable energy sources, with at least 5% of that total consumption provided by on-site renewable energy. For projects using on-site solar energy, a minimum of 25% of total site area must be allocated for photovoltaic array and energy production.
Energy Metering and Reporting – Owners must annually benchmark and report energy and water use performance using the ENERGY STAR Portfolio Manager Tool. Within 24 months of occupancy, owners must submit 12 months of operations data demonstrating that energy consumption is less than or equal to renewable energy associated with the building and building site. Half of this requirement is already covered by the benchmarking requirements discussed above. However, the addition of matching consumption data to renewable generation is a new requirement.
While the final text of the net-zero standard is still unknown (and there is time to delay or loosen these requirements), assume that 2026 is the last year to receive a building permit for a new building or major renovation that does not meet the net-zero standard.
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