Building Performance Colorado is the state program for large commercial buildings. Its annual reporting date, November 1, passed the day before this note went up, and the next one is a year out. That makes now the easiest time to set up the next cycle properly.
This note sets out what the Colorado Energy Office says, in plain terms, and how a multi-site owner can organize around it. It is not legal advice, and it cannot tell you whether a building meets the program’s requirements. Confirm current rules and deadlines with the Colorado Energy Office, and with the City of Denver for any Denver buildings.
What the state says
The Colorado Energy Office says three things that matter for planning (Colorado Energy Office, Building Performance Colorado):
- The program applies to most commercial buildings 50,000 square feet and larger.
- It supports state goals to reduce emissions from the commercial buildings sector by 7% by 2026 and 20% by 2030, compared to 2021 levels.
- Benchmarking reports and fees are due November 1 each year.
Everything else, including which buildings are exempt, how floor area is measured and what each building must achieve, is on the office’s page and in the program rules. Read it there, not in a summary, this one included.
Is a building in scope?
“Most commercial buildings 50,000 square feet and larger” leaves two questions for each property. Is it at least 50,000 square feet? And is it one of the building types the rules include?
For each site, record:
- gross floor area, and the document it came from
- primary use, and any mixed uses with their floor areas
- whether it is one building or part of a connected group
- the owner entity responsible for reporting
Pay close attention to buildings between 45,000 and 55,000 square feet. Two documents that disagree by a few thousand square feet can put a building on either side of the line. Settle on one source, keep the reasoning on file, and use the same source every year.
Reading the 7% and 20% goals
The 7% and 20% figures are goals for the commercial buildings sector as a whole, measured against 2021 levels. They describe where the state wants the sector to go. How that translates into a requirement for a particular building is set in the program’s rules.
So do not apply 7% or 20% to your own building and call it a target. Read the rules for what your building type is asked to do, and by when. If the rules are unclear for a building, ask the Colorado Energy Office in writing and keep the answer.
One practical point does follow from the goals: 2021 is the reference year. If your bill history for 2021 is thin, gather it now, while the utility portals and your own files still have it.
Questions to put in writing
Where the rules leave a building’s situation unclear, ask the Colorado Energy Office directly, in writing, and file the reply with the building’s records. Questions worth asking for a multi-site owner:
- Does this building, at this floor area and use, fall under the program?
- Which floor area measure should we report, and from what source?
- How should a mixed-use building, or a group of connected buildings, be set up?
- Who reports for a building with more than one owner, or with a ground lease?
- What should we do where tenant data cannot be obtained in time?
A written answer is worth more than a remembered phone call, both to you and to whoever takes over the file next year.
Keep every year’s file
Each November 1 leaves a record behind. Keep it: the report as submitted, the fee receipt, the meter data behind it, and any correspondence with the office.
Those files are what let you explain a change in a building’s numbers three years from now. They also answer the first question a buyer, a lender or a new facilities manager will ask about a large building.
When a building changes hands
Buildings are bought and sold mid-year. Before a sale closes, agree in writing who prepares the next report, who pays the fee, and how the meter data and Portfolio Manager property pass to the new owner. Then confirm with the Colorado Energy Office whose name the next report should carry.
November 1, every year
The fixed date is November 1, and both reports and fees are due then, each year. Working backward from it is recommended practice, not a requirement. One workable schedule:
| Weeks before November 1 | Step |
|---|---|
| 16 | Confirm the building list and floor areas |
| 14 | Request whole-building data from utilities |
| 10 | Load meter data into Portfolio Manager |
| 8 | Run data checks and chase gaps |
| 4 | Internal review and sign-off |
| 2 | Submit reports and pay fees |
Check the office’s page for how reports are submitted and how fees are paid. Tenant data requests are usually the slowest step, so start them first. Whole-building data for a building with many tenant meters depends on the utility’s process, and that can take weeks.
Denver buildings may face both
The City of Denver says Energize Denver applies to commercial and multifamily buildings in Denver that are 5,000 square feet and larger (City of Denver, Energize Denver). A commercial building in Denver of 50,000 square feet or more may fall under both programs.
If so, keep one set of records: one building list, one Portfolio Manager property per building, one meter map. Then file to each program on its own schedule and under its own rules. The two programs set their requirements separately, so confirm with both the City of Denver and the Colorado Energy Office how each applies.
Our compliance calendar lays out a year around both programs. Only the November 1 state date is a hard date there; the rest is recommended practice. Our Energize Denver checklist for owners covers the city side.
The data checks that matter
Before submitting, check each building for:
- Every meter has 12 full months, with no gaps and no double-counted bills.
- Estimated reads replaced with actual reads where they exist.
- Consistent units across utilities and fuels.
- Floor area that matches your building list.
- A year-over-year change you can explain in one sentence.
These are the checks good bill auditing uses. A meter missing from the file, or a bill entered twice, changes a building’s number as surely as a new chiller would.
From reporting to planning
A benchmarking report shows where a building stands. The state goals show which direction the state wants the sector to move. The distance between the two is a capital planning question.
For a portfolio with several large buildings, that means deciding which building gets which project in which year. Controls work first at one site, a heat pump retrofit at another, a reroof and solar at a third. The engineering belongs to licensed engineers. The sequence, the budget and the effect on each utility bill can be planned now.
A Portfolio Energy Plan builds that sequence for up to 40 sites over five years, from your bills and benchmarking data.
Where our work stops
Our benchmarking specialists set up Portfolio Manager and prepare filings. Where a program requires third-party verification, a qualified verifier does it, never the person who entered the data.
We do not give legal advice, and we do not tell an owner that a building meets a program’s requirements. That determination belongs to the program. What we can show is that the data in the filing matches the bills, the meters and the floor areas on record.
Where to start
A Benchmarking Filing sets up Portfolio Manager in your name and prepares each building’s annual filing, from $950 per building a year, with verification fees extra. Starting now leaves a full year before the next November 1. Confirm the current rules with the Colorado Energy Office before each cycle.
