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DC BEPS compliance

DC BEPS, from where you stand today to a filed plan.

Buildings 50,000 sq ft and up have to meet a performance standard, not just report data. Cycle 1 closes with the 2026 calendar year, and the Completed Actions Report is due May 3, 2027.

No obligation. We will tell you if you do not need us.
Cycle 1 at a glance
Completed Actions Report May 3, 2027 Required from every covered owner over 50,000 sq ft, on both pathways, whether or not the building meets its target. No report means not compliant.
Pathway change and ACP December 31, 2026 The window to change pathway or apply for an alternative compliance payment closes at the end of this year.
Verified data May 3, 2027 CY2026 benchmarking plus third-party verification.
Cycle 2 begins January 1, 2029 Pushed back a year. Cycle 1 dates are unchanged.

Dates and thresholds change. We confirm the current requirement for your specific building before anyone acts on it.

BEPS is a standard, and benchmarking is only how it is measured.

Benchmarking tells the District how your building performs. BEPS is the District telling you that performance has to clear a bar. For most scoreable property types that bar is the ENERGY STAR score, and for multifamily the standard sits at 66. Buildings above it are compliant for the cycle. Buildings below it choose a pathway and improve.

There are two main routes. The performance pathway asks for a percentage reduction in energy use over the cycle. The standard target pathway asks you to reach the standard itself. Which one is right depends on how far below the bar you are, what upgrades you have already done, and what your capital plan actually allows, and the choice is locked once the window closes.

Everyone talks about the penalty. In practice the more useful conversation is about the documentation. DOEE has not assessed a single BEPS payment to date, and when one is assessed the mechanism for reducing it is a building improvement agreement, which is negotiated on the record you built during the cycle. Katie Bergfeld at DOEE put it plainly: you do not have to wait on our guidance to start documenting.

What decides your outcome
Your gap to the standard
A building eight points under the standard is a different conversation from one twenty points under. We calculate it before recommending anything.
The paper trail
Audits, measures implemented, board minutes, invoices. This is what a settlement conversation is built from, and it has to be assembled during the cycle.
Verified square footage
The penalty math is per square foot and the score is per square foot. GFA verification is the highest-leverage hour in the whole engagement.
The services behind this page

How the engagement runs

Two phases. Position first, then the filing that closes the cycle.

1
Establish the real position
Verified gross floor area, clean benchmarking data, current score, and the gap to the standard in points and in dollars.
2
Choose the pathway deliberately
We model the routes against your capital plan and your board budget cycle, then file the election before the December 31, 2026 window closes.
3
Document as you go
Every measure, every invoice, every audit recommendation, captured in a form that supports the Completed Actions Report and any later settlement.
4
File the Completed Actions Report
Due May 3, 2027, from every covered owner on both pathways. This is the deliverable that determines compliance, and it is live in the portal now.
5
If a payment is assessed, negotiate it
Settlement runs through a building improvement agreement, where investment in the building can offset what is owed. Nothing is negotiable until DOEE assesses a payment.
The exposure, honestly

The published cap is ten dollars a square foot, and most buildings never get there.

The penalty math is published, and for multifamily it works out to roughly twenty-nine cents per square foot for each point below the standard, up to a ten dollar per square foot ceiling and a program cap. For an eight-point gap on a mid-size condo that is real money, and it is also the exact figure a board needs before it will approve anything.

What we do not do is quote you a running total or imply a payment is inevitable. DOEE has assessed none so far, exemptions exist for demolition, financial distress and low occupancy in the baseline years, and condos and co-ops are named as non-income-producing for the applicable test. We work out which of those doors is actually open for your building before we talk about money.

Received a letter?

What a DOEE letter usually means.

Most DC correspondence is one of two things, and neither is a bill.

Send us the letter
Benchmarking notice or notice of violation
DOEE’s list says the building owed a filing that it has not received. Half the time the fix is procedural: the building is not covered, the square footage is wrong, or the filing landed under a different identifier.
BEPS correspondence
Cycle reminders, pathway confirmations and, eventually, a notice of infraction. DOEE has assessed no BEPS payments to date, and nothing is negotiable until it does, so the right response to a cycle letter is documentation, not panic.

Send us the letter itself, not a summary. We read it for the six things that decide the response: who sent it, which building and identifier it names, what period it covers, what it says you failed to do, the cure date, and whether it is a first notice or an escalation. We never quote a running penalty total, and we cure first, then talk to the regulator.

Why boards bring us in for BEPS

We sit in the DOEE stakeholder and condo subcommittee meetings, so the advice you get is current rather than remembered.

Actually local
We are based in the DMV and sit in the stakeholder meetings where these rules get written, not on a national help desk.
Built for boards
Most of our clients are condo and co-op boards and the managers who serve them. We present in plain English, on your meeting schedule.
Credentialed
Certified Energy Manager on staff, Portfolio Manager specialists, and the credentials the verification work requires.
One accountable partner
We are not engineers and we do not pretend to be. We manage the process, coordinate the right vendors, and own the outcome.
Owners and managers we work with
FirstService Residential Legum & Norman EJF Real Estate Services Comsource Management Barkan Management Howard University Regency Centers Montgomery County Green Bank

DC BEPS questions boards ask

Yes. The Completed Actions Report is due May 3, 2027 from every covered owner over 50,000 sq ft in the cycle, on both pathways, whether or not the building meets its target. A building that clears the standard and files nothing is not compliant.

That is close to how settlement works. Once a payment is assessed, a building improvement agreement lets investment in the building offset what would otherwise be paid, and the published ladder gives credit based on how much you invest relative to the assessment. Only the incremental cost above business as usual counts, net of rebates, so the way a project is scoped and priced matters.

Treat it as a mitigating circumstance DOEE will consider during settlement after a payment is assessed, not as an exemption you apply for and not as a point system. Separate guidance is expected, and until it exists we document the effort rather than promise an outcome.

No. Solar, renewable energy certificates, offsets and power purchase agreements are excluded from the custom alternative compliance payment, and solar is not a BEPS pathway. It can be a good investment for other reasons, and we will tell you when it is, but it does not move your compliance position.

Condominiums and cooperatives are covered, and they are named as non-income-producing for the general test that applies to the financial distress route. The practical difference is governance, not obligation, and we build the timeline around your board meeting schedule.

Keep reading

The pages that usually matter next for a DC building.

Annual filing Benchmarking in DC The annual filing, what is reported, and how we keep the record clean. Third-party Verification in DC Third-party data verification and the square footage work that moves every number. Everything we do here Full services in DC Everything Honeydew manages here, compliance and energy services together.
What is BEPS? All Honeydew services Every region we serve Latest rule changes on the blog

Know your gap before the pathway window closes.

A first call gets you your current score, the standard for your property type, and the size of the gap. No obligation attached.

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