Mid-Atlantic
Six jurisdictions, each with its own definition of a covered building and its own view of what happens when a building misses a deadline. Montgomery County now files separately from the Maryland state program, and county lines matter more than mailing addresses here.
Washington, DC
Covered buildings report annually, and buildings over 50,000 square feet are inside the BEPS cycle. Condominiums and cooperatives are covered and are named as non-income-producing for the applicable test.
Cycle 1 requires a Completed Actions Report from every covered owner over 50,000 square feet, on both pathways, whether or not the building meets its target. No report means not compliant. Settlement of any assessed payment is handled through a building improvement agreement.
Maryland
Statewide program administered by the Maryland Department of the Environment. Buildings inside Montgomery County are carved out and file with the county instead.
Maryland measures on weather-normalized site energy use intensity and direct greenhouse gas intensity rather than an ENERGY STAR score, which changes what data actually matters for the filing.
Montgomery County
Since HB49 took effect in October 2025, county buildings are exempt from the Maryland state program and file with county DEP only. Legacy dual-filed buildings need cleaning up.
Enforcement runs through the county code as a count-based ladder, citation, then order of abatement, then escalating citations. Prospects increasingly arrive holding a court order rather than a first notice.
Virginia
No statewide benchmarking mandate. Honeydew works here on voluntary benchmarking, procurement, solar advisory, and portfolio consistency for owners who also hold covered buildings elsewhere.
Virginia buildings usually enter the relationship as part of a portfolio that has covered buildings in DC or Maryland, and stay for the energy services.
New Jersey
Statewide program run by the Board of Public Utilities. Coverage is driven by MOD-IV tax class, not ownership form, so condominiums and cooperatives are not covered.
The BPU currently imposes no fines, so penalty-based urgency does not apply in New Jersey and we do not use it. The obligation still stands and non-filing still shows in the public record.
Philadelphia
City program only. Pennsylvania has no statewide mandate, so nothing stacks. Commercial and multifamily at 50,000 square feet and above.
Two separate obligations run in parallel: the annual benchmarking filing, and the five-year Building Energy Performance Program tune-up cycle for non-residential buildings. Check both, every time.
Regulatory dates, thresholds, penalties, and program mechanisms change, and several of the programs above have draft elements that are not yet settled. Nothing on this page is a determination about a specific building. Confirm the current requirement for the individual property before acting, and we will do that with you.
Not sure which rulebook applies?
Mailing city is not the same as jurisdiction, and one property can sit in two programs at once. Give us the address and we will check it properly.
Tell us what is on your plate. We will help you sort it out.
A notice, a deadline, a portfolio, or simply a question. You do not need to have it organized before you call.