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West Coast

California layers city programmes on top of a state programme, and the real constraint is utility data access. Three of the six major California utilities need no client document at all, while two need heavy owner-signed packages. Washington State adds an absolute-target standard that is not a benchmarking programme at all.

CA

California

Statewide AB 802, owner filed annually. Condominiums are statutorily excluded from the state programme. Shopping centers are tested per building above 50,000 square feet.

Beyond benchmarking

Sort a California portfolio by fuel and utility, never by property or city. A building with a live notice and a blocked electric utility can often still have its gas request submitted the same day, and that partial unblock is where the schedule is won.

Annual filing
June 1, annual
Performance standard
No state BPS
Benchmarking enforcement
State enforced
Performance enforcement
Not applicable
What Honeydew manages here
Utility-first sequencing across the portfolio
Authorisation package routing
Exemption identification
Pending revision resolution
LA

Los Angeles

EBEWE. City filing satisfies the state programme, but a city exemption does not, so exempt buildings over 50,000 square feet may still owe the state. Condominiums are covered and the association files.

Beyond benchmarking

LADWP is blocked until an owner letter of authorisation exists, but SoCalGas is open with no client document. Open the gas half of every property immediately and let it backfill during the LADWP wait.

Annual filing
June 1, annual
Performance standard
A/RCx cycle
Benchmarking enforcement
City enforced
Performance enforcement
Audit and retrocommissioning
What Honeydew manages here
SoCalGas immediate start
LADWP authorisation preparation
A/RCx cycle scheduling by building ID
State versus city obligation check
SF

San Francisco

Non-residential from 10,000 square feet, the lowest threshold we work with. City filing satisfies the state programme.

Beyond benchmarking

Both fuels are PG&E, so every San Francisco property sits behind the same attestation gate with no partial-fuel workaround. Commercial energy audits run on rolling five-year per-building dates.

Annual filing
May 1, annual
Performance standard
Audit cycle
Benchmarking enforcement
City enforced
Performance enforcement
Audit required
What Honeydew manages here
Coverage and threshold review
Utility data access and portal connections
Portfolio Manager setup and QA
Filing, tracking, and agency follow-up
SJ

San Jose

City filing satisfies the state programme. Exemptions are due a month before the filing itself, which catches people out.

Beyond benchmarking

Both fuels are PG&E here as well, so the attestation is the gate for the whole property. Separate building identifiers are assigned on request where a campus should be split.

Annual filing
May 1, annual
Performance standard
Beyond Benchmarking
Benchmarking enforcement
City enforced
Performance enforcement
Five-year cycle
What Honeydew manages here
Coverage and threshold review
Utility data access and portal connections
Portfolio Manager setup and QA
Filing, tracking, and agency follow-up
WA

Washington State

Clean Buildings Performance Standard. Not just benchmarking, it requires an energy management plan, an operations and maintenance programme, and a performance target.

Beyond benchmarking

The test is a single building, not the aggregate of a campus, and parking is excluded. Watch the band inversion, a building just under 50,000 square feet is due eleven months earlier than one just over it. Extensions can be filed up to six months after a missed deadline.

Annual filing
Tiered, 2026 to 2028
Performance standard
Absolute EUI target
Benchmarking enforcement
Notice driven
Performance enforcement
Four pathways
What Honeydew manages here
Per-building tier determination
Extension filings inside the late window
Pathway selection across four options
Energy management plan coordination
Read more about Washington State
SEA

Seattle

Fully stacks with the state standard. Two filings, and neither satisfies the other.

Beyond benchmarking

A new city portal launched in mid 2026, so the submission path should be re-verified before filing. Building tune-ups are in their second cycle, and there are nine alternative compliance paths, two of which can be answered from public data in minutes.

Annual filing
June 1, annual
Performance standard
Seattle BEPS
Benchmarking enforcement
~90 day penalty
Performance enforcement
2031 onward
What Honeydew manages here
Dual city and state filing
Tune-up alternative compliance screening
New portal submission
Verifier independence management

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.

202-670-9625 Send us the address
Start with the building

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