Property Size

Existing buildings 20,000 Sq. Ft. and larger.

Annual benchmarking reporting requires 12 calendar months of whole-building energy and building use data. For example, in 2025, building owners must report 12 months of 2024 data.

May 20, annually. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Note: For the 2026 reporting year, the Chula Vista BESO benchmarking deadline has been extended to June 30.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

Chula Vista BESO requires covered properties to meet either performance target compliance requirements or provisional compliance requirements.

Performance Target Compliance

Every five years, the building must submit a verified ENERGY STAR report showing that it has decreased its Site EUI-WN from the Baseline Year according to the following schedule:

Provisional Compliance

The property must submit a verified ENERGY STAR report showing that it has decreased its Site EUI-WN by at least 50% of the improvement target in the table above and must perform retro-commissioning on the building and implement energy conservation measures.

BPS Due Date

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.

Under Chula Vista BESO, data verification is required in the Baseline Year data and for data that is used to demonstration compliance with Conservation requirements.

Failure to comply with Chula Vista BESO will result in monthly fines up to $750 (20,000 to 49,999 Sq. Ft.), $1500 (50,000 to 99,999 Sq. Ft.), and $2,250 (100,000 Sq. Ft.).

CONTACT US HERE to learn more and get started with compliance.

Chula Vista BESO compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.

Ordinances such as Chula Vista BESO are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.

Property Size

Non-residential buildings with 10,000 square feet or more of space that is heated or cooled.

Multifamily residential buildings with 50,000 sq ft or more of space that is heated or cooled.

Annual benchmarking reporting requires 12 calendar months of whole-building energy and building use data. For example, in 2025, building owners must report 12 months of 2024 data.

May 1, annually. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

While San Francisco does not have a complete BPS program, they do require energy audits for non-residential buildings which must be completed by a qualified energy professional every five years. Buildings 50,000 Sq. Ft. or larger must complete and ASHRAE Level II audit while buildings 10,000 to 49,999 Sq. Ft. must complete an ASHRAE Level I audit.

Additionally, San Francisco requires commercial buildings of 50,000 square feet or more to obtain all electricity from 100% renewable sources on a tiered deadline basis outline below.

Building Audit Deadline

Building audits for applicable buildings are required every 5 years.

Electrification Deadlines

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.

Under San Francisco’s Existing Buildings Energy Ordinance, third-party data verification of benchmarking reports is not required. Audits however must be completed by an qualified professional.

Failure to comply with San Francisco’s Existing Buildings Energy Ordinance may result in fines of $50 per day up to $1,250 for buildings 10,000 Sq. Ft. or larger and $100 per day up to $2,500 for buildings 50,000 Sq. Ft. or larger.

CONTACT US HERE to learn more and get started with compliance.

San Francisco Existing Buildings Energy Ordinance compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.

Ordinances such as San Francisco Existing Buildings Energy Ordinance (EBEO) are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.

Property Size

Residential and non-residential buildings 20,000 Sq. Ft. or larger.

Annual benchmarking reporting requires 12 calendar months of whole-building energy, water, and building use data. For example, in 2026, building owners must report 12 months of 2025 data.

May 1, annually. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

San Jose BPO requires covered properties to comply with their “Beyond Benchmarking” program which allows covered buildings to select one of two pathways to compliance.

Performance Pathway

Properties that are highly efficient or demonstrate improved efficiency can comply with Beyond Benchmarking requirements via the Performance Pathway. Owners will submit a performance report that verifies their building has performed better than the energy and water performance targets set by the city.

Improvement Pathway

If a property cannot meet either energy or water performance target, they must complete one of the following Improvement Pathways:

1. Complete an energy and/or water audit and submit the audit report to the City
2. Perform energy and/or water retro-commissioning, making low-cost improvements to existing building systems and submit a retro-commissioning report to the City
3. Install energy and/or water efficiency improvement measures as defined in the ordinance and submit an efficiency improvement report to the City

BPS Due Date

Below are the initial deadlines for Beyond Benchmarking. Compliance due every 5 years from the buildings first reporting deadline.

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.

Under San Jose BPO, data verification was required for buildings complying with Beyond Benchmarking via a Performance Pathway.

Failure to comply with San Jose BPO annual benchmarking may incur a monetary penalty from $25-$50 per day of non-compliance, up to $5,000 per calendar year.

CONTACT US HERE to learn more and get started with compliance.

San Jose Energy and Water Building Performance Ordinance (BPO) compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.

Ordinances such as San Jose Building Performance Ordinance are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.

Property Size

All existing buildings over 20,000 Sq. Ft.

Starting in 2026, building owners are required to annually benchmark and report whole-building energy and building use data for the full calendar year. For example, in 2026, buildings owners must report 12 full calendar months of 2025 energy data.

Note that benchmarking data must also be third-party verified before submittal at the years specified (2026, 2028, 2032, 2036).

November 15, 2026 and then every May 15 thereafter. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

WeHo EBPS requires building owners to meet performance targets by either (1) meeting energy performance targets by the deadline, or (2) submitting a Building Performance Action Plan (BPAP). These are measured using Site EUI (energy use intensity) or GHGI (greenhouse gas intensity).

BPAPs outline how the owner will improve energy efficiency, such as upgrading equipment or implementing other energy-saving measures, along with a timeline for completion. The city must approve these plans, and they must demonstrate measurable progress toward meeting the targets. After 2036, BPAPs will no longer be accepted, and buildings will be required to meet the final performance standard.

Covered properties under WeHo EBPS need to comply with building performance standards in the following years:

• First Interim Performance Standard: May 15, 2028
  • Building Energy Use Period: January 1 – December 31, 2027
• Second Interim Performance Standard: May 15, 2032
  • Building Energy Use Period: January 1 – December 31, 2031
• Final Performance Standard: May 15, 2036
  • Building Energy Use Period: January 1 – December 31, 2035

Energy performance targets will get increasingly more stringent over time with each compliance deadline.

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert to independently review and verify the building’s benchmarking data.

Under WeHo EBPS, data verification is required before submittal in 2026. More data verification requires may be implemented in the future. Additionally, data verification must be completed by one of the following qualified verifiers:

• Certified Energy Manager (CEM)
• Professional Engineer (PE)
• Registered Architect (AE)
• Building Energy Assessment Professional (BEAP)
• Energy Management Professional (EMP)

WeHo EBPS Benchmarking Penalty

Each instance where an owner of a covered property fails to meet annual reporting requirements can result in a fine up to $1,000.

WeHo EBPS Performance Standard Penalty

Buildings that fail to comply with performance standards and do not have an approved Building Performance Action Plan (BPAP) will be subject to fines equal to the Social Cost of Carbon for each unachieved GHG emission reduction.

The City’s Fee Resolution sets the exact amount fined per CO2e. Fines must be paid annually until the building is in compliance. Analysis from the California Air Resources Board projects values ranging from $63 to $93 per ton by 2025, under midrange scenarios.

WeHo EBPS Accuracy Penalty

Inaccurate reports or discrepancies of 50% or more between third-party verified data and the owner’s self-certified data will result in a fine of $1,000.

WeHo EBPS Overall Penalty

Owners of a covered property that violate annual benchmarking reporting, fail to meet interim and final performance standards, AND don’t have an approved BPAP will be fined $10 per square foot.

CONTACT US HERE to learn more and get started with compliance.

West Hollywood Equitable Building Performance Standards (EBPS) compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting and providing third-party data verification.

We also provide a complimentary benchmarking and compliance roadmap consultation, where we’ll assess your building’s performance, highlight key metrics, and develop a clear and manageable compliance for your property with WeHo’s EBPS.

Ordinances such as WeHo EBPS are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

It’s never too early to start planning for your energy performance targets! The sooner you begin, the easier and more cost-effective the journey will be. VCA Green makes compliance as smooth as possible by handling every step. From accurate data collection, verification and reporting to project management, let’s work together to create a tailored roadmap for you and your property! The earlier we get started, the more we can help you save, both in time and cost.

Covered Entities

Both public and private business entities who have total annual revenues over $1 billion USD (in the prior fiscal year) that do business in California. The revenue threshold accounts for revenue earned for the entire entity, not just the revenue earned in California.

Doing Business in California

CARB follows the Revenue and Tax Code § 23101 which defines “doing business” as actively engaging in any transaction for the purpose of financial or pecuniary gain or profit. An entity is doing business in California if the entity is doing business (as defined) and any of the following conditions are met:

• The entity is organized or commercially domiciled in this state
• Sales in California exceed the inflation adjusted threshold of $735,019 (2024)

Revenue Threshold

The bill defines revenue under the California Revenue and Taxation Cost (RTC) § 25120(f)(2) definition. Revenue is the gross amounts realized on the sale or exchange of property, performance of services, or the use of property in a transaction that produces business income.

California SB 253 requires covered entities to report Scope 1, 2, and 3 GHG emissions to the California Air Resources Board (CARB). The reporting business must cover the entity’s emissions globally, not just those emitted within California.

Companies must prepare reports in accordance with the GHG Protocol Corporate Accounting and Reporting Standard (or a successor standard). Scope 3 reports should follow the GHG Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standard.

Scope emissions are categorized by the following definitions:

Scope 1 Emissions: Direct emissions from sources the company owns or controls.

• Company vehicles
• On-site combustion

Scope 2 Emissions: Indirect emissions from purchased energy.

• Electricity
• Heating and cooling
• Steam

Scope 3 Emissions: Indirect emissions resulting from business activities, not included in Scope 2.

• Business travel
• Purchased goods
• Emissions from production of raw materials
• Waste

Companies are required to report their GHG emissions on an annual basis. CARB has extended its Scope 1 and 2 reporting deadlines from August 10 to November 10, 2026. Scope 3 reports are expected to be due in 2027, though an official date has not been set.

• If the reporting entity’s fiscal year ends between January 1 and February 1, 2026, the entity will report data from the fiscal year ending in 2026.
• If the reporting entity’s fiscal year ends between February 2 and December 31, 2026, the entity will report data from the fiscal year ending in 2025.
• Each entity will have at least 6 months after their fiscal year ends to submit their report.

Entities that were not collecting data at the time the Enforcement Notice (Dec 2024) was issued, the entity will not need to submit a report in 2026. These entities must send CARB a letterhead stating they were not collecting data at the time.

*These due dates are pending finalization by CARB.

Third-party data verification requires covered entities to hire a third-party expert who will independently review and verify the company’s GHG emission data disclosure.

Under SB 253, assurance is not required for 2026 reports. Limited assurance will be required in the future. By 2030, CARB will require data assurance at the “reasonable assurance” level for Scope 1 and 2, and at a “limited assurance” level for Scope 3. These requirements are implemented at CARB’s discretion, depending on market conditions.

SB 253 violations will result in administrative penalties of up to $500,000 per reporting year. CARB will not assess penalties for companies who demonstrate a good-faith effort for Scope 3 emissions reports until 2030.

CONTACT US HERE to learn more and get started with compliance.

SB 253 compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green simplifies the entire process while ensuring accurate reporting. Our certified Carbon Auditing Professionals streamline the complex reporting requirements of climate disclosures, from end-to-end carbon accounting to preparing assurance-ready GHG emissions reports.

SB 253 deadlines are rapidly approaching. Retrieving historical GHG emissions data will take time, especially when coordinating with your team.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.

Property Size

Buildings over 20,000 Sq. Ft.

Specifics on building type are still pending finalization.

Annual benchmarking reporting requires 12 calendar months of whole-building energy, and building use data. For example, in 2025, building owners must report 12 months of 2024 data.

June 1, annually. While official regulations have not been published, this policy is expected to be heard by Santa Monica City Council in July 2026. Benchmarking reports must be submitted on an annual basis using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

Santa Monica CHEBO has proposed requiring covered properties to meet building performance targets that become increasingly stringent. Buildings will also be able to submit and maintain a Building Performance Action Plan (BPAP).

BPS Due Date

CHEBO BPS deadlines have yet to be finalized. Proposed regulation suggests buildings will need to comply on the following schedule:

June 1, 2031 (every 5 years thereafter) – Buildings over 50,000 Sq. Ft.

June 1, 2036 (every 5 years thereafter) – Buildings over 25,000 Sq. Ft.

All covered buildings will need to achieve a final performance target of net zero emissions by 2050.

Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.

Data verification under Santa Monica’s proposed CHEBO policy will be required for years before BPS deadlines (2031, 2036, 2041, 2046, 2050).

Santa Monica CHEBO non-compliance penalties have yet to be addressed.

CONTACT US HERE to learn more and get started with compliance.

Although policy has yet to be enacted, now is the time to prepare. Santa Monica CHEBO compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.

Ordinances such as Santa Monica CHEBO are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.

Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.