Group 1 Covered Properties

Buildings 50,000 Sq. Ft. and larger and are either:

• Owned by the City
• The City pays for the majority of the annual energy bills

Group 2 Covered Properties

Buildings other than a Group 1 property that are 50,000 Sq. Ft. or larger including buildings held in the condominium form of ownership that is governed by the same board.

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

Municipal buildings must report by December 31, annually. Non-municipal buildings (institutional, commercial, and multifamily) must report by April 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.

St. Louis BEPS requires covered properties to meet weather-normalized site energy use intensity (site EUI) targets based on the property type. These targets become more strict every 4 year cycle.

Paths to Compliance

St. Louis offers multiple pathways to compliance. Below is a summary list. Further details can be found on this Fact Sheet:

1. Performance: As described above, properties meet the weather-normalized site EUI for that specific cycle.
2. Early Adopters: Buildings that meet or exceed targets AND reduce site EUI by 20% or more will be placed in compliance for certain future cycles.
3. Alternative Compliance Path: If a property reduced its EUI by 50% of the difference between its 2018 baseline EUI and the EUI standard for its property type in that cycle AND submits required documentation, then it is in compliance.
4. Custom Alternative Compliance Path: If a property has unique characteristics, the owner can apply for a custom alternative compliance path. This requires an application with the City and an ASHRAE Level II Audit. Compliance is achieved once approved by the City.

Compliance Cycles

The first BEPS compliance cycle was May 4, 2021 through May 4, 2025. St. Louis generally operates on a “4+1” cycle in which the first 3 years are for energy improvement, the fourth year is to achieve the target, and the fifth year is to maintain performance and plan for the next cycle.

The next compliance years are 2030 and 2035.

*Qualified affordable housing and houses of worship will have six years to meet the standard. For these facilities, the first compliance due date is May 4, 2027.

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 St. Louis BEPS, data verification is required to confirm building performance standards compliance. The data from the last year of each BEPS cycle (known as a verification year), must be verified by a third party.

For example, in the 2021-2025 BEPS cycle, data verification was required for 2024 data. Data verification must be submitted by June 1st of the final year in the compliance cycle.

St. Louis buildings that fail to benchmark or comply with BEPS will be issued a written warning upon initial violation. If the required information is not submitted within 60 days of the warning, a fine of $50 to $200 per day will be issued up to $1,000 per year. Buildings not in compliance will not be eligible for issuance of new residential or commercial occupancy permits.

CONTACT US HERE to learn more and get started with compliance. We perform benchmarking, third-party verification, and building performance services.

St. Louis BEPS 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.

While each service varies, the process of benchmarking, or analyzing data, can take 3-6 months on average. Ordinances such as St. Louis BEPS 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.