- January 22, 2025

Maryland is implementing COMAR 26.28.02 Building Energy Performance Standards (BEPS) as required under the Climate Solutions Now Act of 2022.
The first step of implementation is measuring energy usage with mandated benchmarking reporting.
For the first year of implementation, the deadline is September 1, 2025.
Who is Required to Submit a Benchmarking Report?
Maryland is requiring you to submit a benchmarking report if the gross square footage of the building is greater than or equal to 35,000 square feet excluding the parking garage area, and is:
- A single building, as defined by the building’s “envelope.”
- One or more buildings that are held in the condominium form of ownership and governed by a single board of managers.
- Two or more buildings that are served together or in part by the same electric or gas meter or are served by the same heating or cooling system or systems, which is not a district energy system.
Requirements
Building owners are required to annually “benchmark” buildings subject to the performance standards (unless exempt).
When benchmarking your building:
- Submit the previous calendar year’s whole building energy consumption data online through ENERGY STAR Portfolio Manager by June 1 each year, starting in 2025.
To assist building owners with their transition to the new BEPS requirement, the Department intends to treat all initial benchmarking reports submitted by September 1, 2025, as timely.
Note: ENERGY STAR Portfolio Manager is free to use.
How to Know if You Are Exempt
You are eligible to apply for an EXEMPTION if the gross square footage of the building is greater than or equal to 35,000 square feet, excluding the parking garage area, and is:
- A building, or space within a building, individually designated as a historic property under federal, State, or local law, separate and apart from a building’s inclusion in a historic district
- Public or nonpublic elementary or secondary school
- A manufacturing building
- An agricultural building
- A building owned by the federal government; or
- A demolished building.
If you need assistance exploring Benchmarking service providers, connecting to ENERGY STAR Portfolio Manager, or anything in between, please reach out to Mike Eckenroth.
We are happy to be a resource supporting your compliance with these new requirements.
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