Philadelphia's Energy Benchmarking and Tune-Up Programs

Buildings covered

Both programs apply to:

• Commercial and multifamily buildings with 50,000 sf or more indoor floor space.
• Commercial portions of mixed-use buildings where 50,000 sf or more is devoted to commercial use.

Exemptions may apply where:

• More than 50% of indoor floor space is unoccupied for 180+ days in a calendar year.
• Benchmarking or disclosure would cause exceptional hardship or would not be in the public interest, per the Office of Sustainability.
• The building is primarily used for manufacturing or industrial process where benchmarking doesn't meaningfully reflect building energy use.
• Ownership changed and a full calendar year of utility bills isn't available.

Primary source: phila.gov (Office of Sustainability — Building Energy Benchmarking and Performance).

Building Energy Benchmarking Ordinance (§ 9-3402)

Enacted June 2012. Key elements:

• Annual reporting. Building owners report previous-calendar-year energy and water usage via ENERGY STAR Portfolio Manager by June 30 each year.
• Public disclosure. Reported data has been publicly disclosed since 2014 — accessible market transparency for efficiency performance.
• Tenant data. Building owners responsible for obtaining energy/water consumption data even where tenants have separate meters. Tenants required to provide data on request.
• Penalties. Non-compliance: $300 for first 30 days, $100 per day thereafter.

The benchmarking ordinance is about measurement, disclosure, and market signaling — not direct performance mandates. Building owners who report consistently over years can demonstrate efficiency improvements; lower-performing buildings become visibly identified in the market.

Building Energy Performance Program (BEPP / Tune-Up)

Created under Bill #190600, signed into law December 2019. The tune-up policy:

• Five-year tune-up cycle. Covered building operators submit a Tune-Up Workbook to the Office of Sustainability every five years.
• What a tune-up covers. Review of energy systems and controls, minor tweaks and corrective actions to restore good performance. Scope typically includes building envelope, HVAC systems, domestic hot water, and electrical lighting.
• Specialist requirement. Tune-ups must be completed by an approved specialist — Professional Engineer (PE) or Certified Energy Manager (CEM).
• Compliance options. (1) Perform a tune-up; (2) demonstrate high performance (meet a performance threshold exempting the building); (3) obtain exemption.
• Policy goal. City projects approximately 200,000 metric tons of carbon reduction from the program.

BEPP is an operational-energy program. It doesn't mandate specific equipment upgrades or prescribe energy reductions; it requires periodic systematic review of how the building's systems are performing and corrective action where warranted.

Combined compliance pattern

Owners of covered buildings maintain both tracks:

1. Annual benchmarking via Portfolio Manager by June 30.
2. Data collection from tenants where separately metered.
3. Public disclosure via city-released datasets.
4. Tune-up every five years by qualified specialist.
5. Tune-Up Workbook submission to Office of Sustainability.
6. Implementation of identified corrective actions — the tune-up isn't just documentation, it's identifying and addressing controls/systems issues.

Interaction with PA state energy code

PA's Uniform Construction Code (see our PA UCC essay) adopts IECC as the state energy code applied through construction permits. Philadelphia's benchmarking and tune-up programs layer on top — focusing on operational performance of existing buildings rather than construction-phase code compliance.

• PA UCC energy code — applies to new construction and major renovation through the permit process.
• Philadelphia's city authority under 2017 state law allows Philadelphia to adopt updated ICC Codes independently; Philadelphia runs 2018 ICC Codes (ahead of PA state-adopted cycle for a period).
• Benchmarking ordinance — applies to existing buildings; operational energy reporting.
• BEPP Tune-Up — applies to existing buildings; operational energy performance through systematic review.

A new Philadelphia building is designed to energy code at construction, then (once occupied and 50,000+ sf) enters the benchmarking and tune-up tracks.

How Philadelphia compares to other benchmark-mandating programs

• Maryland BEPS. Statewide program for 35,000+ sf covering both benchmarking and emissions-reduction targets through 2040 net-zero. See our MD Energy Code + BEPS essay. Broader scope than Philadelphia's BEPP, which is operational-tune-up focused rather than emissions-trajectory focused.
• DC BEPS. DC Building Energy Performance Standards covers buildings 50,000+ sf with emissions-reduction trajectory similar to MD BEPS.
• Boston BERDO and NYC LL97 are similar next-generation programs.
• Philadelphia BEPP is a tune-up/operational program without emissions trajectory mandates (as of current policy).

The distinction: benchmarking + tune-up (Philadelphia) is a "measure and maintain" model; BEPS/LL97-style programs (MD, DC, Boston, NYC) add "reduce emissions to X by Y" on top.

Common issues for owners and operators

• Tenant data collection. Multi-tenant office and retail buildings need data-collection processes from tenants. Some tenants are slow to respond; plan ahead for the June 30 deadline.
• Data quality errors in Portfolio Manager. Common first-year issues; review before submission.
• Qualified tune-up specialist selection. Market is mature; engage the specialist 6+ months before submittal deadline to allow for scope + site visit + workbook prep.
• High-performance exemption path. Buildings meeting threshold may avoid tune-up; verify with Office of Sustainability.
• Corrective actions identified during tune-up should be scoped for capital planning; while the tune-up process is flexible, identified issues represent deferred maintenance that typically merits attention.
• Record-keeping for future audits and tune-up cycles.

What to do with this

If you own a Philadelphia commercial/multifamily building 50,000+ sf: confirm benchmarking is current; identify whether your five-year tune-up cycle is due; engage qualified specialist early.

If you're acquiring a Philadelphia large building: due diligence should include benchmarking compliance history, previous tune-up reports, and Office of Sustainability standing.

If you're designing a new Philadelphia commercial building: design to current energy code (city-adopted 2018 I-Codes or later) with operational performance in mind — your successor owner will benchmark and tune-up.

If you operate a portfolio across multiple Mid-Atlantic cities: track each jurisdiction's program. Philadelphia BEPP, MD BEPS, DC BEPS all have different structures, timelines, and obligations.

For PA construction-side context, see our PA UCC essay and Philadelphia Pre-Permit Approvals essay.

About The Hive

The Hive builds tools and publishes essays for working construction and MEP professionals in the Delaware Valley and Mid-Atlantic. Primary-source-grounded, practitioner-voiced, free to use.