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Frequently Asked Questions

Do I need to report to both the City of San Diego and the State of California?

Building owners within the City of San Diego should report to the City of San Diego instead of the State.

Which buildings need to comply with the benchmarking ordinance?

Owners and operators of all commercial, multifamily and mixed-use properties larger than 50,000 square feet (and for multifamily and mixed-used properties with more than 17 residential utility accounts) are required to benchmark and publicly disclose building energy usage to the city.

Who is responsible for compliance with the ordinance?

The building owner is responsible for reporting the data to the city.

What is the deadline to comply?

Reporting is due annually on June 1 for commercial, multifamily (with 17 or more residential utility accounts) and mixed-use buildings.

How often must I report to the City?

Reporting is annual and due June 1 every year. Since buildings generally don’t change a lot, most owners will not have to input much new data after the first year. The only new information to report is how much energy you used last year. To make it easy, there are ways to automatically have your energy bills go into ENERGY STAR, so you may only need to click a button to submit data the second year. Learn more about automated data uploads.

Is there a cost to benchmark my building with ENERGY STAR Portfolio Manager?

Portfolio Manager is a free online tool to benchmark your building and create the reports required for compliance with the City of San Diego’s benchmarking ordinance. There may be fees or costs associated with hiring an outside consultant to help you with benchmarking if you choose not to do it yourself.

Is a certain ENERGY STAR score or performance target required for compliance?

There is no ENERGY STAR score or performance target required for compliance. The data and information are intended to help you make informed decisions to pursue efficiency measures and save on energy costs while improving your overall operations.

What type of information or data do I need to benchmark?

Benchmarking requires building characteristic information, occupancy information and energy use data.

The Portfolio Manager Reference Guide lists specific required information for varying building types. Each building type has different requirements—for example, a fast food restaurant and a hospital use energy differently and have different information that is required to collect. To streamline the process of collecting data, generate a data collection worksheet specific to your property type(s).

What steps do I need to take to comply?

Create your building in ENERGY STAR Portfolio Manager, including any required use details for your property type(s).

  1. Add your energy meters and meter data manually or via syncing (recommended) with SDG&E’s Benchmarking Data Request Portal. Visit SDG&E’s benchmarking webpage to get started.
  2. Once your data is entered, run Portfolio Manager’s data validation tool and fix any errors.
  3. Submit your benchmarking report using the links found at sandiego.gov/benchmark.
  4. Review the generated report to ensure it is accurate and complete and then submit the report to the city.

Note: the City’s ordinance only requires reporting and disclosure of whole-building energy consumption.

Who can prepare the report or send the data?

Anyone can open a Portfolio Manager account and create the report. The EPA offers training videos and guides, and there are additional resources (see Additional Resources tab on this site). Some building owners or managers may choose to have internal staff manage the account and submit reports, while others may hire an external service provider.

Can more than one person have access to the Portfolio Manager account?

When setting up your organization’s account, you can use your own contact information or general contact information for your organization. Whether you use individual or organizational information, we recommend that only one person be responsible for uploading data each month to prevent inconsistencies or duplicate data entry. However, it is advisable to have at least two or more people within your organization capable of accessing the account (i.e., know the login credentials) in case the person in charge of reporting utility data leaves your organization.

What property types can I input into Portfolio Manager?

Portfolio Manager is a powerful tool and contains more than 80 property types to choose from when setting up your property. Download the list of Portfolio Manager property types, definitions and use details. Choose a property type that best describes how most of your building functions.

Can I add properties to an existing account?

Portfolio Manager is designed so that your account can have multiple properties.

How does the ordinance apply to multiple owners of a single building?

Only one report is required per property, and in cases where a building has multiple owners, managers and/or agents, all are encouraged to collaborate to ensure that one annual report is submitted. Options include creating a joint team to comply (e.g., a representative of each owner works together) or appointing a mutually agreed upon staff member or third party to facilitate compliance (e.g., naming a staff member or contracting a third party).

How does the ordinance apply to multiple buildings with shared energy?

If multiple buildings (at least one of which is covered by the ordinance) share one or more energy consuming systems (e.g., boilers, electricity meters, district chilled water, etc.), then all buildings should benchmark, verify and report as a campus (reporting both parent and child properties from Portfolio Manager). Learn more about campus benchmarking.

Note: If multiple buildings with the same owner (such as a campus or multi-building complex) have separate energy consuming systems, any covered buildings (that meet size and use type requirements) should be benchmarked separately.

Is compliance required for strip malls or open-air shopping centers?

Compliance is required for each individual building that has more than 50,000 square feet of gross floor area. Separate buildings that have the appearance of being a single building due to a continuous façade should be treated as individual buildings. If a single building within a strip mall or open-air shopping center encompasses over 50,000 square feet, then that individual building must comply.

What is considered an industrial property?

Industrial properties, which are exempt from benchmarking reporting, include spaces adapted for uses like assemblage, processing and/or manufacturing products from raw materials or fabricated parts. Warehouses and distribution centers are not considered industrial and are required to comply.

Does my building square footage include parking areas?

When calculating your square footage to determine if you’re required to comply, covered parking structures should be included while open and uncovered parking lots should be excluded. When entering your gross floor area into Portfolio Manager, there is a separate field for parking, so you can separate the parking area from your self-reported area.

However, if your open and uncovered parking lots use lighting that is on the same meter as the building, you should include that square footage in your parking area in Portfolio Manager, even though it’s not counted toward the 50,000-square-foot threshold. Portfolio Manager provides an assessment of the building, not its parking area. If it is not possible to submeter your open and uncovered parking area energy usage, Portfolio Manager will estimate the amount of energy parking uses and subtract that out before calculating your metrics by using the parking square footage entered.

Is there a procedure to protect proprietary data?

Certain building owners may request that their energy usage be determined a trade secret and thus not subject to disclosure. Such an exemption must be obtained from the executive director of the California Energy Commission. If it is granted, the building owner is required to report building characteristic information but not energy use data.

What happens if the building owner does not comply?

The City of San Diego retains the authority to issue fines for noncompliance, however the City is currently primarily focused on increasing compliance rates by educating building owners and managers.

What happens to the information provided to the City?

Information reported each year will be sent to the California Energy Commission, as well as publicly disclosed to allow current and prospective building owners and tenants to better understand the buildings in which they live and work.

What information will be publicly disclosed?

The City of San Diego may make the following information available:

  • Building address, including county, latitude and longitude
  • Year built
  • Gross floor area and property floor area (buildings and parking)
  • Property or building name (if any)
  • Open “comments” field for the building owner or owner’s agent to provide additional information about the building
  • ENERGY STAR Portfolio Manager property ID
  • Percentage of space occupied (occupancy) and number of occupants
  • Number of buildings (if served by one common energy meter without submetering)
  • ENERGY STAR score for eligible buildings
  • Monthly and/or annual site and/or source energy used by energy type
  • Monthly and/or annual weather-normalized site and/or source energy use intensity
  • Monthly and/or annual peak electricity demand
  • Total greenhouse gas emissions

How do I benchmark if my building was only occupied recently and doesn’t have 12 months of data?

Your building is exempt from reporting if it did not have a permanent or temporary certificate of occupancy for more than half of the calendar year being reported. You must email an exemption request to the City at [email protected]. Otherwise, reporting is required, and you should include as much energy use data as you have.

How should I benchmark garden style apartments?

If your multifamily property consists of multiple properties, such as a garden-style community, you should benchmark as a campus of the entire property. Multifamily properties are one of the few property types that certify as a campus. You can enter all the data as a single property, or if each building is separately metered, you may want to enter each building as a “child property.” Learn more.

How can I request my energy data from SDG&E?

Both aggregated and nonaggregated data requests require customers to complete the following steps.

  1. Connect and share your property(ies) in Portfolio Manager with SDG&E Benchmarking
  2. Request building metrics through SDG&E’s benchmarking data request portal

Read the PDF icon Benchmarking Data Request Portal User Guide to learn more about the process.

Does SDG&E update the energy information every month if I give them full access?

Yes. If you request recurring data uploads during the request process, SDG&E will update data monthly. SDG&E’s portal uploads data by calendar month, not by billing period, so you may need to adjust any historical entries in your account to resolve data overlaps and gaps.

What if utility customers refuse to release their energy use data to a building owner?

For buildings required to comply that have fewer than three utility accounts of each energy type a utility provides, the utility customers of record for the accounts serving the building must provide their permission before the utility will provide energy use data. When a building owner is unable to obtain energy use data because customers did not provide permission, the building owner will comply by reporting building characteristic information in ENERGY STAR Portfolio Manager, but not energy use data.

What do owners need to provide to show proof of ownership to get access to the whole building data from the utility?

A person requesting whole-building energy use data will need to provide an attestation that he or she is the building owner or is authorized to act on behalf of the building owner. Proof of ownership is not required.

What if my building is not an eligible property type and doesn’t generate a score?

If your property type is ineligible for an ENERGY STAR score, you can still receive the weather-normalized energy use intensity (EUI) of your property, measured in kBtu/square foot. You can compare this weather-normalized EUI to national averages for your property type PDF icon using an ENERGY STAR reference table.

How do I know if I’ve successfully submitted the report and have complied?

After submitting the compliance report through ENERGY STAR Portfolio Manager, you’ll receive an email confirming your entry.

How can I improve my building’s ENERGY STAR score?

Scores improve with increased energy efficiencies within the building. There may be initiatives you can pursue, including programs and rebates provided by San Diego Gas & Electric.

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