Montgomery County BEPS Explained: Benchmarking Deadlines, Site EUI Targets, and Compliance Paths
Montgomery County, Maryland has positioned itself as a leader in local climate action through its Building Energy Performance Standards (BEPS) program focused on normalized net site energy use intensity (EUI). This metric—with weather normalization and renewables credit—serves as the cornerstone for evaluating building performance. This post will:
Explain the difference between Site EUI and Normalized Net Site EUI (NN EUI).
Outline Montgomery County’s BEPS coverage, timeline, and regulatory framework.
Explore compliance pathways: Performance Pathway vs Building Performance Improvement Plan (BPIP).
Discuss alignment with Maryland’s statewide BEPS.
Offer practical guidance and resources for building owners and operators.
1. Site EUI vs Normalized Net Site EUI
Site Energy Use Intensity (Site EUI) measures a building’s annual on-site energy consumption per gross square foot (expressed in kBtu/sf/yr)
Montgomery County BEPS evaluates buildings based on Normalized Net Site EUI (NN EUI)—a weather‑normalized version of Site EUI presented as:
This ensures:
Fair comparison year-over-year regardless of weather variability.
Credit for on‑site renewables, encouraging solar and electrification.
Appropriate treatment of excluded energy uses like EV charging and dedicated parking loads .
2. Montgomery County BEPS: Coverage & Regulatory Framework
a) Covered Buildings & Timeline
Under Bill 16‑21, effective July 2022, Montgomery County expanded benchmarking and BEPS to include:
All non‑residential and multifamily buildings ≥ 25,000 gross square feet (gsf).
Buildings divided into five groups with staggered compliance schedules
| Group | Building Types | Size Range (gsf) | Benchmarking Begins | Baseline Period | Interim Deadline | Final Deadline |
|---|---|---|---|---|---|---|
| 1 | Non‑res County & Private | ≥ 250k | June 1, 2016 | 2018–2022 | Dec 31, 2028 | Dec 31, 2033 |
| 2 | Non‑res Private 50–250 k | 50k–250k | June 1, 2017 | 2018–2022 | Dec 31, 2028 | Dec 31, 2033 |
| 3 | Non‑res 25–50 k | 25k–50k | June 1, 2023 | 2022–2024 | Dec 31, 2030 | Dec 31, 2035 |
| 4 | Multifamily ≥ 250 k | ≥ 250k | June 1, 2023 | 2022–2024 | Dec 31, 2030 | Dec 31, 2035 |
| 5 | Multifamily 25–250 k | 25k–250k | June 1, 2024 | 2023–2025 | Dec 31, 2031 | Dec 31, 2036 |
These deadlines give buildings time to benchmark, plan upgrades, and gradually meet interim and final EUI targets .
b) Performance Standards & Final Site EUI
DEP regulations set final Site EUI performance standards tailored to ENERGY STAR property types (e.g., office, multifamily, retail). For mixed‑use, area‑weighted standards apply. If a building’s baseline EUI is over 30% higher than the final target, the final target is capped at a 30% reduction from that baseline.
The county uses local and national datasets to form standards, ensuring equitable targets even for unique building types where ENERGY STAR scores may not exist
3. Compliance Paths: Performance Pathway vs BPIP
A. Performance Pathway
Under this path:
Owners benchmark annually via ENERGY STAR Portfolio Manager, sharing results with DEP by June 1st
Building performance is measured with NN EUI.
Compliance requires hitting the interim target at year 5 and the final target at year 10.
On-site renewables and excluded energy uses reduce the NN EUI metric
Buildings achieving or exceeding the target at deadlines are considered compliant.
B. Building Performance Improvement Plan (BPIP)
For buildings that cannot reasonably reach targets due to technical or economic constraints:
Submit an ASHRAE Level 2 energy audit and a retrofit plan with cost-effective measures.
Simple payback limits: ≤ 25 years (general) or ≤ 10 years (under‑resourced buildings).
Submit BPIP at least 90 days before interim or final deadline.
Continue benchmarking and report on BPIP progress—following the plan grants compliance even if target isn’t met .
4. Maryland Statewide BEPS & Interaction with County BEPS
State versus County Requirements
Maryland’s Climate Solutions Now Act targets commercial and multifamily buildings ≥ 35,000 sf, requiring both energy use and GHG emissions reductions. However, Montgomery County buildings complying with local BEPS are exempt from the state’s BEPS requirements under recent legislation, while still fulfilling benchmark reporting obligations via ENERGY STAR Portfolio Manager to both DEP and MDE.
Aligned dual reporting is facilitated through guidance allowing shared energy exclusions, campus reporting formats, and verification procedures accepted by both county and state authorities.
5. Practical Guidance for Building Owners
Benchmarking & Baseline Setup
Enroll your building (≥ 25,000 sf) in ENERGY STAR Portfolio Manager, categorize by primary property type.
Benchmark 3+ years of data to establish baseline (average of the two highest weather‑normalized Site EUI years)
Track NN EUI and Reductions
Make sure weather normalization is enabled and properly applied.
Subtract credits for onsite renewables, EV charging, parking, and heated pool usage correctly to compute NN EUI
Review percent reduction versus baseline annually, as actual NN EUI values may shift slightly with rolling normalization updates.
Know Your Targets & Timeline
Use Montgomery County’s Performance Requirements Look-Up Tool by address or MBID to find your baseline, interim, and final targets.
Mixed-use buildings must apply area-weighted target calculations across property types.
Understand that if your baseline is over 30% above standard, your final target will only require a 30% reduction
If Not On Track: BPIP
Commission an ASHRAE Level 2 energy audit to identify feasible efficiency or electrification measures.
Create a retrofit roadmap aligned with simple-payback criteria.
Submit a BPIP by the pre-deadline and report annual progress in Portfolio Manager. Compliance is maintained if you’re implementing the plan, even if not meeting numeric targets.
Leverage Financial & Technical Support
Montgomery County Green Bank offers technical assistance, financing, and partnership options for BEPS compliance.
Utility-based incentives (e.g. EmPOWER Maryland) support upgrades.
State/federal tax incentives (e.g. Investment Tax Credit, 179D deduction) may offset capital costs.
DEP maintains a dedicated BEPS Helpdesk for technical assistance
6. Why Montgomery County’s BEPS Matters
Montgomery County’s BEPS program is notable for:
Lower threshold at 25,000 sf, expanding benchmarking to smaller non- and multifamily buildings.
Use of normalized net Site EUI, ensuring fair evaluation across years and accrual of renewable energy benefits.
Offering both Performance Pathway and BPIP, supporting flexibility.
Incorporating final performance caps (30% reduction limit) to avoid overly burdensome targets.
Deference from statewide BEPS requirements, so long as local compliance is met.
Incentivizing energy efficiency investments and renewables adoption without over-prescriptive mandates.
These features together promote predictability, adaptability, and transparency for owners and encourage meaningful reductions in building energy usage.
7. Conclusion
Montgomery County’s BEPS framework offers:
A phased, fair, and flexible approach leveraging weather‑normalized Site EUI with renewables allowances.
Clear interim and final targets tailored per building type, with capped reductions for outliers.
Two compliance routes: the Performance Pathway and BPIP, accommodating a range of economic and technical circumstances.
Seamless integration with Maryland’s state BEPS system through aligned reporting protocols.
Key Recommendations
Register and benchmark via ENERGY STAR Portfolio Manager, share with DEP and MDE.
Rely on Normalized Net Site EUI, not raw Site EUI, for all compliance tracking.
Plan ahead using projected interim and final targets based on your building’s baseline.
If facing difficulty meeting targets, prepare a BPIP and follow it with annual reporting.
Utilize county, utility, and federal resources to reduce energy use and maximize cost-effectiveness.
With diligent benchmarking and early planning, building owners in Montgomery County can achieve BEPS compliance—and unlock long-term benefits like energy savings, occupant comfort, and operational resilience.
