NJ energy benchmarking: which buildings must report, and by when

Which buildings have to benchmark

NJ energy benchmarking covers class 4A commercial buildings, class 4C apartment buildings designed for five or more families, and state-owned buildings, each over 25,000 square feet, and the BPU builds the list from the state's MOD-IV tax assessment database.

The property class comes from the tax record, not from how a building is marketed or leased. Class 4A is commercial property. Class 4C is apartment buildings designed for five or more families, so rental multifamily is in once it passes the size threshold.

The threshold is over 25,000 square feet, and it applies to each building. The statute covers "each commercial building over 25,000 square feet," so on a campus every building above the line must be included in the owner's Portfolio Manager submission. The Board encourages owners to include their smaller campus buildings but doesn't require it.

Parking counts in two ways. An attached garage's floor area is added to the building's, so a building and garage that together exceed 25,000 square feet are covered. A stand-alone garage over 25,000 square feet is covered in its own right.

Mixed-use buildings with commercial and residential space are covered when they're classed 4A or 4C. The BPU's benchmarking help desk adds that a building spread over more than one tax parcel can be covered even when one parcel alone is under 25,000 square feet, as long as the whole building is over it.

Condos are out. The order excludes class 2 residential property, and condominiums are class 2, so condo buildings are off the list regardless of size. The help desk states that co-ops are not covered either.

Among the other excluded classes: class 4B industrial property, public schools and other school property (classes 15A and 15B), federal, county and local government buildings (class 15C, apart from state buildings), and church and charitable property (class 15D).

To check a specific building, search the Covered Buildings List on the BPU's BEAM portal. The Board directed that the list be updated every year, so it's worth checking each cycle.

The deadline is July 1, for the year before

New Jersey benchmarking reports are due July 1 each year for the prior calendar year; the Board of Public Utilities set that deadline after the first cycle, when 2022 data was due October 1, 2023.

Each report covers a full calendar year, January through December, because the statute asks for the prior calendar year's energy and water use. Calendar 2025 data was due July 1, 2026.

The Board notifies owners of covered buildings every year. For the reporting season covering calendar 2025 data, New Jersey's Clean Energy Program said owners would be notified in the first quarter of 2026, and that the letter contains the building's New Jersey Unique Building Identification number, or UBID.

A sale or an addition during the year doesn't pause the obligation. The Board ruled out exemptions for both, and directed utilities to provide continuous monthly meter data for the full year even when the owner or the tenants change.

Leave room before July 1. The data request runs through each utility serving the building, and if tenant consent is needed, that step waits on other people's signatures.

What you report, and where the numbers come from

You report twelve months of whole-building energy and water use, entered in EPA's ENERGY STAR Portfolio Manager by the July 1 deadline.

When tenants hold their own utility accounts, the owner can't see that meter data, so the order routes it through the utilities. The owner sends a Data Access Request Form to each utility serving the building. The utility identifies the building's meters and applies what the order calls the 4/50 rule.

If the building has fewer than four tenants, or one tenant uses more than 50% of the energy or water, the owner must request each tenant's written consent before the utility releases that data. The utility provides a Consent Letter for this, and an owner who can't reach a tenant can record a good-faith effort on it.

Otherwise the utility aggregates every meter in the building and gives the owner whole-building totals. Aggregation keeps each tenant's usage anonymous, which is the reason the rule exists.

In practice, the rule works out like this. An apartment building with many separately metered units, none using more than half the building's energy, gets aggregated totals without chasing every resident. A single-tenant office building where the tenant holds the utility accounts, or a retail building where the stores hold their own accounts and one draws more than half the power, fails the rule, and the owner has to request each tenant's written consent first.

Water follows the same rule when tenants, rather than the owner, are the water utility's customers. The order notes that buildings typically have a single master water meter in the owner's name.

The 2022 order also flagged the 4/50 rule and the exemption conditions for review in the second program year, so confirm the current version with the BPU before you plan around it.

The owner doesn't have to do the data entry. The order lets the owner designate a third party, such as the property manager, to complete the Portfolio Manager submission. The BPU also certifies NJ Certified Benchmarkers, people who have passed a test on Portfolio Manager and New Jersey's program rules, and publishes the list on its BEAM help desk.

What the ENERGY STAR score does and doesn't tell you

The ENERGY STAR score runs from 1 to 100: 50 is median energy performance, and 75 or higher marks a top performer that may be eligible for ENERGY STAR certification.

The comparison is against other buildings nationwide with the same primary use, not other New Jersey buildings. For most property types, EPA builds that peer group from the federal Commercial Buildings Energy Consumption Survey (CBECS). For a few, such as hospitals and senior living communities, it relies on industry surveys.

Not every building gets a score. EPA publishes the property types eligible for one, and office, hotel, retail store, supermarket and multifamily housing are among them. A covered building whose property type isn't on EPA's list still has to report; it just won't receive a 1 to 100 score.

The score is a whole-building number. EPA describes it as assessing how the building performs as a whole, given its physical attributes, operations and occupancy.

That is also its limit. A low score says the building performs worse than the median for its type. It can't say whether the cause is a 30-year-old boiler, a rooftop unit with a seized economizer, a control left in manual, or simply how the building is run.

Finding the cause takes someone walking the building and reading the plant. That is the start of an energy audit, not part of benchmarking.

Exemptions, and what happens if you miss it

Owners can request an exemption for a new building, a demolition, a building unoccupied for a full 365 days, a foreclosure or bankruptcy filed during the reporting year, a sale before the reporting year, or other good cause.

New buildings get a full year of operation first. A building isn't added to the Covered Buildings list until the second year after its year-built in MOD-IV. The order's example is a building with a year-built of 2022 that first reports 2023 data, due July 1, 2024.

Each exemption needs evidence: a certificate of approval for demolition, an affidavit or certification of non-occupancy, or proof of the foreclosure or bankruptcy filing. Good cause covers cases such as a building that is under the size threshold or an error on the list.

Requests go through the exemption request form on the BPU's BEAM portal, which lists a sale as a reason, with a deed of sale as the example evidence. For the reporting season covering calendar 2025 data, New Jersey's Clean Energy Program told owners whose building was sold before 2025 to request an exemption. A sale during the reporting year doesn't qualify.

On enforcement, the Board's 2022 order adopted Staff's recommendation that no fines be levied. For the first two program years, it gave owners a 90-day grace period after the deadline before they were deemed nonresponsive.

After those two years, the order directed Staff to analyze compliance rates and re-evaluate how to motivate compliance. The order doesn't say what applies after that, so for the current position ask the BPU's benchmarking help desk on the BEAM portal rather than relying on the 2022 terms.

From a benchmark to an incentive model

A benchmark shows how a building compares with its peers, but it doesn't size an incentive: New Jersey's custom and engineered utility pathways pay on the modeled saving for the specific equipment replaced, and that model starts from the same twelve months of bills.

The two ask for overlapping data. Both need a full year of the building's energy use, and both run into the same practical problem: the electric and gas history often sits with two different companies.

What each does with it differs. Benchmarking compares the whole building with a national peer group. On the custom and engineered pathways, an incentive model looks at specific plant, what it uses now and what its replacement would use, and the utility pays on the gap; prescriptive rebates use a published per-ton or per-MBH rate instead.

That makes a benchmark a useful prompt rather than an answer. If the building compares poorly and its boiler, chiller or rooftop units are old, the next step is a survey of that plant, which is where an incentive figure comes from.

To be clear about scope: we don't file benchmarking reports. The owner does, or a third party the owner designates, such as a property manager or an NJ Certified Benchmarker.

Our work is the incentive side of an HVAC replacement: the survey, the energy model, the utility application and the coordination. Licensed partner contractors carry out the installation.

If you've already pulled a year of bills for benchmarking, keep them together. On custom and engineered HVAC projects the incentive has to be approved before any equipment is bought, and that year of data is what the model is built from.