BEPS Compliance and Enforcement Guidebook for Compliance Cycle 1
Chapter 3.2 - Standard Target Pathway

The Standard Target Pathway is a performance-based compliance method designed for buildings in a high-performing property type group. In the Compliance Cycle for a building on the Standard Target Pathway, the building is required to meet or beat the Standard for its property type in the evaluation year. Similar to the Performance Pathway, the Standard Target Pathway is designed to give buildings flexibility in how they meet the energy performance requirement, meaning that building owners can choose and implement the EEMs they think are best for reducing energy consumption in their buildings. This Pathway was developed to address the concern that at higher levels of performance, there is less opportunity for cost-effective EEMs and that buildings may require a higher level of investment to achieve significant energy savings.

3.2.1 – Standard Target Pathway Eligibility

A building must be of a “high-performing” property type to be eligible for the Standard Target Pathway. A high-performing property type includes those property types where the Standards are at least as energy efficient as the national median. The national median is an ENERGY STAR Score of 50, or for property types that cannot receive a Score, the national median Source EUI. Many buildings in the District subject to BEPS belong to a “high-performing” property type and will be eligible to select the Standard Target Pathway. For the Compliance Cycle that begins January 1, 2021, the property types that can use the Standard Target Pathway are listed in Table 6.
 
Table 6 – Property Types Eligible to use the Standard Target Pathway in Cycle 1

 
In addition, College/University/Hospital campuses that have floor areas primarily composed of property types listed in Table 6 are also eligible to use the Standard Target Pathway.
 

3.2.2 – Standard Target Pathway Metrics and Evaluation

A building on the Standard Target Pathway is evaluated using the same metric as the Standard for its property type (Figure 6). Building owners should refer to the 2021 Building Energy Performance Standards (Title 20 of the DCMR, Section 3530) to identify the metric used for their property type. More than 90% of buildings in the District will use the ENERGY STAR Score metric.
 
Figure 6 – Standard Target Pathway Metrics

 
Examples of energy performance evaluations under the Standard Target Pathway are listed below:
• A building that has its Standard measured in an ENERGY STAR Score must increase its ENERGY STAR Score to be equal to or higher than the Standard for that property type. For example, if the Standard for an Office building is 72, a building following the Standard Target Pathway with an ENERGY STAR Score of 68 at the beginning of the Compliance Cycle must raise its Score to at least a 72 by the end of the Cycle to comply.
• A building that has its Standard measured in Normalized Source EUI must lower its Normalized Source EUI so it is equal to or lower than the Standard for the property type. For example, an “Other - Public Services” building with a Normalized Source EUI of 100 kBtu/ft² at the beginning of a Compliance Cycle must lower its Normalized Source EUI to at least 87 kBtu/ft² to comply.
• A building that has its Standard measured in unadjusted Source EUI must lower its Source EUI so it is equal to or lower than the Standard for the property type.
 
As described in Section 2.4, the COVID-19 PHE delay provides additional time for building owners to achieve the energy performance requirements. Applying the delay to the Standard Target Pathway, successful compliance requires meeting or exceeding the building’s Standard in CY2026, as shown in Table 7.
 
Table 7 – Standard Target Pathway Evaluation Year Options

 

3.2.3 – Standard Target Pathway Reporting Requirements

As explained in Section 2.1, a building that uses the COVID-19 PHE delay has its reporting/verification deadlines extended by one year. Buildings with this delay following the Standard Target Pathway must complete the reporting/verification requirements by the deadlines in Table 8.
 
Table 8 – Standard Target Pathway Reporting Requirements

 
As mentioned in Section 3.1.2, the building owner demonstrate the building’s energy use through a complete and accurate District Benchmark Results and Compliance Report for the relevant calendar years. Building owners must complete all District benchmarking requirements, including third-party data verification requirements, for BEPS performance evaluation.
 
Additionally, DOEE requires all buildings under a Standard Target Pathway to submit a Completed Actions Report through the Portal. This Report includes a short survey of the EEMs (e.g., list of EEMs implemented; cost(s) of EEMs; date EEM was implemented; and estimated site energy savings from each EEM, if available) the building owner implemented to meet the energy performance requirements. This report must be filed regardless of whether a building meets the property type’s Standard and will be used by DOEE to improve future iterations of the BEPS Program.
 

3.2.4 – Contingency if EPA Changes ENERGY STAR® Models

ENERGY STAR Scores are established and modeled by the EPA, and it is not uncommon for EPA to update these models. These changes result in overwriting previous Scores—as was the case in 2018 when EPA released updated ENERGY STAR Score models and new source-site factors through Portfolio Manager. As a result, some buildings saw major changes in their Score (e.g., Office Scores fell an average of 10 points). EPA has indicated that it plans to implement updated scoring models and new source-site factors sometime in the next five years.
 
Changes to ENERGY STAR Score models mid-Compliance Cycle would create a challenge for building owners and DOEE in measuring, determining, and implementing the BEPS Program. For example, while a building may meet the Standard under the current ENERGY STAR metrics, it may not meet the requirements if the building’s ENERGY STAR Score is calculated using a different metric.
 
DOEE cannot predict the specific effect until EPA releases updated ENERGY STAR Score models but has developed steps to mitigate uncertainty. DOEE will request buildings selecting the Standard Target Pathway to submit additional information from Portfolio Manager documenting the basis of their ENERGY STAR scores. For buildings approved for the Standard Target Pathway, DOEE will calculate the Source EUI reduction required for them to meet a specific ENERGY STAR Score (e.g., for all Offices, the Source EUI reduction required to go from an ENERGY STAR Score of a 65 to a 71 is 9%). Using this calculation, DOEE can track a building’s progress towards a specific target, regardless of the metric change. DOEE can also recalculate a building’s Source EUI to match past or current source-site factors.
 
For those buildings on the Standard Target Pathway, updated ENERGY STAR Score models cannot serve as the basis for satisfying the energy performance requirements or calculating adjustments to the maximum alternative compliance penalty. For example, if an ENERGY STAR Score update for an Office building during Compliance Cycle 1 changes its ENERGY STAR Score to 72 (71 is the score level established as the BEPS for the Standard Target Pathway for Offices), the building will not be treated as having met the energy performance requirement of the Standard Target Pathway for Cycle 1.
 
Additionally, DOEE will not reassess Pathways available to a given property type as the result of a Score change during a Compliance Cycle. For example, if the Standard of a property type drops below the national median—which would mean that property type is not eligible to use the Standard Target Pathway—DOEE will continue to allow buildings belonging to that property type to follow the Standard Target Pathway. In the opposite scenario, if a property type’s Standard is below the national median—and therefore is ineligible for the Standard Target Pathway—but then rises above the national median as the result of the metric update, DOEE will not allow buildings in that property type to change to the Standard Target Pathway mid-cycle. DOEE will provide additional information when EPA announces a future model update.