Third Party Verification - Benchmarking & Third-Party Verification

The Clean Energy DC Omnibus Act of 2018 expanded the benchmarking requirements to cover smaller buildings and added data verification requirements. Benchmarking helps building owners/managers better understand and quantify how their buildings are using resources, which can drive energy efficiency upgrades, increase occupancy rates, and property values. Having a building’s benchmarking data verified by a third party ensures that buildings are being evaluated through fair and accurate information.

For an overview of the third-party verification requirement, DOEE highly recommends watching our recorded webinar that walks through who can be an approved verifier, what data needs to be verified, and how to report that verification to DOEE. You can also download the accompanying slides to access helpful links and resources. Additional third-party verification webinars aimed at both building owners and third-party verifiers can be found on our benchmarking resources page under "Video trainings for benchmarkers."

What is third-party verification? 

Third-party verification is the process of having an entity with no relationship to either the building owner/manager or benchmarking reporter review property data to identify and correct any gaps or errors in the property’s benchmarking reports.

20 DCMR § 3515 requires building owners or their designees shall perform third-party verifications of their District Benchmark Results and Compliance Reports every three (3) years.

How do I get my data verified? 

You will need an Approved District Data Verifier (ADDV). The ADDV must have no relationship to either the building owner/manager or benchmarking reporter. Provide them with the ENERGY STAR Data Verification Checklist and any appropriate supporting documentation. You can find a sample Data Verification Checklist available online.

You can ask the ADDV to review your Portfolio Manager account and supporting documentation for errors or gaps, and you should provide necessary documentation to correct any errors or gaps identified by the ADDV.

The ADDV must certify on the final page of the Data Verification Checklist that the Data Verification Checklist is complete and accurate by signing and dating it and listing any credential, license, or certification information that demonstrates the verifier’s eligibility to act as an ADDV.

ADDVs are not required to conduct a site visit.
ADDVs are not required to complete the waste and indoor environmental quality section of the Data Verification Checklist.

Can I use the verification from my ENERGY STAR® Certification?

It depends. If the data used when the EPA verified your building for ENERGY STAR Certification has at least six (6) months of data from the same calendar year as the DOEE Verification requirement, then you can use the same verification.

The U.S. Environmental Protection Agency would be the Approved District Data Verifier for the purpose of this section.

How do I report my ENERGY STAR verification for the purpose of DOEE’s Verification requirement?

Make sure that the data verified by the EPA has at least six (6) months of data from the same calendar year as DOEE’s requirements.

Include the following information in the Portfolio Manager “Verification” section:

• The date that the building received ENERGY STAR Certification (enter under "Date of Verification");
• Period Ending Date for Year Verified, which must include a minimum of six (6) months of the calendar year requiring data verification;
• The name, title, and email address of the licensed professional who verified the data for the ENERGY STAR Certification;
• The name and issuing state or organization of their credential, license, or certification;
• Their license or certification number.

Where do I find the Data Verification Checklist?

In Portfolio Manager, select the “Reporting” tab. On the right side of the screen there are multiple ENERGY STAR Performance Documents. Select the “Data Verification Checklist.”

Under Select Report(s) to Download, check the box for “ENERGY STAR Data Verification Checklist (energy data only).” Select the name of your property, timeframe for the report, and appropriate contacts. Complete this step by clicking “GENERATE & DOWNLOAD REPORT(S).”

• Timeframe should be set as “Single Year ending Dec 31 20XX.”
• Primary Contact is the main point of contact for the property. This is the person who people would contact for questions about the property.
• Property Owner is the organization who owns the property/building.
• Licensed Professional is the person who validates the property information that appears on the report.

Once your report has been generated you will see a message in a green box at the top of your page. Your Data Verification Checklist should generate and will automatically pop-up on your screen. If your report does not automatically pop up, review your internet browser pop-up settings.

Who can verify my data?

An Approved District Data Verifier (ADDV) must possess at least one (1) of the following licenses, credentials, or certifications, and be in good standing with the licensing, credentialing, or certifying entity at the time that the data verification is conducted:

• Professional Engineer (PE) issued within the United States
• Licensed Architect issued within the United States
• Certified Energy Manager (CEM)
• Building Energy Assessment Professional; or
• DOEE has the authority to add new qualifications, and we will detail as new credentials are added. (As of January 2025, DOEE has not added any new licenses, credentials, or certifications to this approved list.)
• The U.S. Environmental Protection Agency is an Approved District Data Verifier for the purpose of this section when it performs data verification as part of an ENERGY STAR Certification that uses data including at least six (6) months of the calendar year for which this section requires data verification.

Your Approved District Data Verifier shall NOT be:

• The building owner
• An employee of the building owner
• The building owner’s designee, or an employee of that designee, who prepares or submits benchmarking information in Portfolio Manager for the building owner.

If you have questions about whether an entity constitutes a third-party, please submit a Helpdesk Ticket.

Where can I find a third-party data verification provider? 

Although DOEE can not provide recommendations for vendors, our grantee, the Building Innovation Hub has created a notification system to distribute project opportunities to local service providers and contractors via an email distribution list.

To contact the Building Innovation Hub:

• Fill out an Owner Submission Form, part of the Hub's Vendor Matchmaking services. Once the Hub receives this form, they will distribute it to their list of vendors who can choose if they would like to respond.

Additionally, the EPA has a list of Licensed Professionals that offer Cost-Free Verification of ENERGY STAR Applications for school districts, affordable housing owners, and religious and non-profit organizations.

In order for your ENERGY STAR® Certification to count towards DOEE's third-party verification requirement, you MUST have at least six months of CY2023 data reviewed as part of your ENERGY STAR® Certification. Please refer to "Can I use the verification from my ENERGY STAR® Certification?" above for more details.

How do I submit my verification to DOEE?

In your Portfolio Manager account, go to the Details tab for your property and click the “Add Verification Information” in the Verification section at the bottom of the page to provide the following information:

• Period Ending Date for Year Verified;
• The date of the verification;
• The name, title, telephone number, and email of the ADDV; and
• The name of the ADDV’s credential, license, or certification
• The issuing state or organization of the above qualification
• The license or certification number of the above qualification

You may either enter information directly in the Portfolio Manager Verification Information fields, or if the verifier is part of your Portfolio Manager contacts you can select their name from the "Verified By" dropdown. If selecting from your contacts, you should double-check that all required fields have been filled out.

You do not need to submit the checklist itself, only the above confirmation of verification. However, the building owner/designee MUST keep a signed copy of the Data Verification Checklist and all supporting documentation of the Report for at least three (3) years from the date that the Report is submitted, and MUST be able to provide a copy of those records to the Department upon request.

How often does my data need to be verified?

All buildings covered by the District's benchmarking law will be required to be third-party verified every 3 years starting in 2024 with their calendar year 2023 data. Third-party verification must be completed and submitted on the April 1 reporting deadline of each verification year (2024, 2027, 2030, etc.).

What standards should verifiers use to verify the data?

ADDVs should reference the Licensed Professional’s Guide: Understanding the Roles and Requirements for Verifying Commercial Building Applications for ENERGY STAR® Certification.
• The Indoor Air Quality portion of the checklist is NOT required.
• On-site visits are NOT required.

While all use details will automatically populate on the Data Verification Checklist, for CY2024 (2023 data) DOEE will only be reviewing the verification of use details that impact a building’s EUI or ENERGY STAR Score. If your verifier does not verify a use detail that does not impact EUI metrics or ENERGY STAR Score, they should leave the checkbox blank. All property use details that impact a building’s ENERGY STAR Score or its eligibility to receive a Score (denoted by a blue star) must be verified.

ADDVs should confirm the benchmarking provider has followed DOEE’s guidance for measuring Gross Floor Area.

ADDVs may open a Helpdesk ticket to request additional guidance on specific questions.

What should a verifier do if they identify errors in the data they are verifying?  

What should a building owner (or building owner’s designee) do if a verifier identifies errors in their reported data?  

• Per 20 DCMR 3515.7, the building owner or their designee may request that an Approved District Data Verifier (ADDV) reviews the Portfolio Manager entries and supporting documentation provided by the building owner or their designee to identify any errors or gaps in the data. If after reviewing the Portfolio Manager data the ADDV does identify errors, the building owner or their designee should work directly with the ADDV to correct errors and fill gaps.

• Updates to the data should be done by the building owner or their designee who submits the benchmarking report on behalf of the building owner, not the ADDV.

• If the errors found by the verifier impact past District Benchmarking Results and Compliance Reports, such as misreported Gross Floor Area, misreported property use details, or missing energy meters, then DOEE must be notified of the intended corrections via a formal Benchmarking Data Correction form. Please be prepared to provide supporting documentation and/or narrative that validate the updates to your historic data (such as accepted GFA measurements or an explanation of what energy meters were not previously reported). Errors that do not impact past District Benchmarking Results and Compliance Reports, such as a misreported month of energy data for the year being verified, or updates to use details for the year being verified, do not require the submission of a correction form.

• After corrections are made by the building owner or their designee in Portfolio Manager, a new Data Verification Checklist should be generated so the ADDV can certify the final page by signing and dating it and listing any credential, license, or certification information that demonstrates the verifier’s eligibility to act as an ADDV. (20 DCMR 3515.8)

• If the ADDV identifies errors with the data and the building owner or their designee does not update the data in Portfolio Manager, there are a number of enforcement actions that may be taken:

20 DCMR 3516.1(b) Failure to submit accurate and complete benchmarking information in a District Benchmark Results and Compliance Report. Building owners are subject to penalties of up to $100/day every day the building is out of compliance following the April 1 reporting deadline.
20 DCMR 3516.1(e) Failure to update or correct information for a submitted District Benchmark Results and Compliance Report within thirty (30) days of receiving the new information. Building owners are subject to penalties of up to $100/day every day the building is out of compliance following the 30-day correction period.

• For buildings that are subject to BEPS Period 1 and are currently in the BEPS Compliance Cycle (i.e. did not meet BEPS), per 20 DCMR § 3521.3, a building owner may be assessed the maximum alternative compliance penalty of $10/square foot of gross floor area of the building, regardless of the building’s performance relative to its pathway target, if the building owner knowingly withholds information or submits inaccurate information to DOEE.

Data Verification Supplemental Worksheet 

Per 20 DCMR 3515.8, third-party verifiers must complete and sign the EPA ENERGY STAR Data Verification Checklist generated for each building being verified. This supplemental worksheet is designed to assist third-party verifiers certify each required component of the Data Verification Checklist and prompt discussions with building owners/managers on how property use details were determined and how the building is reporting energy consumption.

This worksheet is NOT meant to be used in place of the ENERGY STAR Data Verification Checklist and is not comprehensive of everything that may be listed on a Data Verification Checklist. Third-party verifiers may request additional documentation to verify gross floor area, property use details, and energy consumption at their discretion. Per 20 DCMR 3515.3 the building owner, or the building owner’s designee, must make the ENERGY STAR Data Verification Checklist, and any appropriate supporting documentation, available to their third-party verifier. To ensure an easy and efficient verification process, building owners and/or verifiers are encouraged to collect the information outlined below. This worksheet is meant to be filled out for each unique property. This worksheet does not need to be sent to DOEE and is meant as a helpful guide as a building goes through its verification.

While all use details will automatically populate on the Data Verification Checklist, for CY2024 (2023 data) DOEE will only be reviewing the verification of use details that impact a building’s EUI or ENERGY STAR Score. If your verifier does not verify a use detail that does not impact EUI metrics or ENERGY STAR Score, they should leave the checkbox blank. All property use details that impact a building’s ENERGY STAR Score or its eligibility to receive a Score (denoted by a blue star) must be verified.

Download Supplemental Worksheet

Third-Party Verification for Benchmarking FAQs