Beginning in 2020, Los Angeles building owners will be required to submit energy audit and retro-commissioning reports to the Department of Building and Safety under the city’s Existing Buildings Energy and Water Efficiency (EBEWE) Program. These new requirements mark the second phase of the 2016 EBEWE Program and are a central strategy in achieving the emissions reduction targets set forth in the city’s 2015 Sustainability Plan. Although the EBEWE Program will likely see changes as a result of the 2019 ‘Green New Deal’ update to the city’s sustainability plan, building owners are still expected to comply with existing EBEWE compliance deadlines.
What is the EBEWE Program?
Under the EBEWE Program, building owners are required to track whole building energy and water usage, report on usage, and in some cases to undergo energy audits, retro-commissioning or efficiency upgrades. Implementation of the program currently consists of two phases:
Phase I: Energy & Water Benchmarking
In phase one, energy and water benchmarking and reporting requirements were gradually phased in for Los Angeles’ building stock. As a management practice, benchmarking involves tracking a building’s key performance indicators and comparing current performance against past performance or to the performance of other similar buildings. As of 2019, all privately owned buildings 20,000 square feet or greater and all city owned buildings 7,500 square feet or greater are required to submit annual benchmark reports to the city using Energy Star Portfolio Manager.
Phase II: Audits & Retro-commissioning
Beginning in 2020, phase two of the EBEWE Program will require all covered buildings to undergo audits and implement retro-commissioning measures in order to improve building efficiency and performance. Unless an exemption is demonstrated, building owners and operators will be required to comply with this requirement on a five-year cycle as determined by the property’s Assessor Identification Number (AIN).
|AIN Ending In||First Compliance Period for Energy Audit and Retro-Commissioning Requirement|
|0||2020: January - June|
|1||2020: July - December|
|2||2021: January - June|
|3||2021: July - December|
|4||2022: January - June|
|5||2022: July - December|
|6||2023: January - June|
|7||2023: July - December|
|8||2024: January - June|
|9||2024: July - December|
How to Comply with the Full Scope of EBEWE Program
There are six main steps that building owners and operators must now follow in order to comply with the EBEWE Program.
Step 1: Track Whole Building Energy and Water Usage
The first step in complying with the EBEWE Program requires collecting whole building data on annual energy and water usage. In most cases, building owners can access aggregated whole building energy and water usage data directly from the Los Angeles Department of Water and Power (LADWP) and SoCalGas. The collection of utility and building data can also be automated using an Energy Management Information Systems like BuildingOS.
Building owners should note that residential buildings with fewer than 5 tenants and commercial buildings with fewer than 3 tenants are required to obtain tenant consent prior to obtaining energy and water usage data. For this reason, it is advised to notify tenants early and to have a process in place to facilitate the transmission of information.
Step 2: Complete Benchmarking Report Using Energy Star Portfolio Manager
As of June 2019, all privately owned buildings 20,000 square feet or larger are required to submit an annual energy and water benchmarking report to the Los Angeles Department of Building and Safety. The annual report must be completed using the EPA’s Energy Star Portfolio Manager (ESPM), and includes descriptive information about the covered building as well as energy and water consumption data that is later made public by the city.
Exemptions may apply if the building is unoccupied, scheduled for demolition, or the building did not receive any energy or water services for the entire calendar year required to be benchmarked.
Step 3: Undergo Energy & Water Audits
All covered buildings must complete both an energy and water audit. Energy audits must meet or exceed ASHRAE level II audit standards and be performed under the supervision of a California licensed engineer or architect. At minimum, energy audits must evaluate (1) heating, ventilation, air conditioning (HVAC) systems and controls, (2) indoor lighting systems and controls, (3) water heating systems, and (4) any on-site renewable energy systems.
Water audits must conform with industry standard practices including the ASHRAE Guideline 0.2 Commissioning Process for Existing Systems and Assemblies. As with the energy audit requirement, all water audits are to be performed under the supervision of a California licensed engineer or architect. At minimum, the water audit must evaluate (1) potable water distribution systems, (2) landscape irrigation systems, (3) water reuse systems, and (4) water features.
Step 4: Implement Energy & Water Retro-Commissioning Measures
In accordance with recommendations made in the applicable energy and water audit, each covered building is required to implement retro-commissioning measures to improve building efficiency and performance.
Step 5: Complete Energy Audit & Retro-Commissioning Report
After completing the audit and retro-commissioning requirements, each covered building must confirm compliance by submitting a report signed by a California licensed engineer or architect to the Department of Building and Safety. The report must include:
• Dates that the audit(s) and retro-commissioning were performed;
• Contact information for the auditor and retro-commissioning provider;
• Information on the base building systems and equipment subject to the audit and retro-commissioning;
• A list of possible retro-commissioning measures, the cost of each measure, and the estimated savings;
• A list of the retro-commissioning measures that were completed;
• Functional performance testing reports;
• Information on any operational training that was performed; and
• Confirmation that an ASHRAE level II energy audit was performed.
Significantly, energy audit and retro-commissioning is not required under the EBEWE Program if the building owner can demonstrate that the covered building meets a minimum efficiency threshold. Exemptions are most commonly demonstrated by certifying that the building has received an Energy Star Certification from the EPA for the reporting year or for two out of three of the previous years.
Step 6: Maintain Historical Records
Lastly, building owners are required to maintain historical records related to benchmarking, audits and retro-commissioning. All relevant records must be maintained for up to five years and must be furnished to the new owner upon the sale of the property.
What to Expect If You Fail to Comply
Los Angeles building owners and operators can expect two penalties for failing to comply with the city’s energy and water benchmarking ordinance. First, under the transparency piece of the policy, non-compliant properties will be publicly identified and published. A second enforcement mechanism exists in the form of a nominal monetary fine.
How Modern Energy Management Practices Can Improve Performance And Avoid The Need For Energy Audits
While energy audits are useful in identifying opportunities to improve building performance, the opportunities identified are also at risk of quickly becoming obsolete. This is due to the fact that energy audits are performed at a set point in time without the ability to anticipate future changes in building performance due to occupant behavior, extreme weather events, equipment failures, and more. Implementing modern energy management practices can help to avoid the need for energy audits by continuously identifying savings opportunities through real-time building systems analysis made possible through advanced submetering and the implementation of Energy Management Information Systems like BuildingOS.
Unlock Savings Opportunities With Our Building Energy Management Solution
There are many ways to reduce energy usage and carbon emissions to help comply with Los Angeles’ Existing Building Energy and Water Efficiency Program, but perhaps one of the most important step is fully understanding your current energy and water usage – and that’s where we come in. BuildingOS is a comprehensive software platform that centralizes all of your building systems and utility data, automates Energy Star reporting, and allows you to understand and act on real-time data to continuously improve operational efficiency and reduce energy consumption. Want to see how BuildingOS can help improve your building portfolio? Contact us today!