Philadelphia Granting COVID-19 Extensions to 2020 Compliance Deadline for Building Benchmarking

COVID-19 Update

April 16, 2020
Brenda H. Gotanda
MGKF Special Alert

In recognition of the challenges faced by many building owners during the current COVID-19 pandemic, the Philadelphia Office of Sustainability is offering a 3-month extension to the 2020 compliance deadline for building benchmarking, however, building owners must apply by June 1 in order to avail themselves of the extension.  The extension will shift the compliance deadline for reporting from June 30 to September 30, 2020.  The extension request form can be found here.  The Office of Sustainability states that it will accept all requests and cautions that, unless a building owner submits a request, it must still comply with applicable benchmarking requirements by the original June 30 deadline.  Owners of large commercial or multifamily buildings (50,000 square feet and larger) in Philadelphia are required to report their energy and water usage data annually to the Office of Sustainability (benchmark) pursuant to Philadelphia’s Energy Benchmarking and Disclosure Law and regulations. 

Building owners covered by the benchmarking program are reminded that vacancy exemptions are valid for only one year.  Thus, if they received a vacancy exemption last year for calendar year 2018 data reporting, and remained vacant in 2019, they must re-apply for an exemption in 2020 applicable to 2019 data reporting.  If they did not meet the vacancy criteria for calendar year 2019 data, they will need to comply with the benchmarking requirements and report their data this year, unless they meet the criteria for some other exemption.  Exemptions are available for buildings that meet the following criteria, but an exemption application must be submitted to the Office of Sustainability:        

  • If more than 50 percent of the indoor floor space is unoccupied for more than a total of 180 days during a calendar year;
  • If benchmarking or disclosure would cause exceptional hardship or would not be in the public interest, as determined by the Office of Sustainability based upon an application and evidence from the owner; or
  • The building is primarily used for manufacturing or other industrial purposes for which benchmarking results would not meaningfully reflect building energy use characteristics due to the intensive use of process energy (i.e., energy used in the actual manufacturing, production, or processing of a good, commodity, or other material).           

The Office of Sustainability exemption request application can be found here

For questions regarding the Philadelphia benchmarking program, please contact MGKF’s Brenda Gotanda at 484-430-2327.