Benchmarking is the foundation of Regulation 28 compliance in Colorado. If you own or manage a commercial building over 50,000 square feet, you must submit annual benchmarking data starting November 1, 2026. Missing this deadline—even if you’re working on a compliance pathway—triggers immediate penalties.
This guide walks you through everything you need to know about setting up and maintaining ENERGY STAR Portfolio Manager for Colorado’s mandatory benchmarking.
What Is Benchmarking?
Benchmarking is the standardized measurement of your building’s energy and water use compared to similar buildings. Under Regulation 28, CDPHE requires all covered buildings to:
- Collect 12 months of energy use data (ideally calendar year or prior fiscal year)
- Normalize it for weather and operating patterns
- Calculate Energy Use Intensity (EUI) and Greenhouse Gas Emissions Intensity (GHG-I)
- Compare your building to national and Colorado-specific benchmarks
ENERGY STAR Portfolio Manager is the EPA-approved platform CDPHE has designated for Colorado submissions. All covered buildings must use it (or another CDPHE-approved tool, though Portfolio Manager is standard).
Setting Up Your Portfolio Manager Account
Step 1: Create Your Account
Go to portfoliomanager.energystar.gov and register with a dedicated email address for your organization. Use a role-based email (building-manager@company.com) rather than a personal email—this ensures the account survives personnel changes.
Step 2: Add Your Building
Portfolio Manager will ask for:
- Building address
- Gross square footage
- Primary building use type (Office, Retail, Warehouse, Multifamily, Hotel, etc.)
- Secondary uses (if applicable, e.g., “Office with 30% Retail”)
- Number of floors
- Year built (if known)
- Annual operating hours
Be precise with square footage. Portfolio Manager’s benchmarks are sensitive to size. A 49,999 sq ft building is not covered by Regulation 28; 50,000+ is. Similarly, if you misreport your primary use, your EUI target may be completely wrong.
Step 3: Configure Utility Accounts
This is critical. Portfolio Manager uses actual utility data to calculate your building’s energy profile. You’ll need:
For electricity:
- Account number with your utility (Xcel, Black Hills, DMEA, etc.)
- 12 months of monthly billing data (or ask your utility for an electronic data share)
- Any on-site solar or renewable generation data
For natural gas:
- Account number
- 12 months of monthly billing data
- Ccf (hundred cubic feet) or therms, not dollars
For water (optional but valuable for benchmarking):
- 12 months of usage data from your water/wastewater provider
For district steam/chilled water (if applicable):
- Consumption data from your district provider
Step 4: Reconcile and Verify
After entering 12 months of utility data, Portfolio Manager will:
- Flag outliers or missing data
- Prompt you to enter weather normalization data (usually auto-populated)
- Calculate your EUI (kBtu/sq ft/year) and GHG intensity
- Compare you to ENERGY STAR benchmarks
Review for accuracy. If your calculated EUI seems wrong:
- Check that all 12 months are entered
- Verify your square footage
- Confirm your building use type
- Look for data entry errors (e.g., 123,456 vs. 1,234.56)
Getting Your Utility Data
The Challenge: Utility companies don’t always make historical data easy to access, and some Colorado utilities have different portals.
Xcel Energy (covers most of Front Range and northeast Colorado):
- Log into your account at xcelenergy.com
- Go to “Usage & Billing” → “View Usage Data”
- Export as CSV or manually record 12 months of kWh and therms
- If you need data older than 24 months, call 1-800-895-4999 and request historical billing
Black Hills Energy (southern and southeastern Colorado):
- Access your account at blackhillsenergy.com
- View monthly usage in the billing section
- Request older data by contacting customer service
Municipals and Coops (DMEA, PECO, La Plata Electric, etc.):
- Log into your account portal
- Check your options for data export or historical reports
- Call customer service if online access is limited
Pro tip: Request a 3-year history if available. Regulation 28 requires 2021 baseline data plus current year, but having 2021–2025 gives you a clearer picture of your building’s trends.
Choosing the Right Building Use Type
This matters more than you think. Your assigned building use determines your EUI target under Pathway 1 and affects your scoring under Pathway 2.
Common use types in Colorado:
| Use Type | Definition |
|---|---|
| Office | Mainly office space; 10+ employees or 5,000+ sq ft |
| Retail | Mostly retail sales floor; shopping centers, department stores |
| Mixed-Use | Multiple primary uses (e.g., office + retail ground floor) |
| Multifamily | Apartments, condos; 4+ units, excludes single-family |
| Hotel | Hotels, motels, guest houses |
| Warehouse | Unrefrigerated storage; distribution, general warehouse |
| Refrigerated | Cold storage, freezer facilities; food, pharmaceuticals |
| Healthcare | Hospitals, medical offices, urgent care |
| Education | Schools, colleges, universities |
| Parking | Parking garages, parking lots with structures |
If your building truly serves multiple uses, use the “Mixed-Use” designation and specify the percentage breakdown. Don’t force-fit a 70% office / 30% retail building into pure “Office” and leave money on the benchmarking table.
Submitting Your 2026 Benchmarking Data to CDPHE
Annual Deadline: November 1
Starting November 1, 2026, you must formally submit your benchmarking report to CDPHE. The process:
- Complete your Portfolio Manager entry with full 12-month data
- Generate your official Portfolio Manager report (Portfolio Manager can do this automatically)
- Download the CDPHE-formatted benchmarking template (available on CDPHE’s website)
- Fill in required fields: building address, sq ft, use type, EUI, GHG-I, baseline year, utility account numbers
- Submit via CDPHE’s Regulation 28 portal by 11:59 p.m. on November 1
Missing the November 1 deadline triggers an automatic penalty filing. There are no grace periods, and CDPHE does not accept late submissions past November 1.
Common Benchmarking Mistakes to Avoid
- Wrong square footage: You input 99,500 sq ft instead of 100,500. Now your EUI target is misaligned.
- Missing months: Your data only covers January–October. Incomplete 12-month data is flagged by Portfolio Manager and rejected by CDPHE.
- Utility data errors: You enter electricity in therms instead of kWh, or confuse “100 therms” with “100 ccf.” Your EUI will be wildly inaccurate.
- Wrong building use type: Your medical office building is entered as “Office” instead of “Healthcare.” EUI targets differ by 50+ percent.
- Not accounting for major changes: Your building had a 4-month renovation or closure. Portfolio Manager has a “special adjustments” feature—use it to flag unusual operating periods.
- Skipping water data: Not required, but water usage (if high) can signal operational issues and affects total GHG if water treatment is carbon-heavy.
Year-to-Year Benchmarking: The Ongoing Cycle
Benchmarking isn’t a one-time thing. Every November 1, you’ll submit the prior calendar year’s data. So:
- November 1, 2026: Submit 2025 energy data (your first official submission)
- November 1, 2027: Submit 2026 energy data
- November 1, 2028: Submit 2027 energy data
- …continuing annually
During this time, CDPHE will also evaluate whether your building is trending toward compliance. If you’re not making progress, you may face compliance challenges at your 2026/2027 deadline.
Using Benchmarking Data for Compliance Pathway Planning
Once you have accurate benchmarking data, use it to model your compliance pathways:
Pathway 1 (EUI Target): How far below the target are you now? Do you meet it today?
Pathway 2 (Percent Reduction): How much have you improved since 2021? Can you achieve another 13% reduction by 2026?
Pathway 3 (GHG Target): If you have on-site solar or are on a green utility rate, how does that affect your GHG profile?
Pathway 4 (Percent GHG Reduction): How much has your GHG intensity improved since 2021, factoring in grid decarbonization?
Most buildings benefit from a professional energy audit to model all four pathways and recommend the most achievable option.
Getting Help with Your Benchmarking
If setting up Portfolio Manager feels overwhelming—managing multiple utility accounts, reconciling data, understanding which fields are required—that’s normal. Many building owners hire energy consultants to handle the administrative work.
We offer flat-fee benchmarking setup and annual submission support for Colorado buildings statewide. If your 2026 deadline is approaching and you’re not set up yet, now is the time to engage support.
The November 1, 2026 deadline is firm. Buildings that have benchmarking data ready will qualify for compliance pathways and have options. Buildings caught flat-footed will be marked non-compliant immediately.
Next step: Gather your 2021–2025 utility data and create your Portfolio Manager account today.