If your building is 50,000 square feet or larger, you’re already required under Colorado Regulation 28 (5 CCR 1001-32) to benchmark your energy use annually and report to the Colorado Department of Public Health and Environment (CDPHE). The tool you’ll use is ENERGY STAR Portfolio Manager — the EPA’s free, web-based platform.

Most building owners find the setup takes 2–4 hours the first time. After that, annual updates take under an hour. This guide walks you through the full process so you don’t lose time to trial and error.

What Is ENERGY STAR Portfolio Manager?

ENERGY STAR Portfolio Manager is a free online platform maintained by the U.S. Environmental Protection Agency (EPA). It lets you track energy and water consumption, calculate Energy Use Intensity (EUI), generate ENERGY STAR scores (where applicable), and produce the standardized reports that CDPHE requires for Regulation 28 compliance.

Colorado uses Portfolio Manager as the mandatory reporting platform. There is no alternative. You cannot submit benchmarking data to CDPHE through any other system.

The metric that matters most for Regulation 28 is Site EUI — total energy consumed per square foot of gross floor area, measured in kBtu/sq ft/year. This is the number your building must hit or beat by the 2026 and 2027 compliance deadlines under Pathway 1, or demonstrate a trajectory toward under Pathways 2, 3, and 4.

Step 1: Create Your Portfolio Manager Account

Go to energystar.gov/buildings/facility-owners-and-managers/existing-buildings/use-portfolio-manager and click Create a New Account.

You’ll need a username, password, and contact information. Use a company email address, not a personal one — this account will be shared with whoever manages compliance going forward, and CDPHE may contact this address directly.

One account can manage multiple properties. If you have a portfolio, set up one account and add each building as a separate property.

Step 2: Add Your Property

After logging in, click Add a Property. You’ll select a primary property type from a dropdown. For Regulation 28, the most common types are:

  • Office (commercial office buildings)
  • Retail Store or Retail — Other
  • K-12 School (if applicable, for public buildings)
  • Multifamily Housing (apartments and condos above 50,000 sq ft)
  • Hotel or Other

Select the type that best matches your building’s primary use. If your building is mixed-use — say, retail on the ground floor and office above — select the primary use type, and you’ll add secondary uses in the next step.

Fill in the property details: name, address, construction year, and gross floor area. Use gross floor area as defined by Regulation 28: the total enclosed area of the building measured to the outside of exterior walls. Do not subtract parking, mechanical rooms, or stairwells — they’re included.

Step 3: Add Space Use Details

Portfolio Manager calculates your Energy Use Intensity and ENERGY STAR score based on the specific uses within your building. Under Space Use, add each distinct use type and its square footage.

For a mixed-use building, you might have:

  • Office: 45,000 sq ft
  • Retail: 12,000 sq ft
  • Parking garage: 8,000 sq ft

Each space type has different operating parameters. For office space, Portfolio Manager will ask for weekly operating hours and the number of workers. For retail, it asks for weekly hours and number of registers. Answer these accurately — they affect your ENERGY STAR score calculation and your EUI normalization for weather.

Regulation 28 uses weather-normalized Site EUI for comparison against the state median. Portfolio Manager calculates this automatically using degree-day data for Denver International Airport (the state’s reference station for most Front Range buildings).

Step 4: Set Up Utility Meters

This is where most first-time users spend the most time. Under the Energy tab, click Add a Meter for each energy source your building uses.

Common meters for Colorado commercial buildings:

  • Electricity — from Xcel Energy, Black Hills Energy, or a municipal utility
  • Natural Gas — from Xcel Energy Gas, Black Hills Energy, or Atmos
  • District Steam or Chilled Water — if you’re in a downtown Denver building connected to a district energy system

For each meter, enter the utility name, meter name (you can make this up — “Main Electric” works), and whether it covers the whole building or just part of it.

After adding meters, you’ll enter your monthly consumption data. You need at least 12 consecutive months of data to generate a valid ENERGY STAR score and EUI. Most building owners collect 2024 calendar year data for their first Regulation 28 submission.

You can enter data manually from paper bills, or request a data release from your utility. Xcel Energy offers automatic data transfer directly to Portfolio Manager through their Xcel Energy Portfolio Manager Integration — call Xcel’s commercial line and ask them to set up automatic monthly uploads. This eliminates manual entry for all future years.

Black Hills Energy offers a similar service. Contact their commercial accounts team.

Unit Conversions

Portfolio Manager accepts data in the units on your bill:

  • Electricity: kWh
  • Natural gas: therms or ccf (100 cubic feet) — check your bill
  • District steam: mlbs (thousand pounds) or mmBtu

Do not convert units yourself. Select the correct unit in Portfolio Manager and enter what’s on your bill.

Step 5: Verify Your EUI and Score

Once you have 12 months of data entered, go to Metrics and look at:

  • Site EUI (kBtu/sq ft/year) — your actual energy use per square foot
  • Source EUI — similar, but accounts for energy lost in generation and transmission
  • ENERGY STAR Score — a 1–100 percentile score comparing your building to similar buildings nationwide (not available for all property types)

Under Regulation 28, Site EUI is the primary compliance metric for Pathway 1. The CDPHE publishes the state median Site EUI by building type, and your target is to meet or beat that median by the applicable deadline.

For reference, the Colorado median Site EUI for office buildings as of the most recent CDPHE data is approximately 68 kBtu/sq ft/year. This will be updated as more buildings report.

If your EUI is above the median and you’re pursuing Pathway 1, you have work to do before December 2026 (for buildings 50,000–99,999 sq ft) or December 2027 (for buildings 100,000+ sq ft). See our compliance pathways guide for your options.

Step 6: Connect to CDPHE for Reporting

Colorado uses Portfolio Manager’s Data Request system to collect annual benchmarking data. CDPHE issues a data request to your Portfolio Manager account, and you accept it.

Here’s how it works:

  1. CDPHE sends a data request to your Portfolio Manager account each year before the annual reporting deadline (typically March 31 for the prior calendar year).
  2. You’ll receive an email notification and see the pending request in your account under Sharing.
  3. Accept the request. CDPHE now has read access to your benchmarking data for the reporting year.
  4. That’s it. There’s no separate form to fill out.

If you don’t receive a data request, it may mean CDPHE doesn’t have your building in their covered property database yet, or your account email doesn’t match what they have on file. Contact CDPHE directly at the Building Benchmarking program contact listed on their website to verify your building’s status.

First-year reporters: if your building should have reported for the 2024 calendar year (deadline: March 31, 2025), check with CDPHE about your compliance status. Regulation 28 does not have a formal grace period for initial reporters — penalties are authorized starting in 2030 for buildings that haven’t come into compliance, but CDPHE has discretion in how they handle early-year non-filers.

Step 7: Annual Updates

Once your account is set up, annual benchmarking takes less than an hour:

  1. Log into Portfolio Manager
  2. Add the new year’s energy data (or verify it uploaded automatically from your utility)
  3. Review your EUI — note whether it improved or worsened year over year
  4. Wait for CDPHE’s data request and accept it before the deadline

That’s the full annual cycle. The heavy lifting is the initial setup.

Common Mistakes to Avoid

Using net leasable area instead of gross floor area. Regulation 28 requires gross floor area. This is almost always larger than your rentable square footage. Using the wrong number understates your EUI, which may seem beneficial but creates a compliance mismatch when CDPHE cross-references with your building permit records.

Missing a meter. If your building has a rooftop solar system or a separate natural gas meter for a backup generator, those need to be included. Regulation 28 covers all energy used at the site, including on-site generation.

Not connecting sub-tenants. If a large tenant pays their own utility bills directly to the utility, you need to either (a) get their consumption data from them and enter it, or (b) have them create their own Portfolio Manager account and share data with your property. CDPHE requires whole-building reporting.

Waiting until March to start. The March 31 deadline creeps up fast. Start entering data in January. If you need utility historical data, requesting it in January gives time for the utility to respond before the deadline.

Next Steps

If your EUI comes in above the state median and Pathway 1 (meeting the EUI target) doesn’t look achievable by your deadline, you have three other compliance pathways available — including performance-based and renewable energy options. Review your options in our compliance pathways guide or contact us for a free consultation to map out the right path for your building.