St. Louis Building Energy Performance Standard: What Property Owners Need to Know

Understanding St. Louis’s Building Energy Performance Goals

St. Louis has taken a major step toward sustainability by implementing its Building Energy Performance Standard (BEPS), passed in 2020. As the first city in the Midwest to adopt such a policy, St. Louis is setting energy use intensity (EUI) limits for municipal, commercial, institutional, and multifamily buildings 50,000 square feet and larger.

This ordinance is a cornerstone of the city’s efforts to reduce greenhouse gas emissions and cut energy waste. It requires buildings to meet site EUI targets based on the 35th percentile of local benchmarking data, meaning 65% of buildings must improve to reach compliance.

What Is A Building Performance Standard?

A Building Performance Standard (BPS) is a regulation that establishes legally binding energy efficiency targets for buildings. These targets are typically expressed as energy use intensity (EUI), calculated as the total energy consumed per square foot annually.

St. Louis’s BEPS mandates that each covered building meet a site EUI threshold for its property type, determined from local 2018 benchmarking data. Buildings that fail to meet the target must make physical or operational improvements to reduce energy consumption.

Key Elements of St. Louis’s BEPS

St. Louis’s BEPS includes the following core components:

• Covered Buildings: All municipal, commercial, institutional, and multifamily buildings 50,000 sq. ft. or larger.
• Property-Type Specific Targets: Each property type has a unique site EUI threshold based on the 35th percentile of local performance.
• Four Compliance Pathways: Properties can meet the target through standard performance or alternative methods.
• Deadlines: First compliance deadline is May 4, 2025, based on 2024 calendar year data.
• Penalties: Non-compliant properties may face fines or denial of occupancy permits for tenants.

Who Must Comply With St. Louis’s BEPS?

The ordinance applies to:

• Office buildings.
• Hospitals and healthcare facilities.
• K-12 schools and universities.
• Retail and food service properties.
• Hotels and multifamily housing.
• Industrial and warehouse spaces.

Any property meeting the 50,000 sq. ft. threshold must comply, with additional flexibility given to affordable housing and religious facilities, which have until 2027 to meet standards.

Steps To Ensure Compliance With St. Louis’s BEPS

1. Benchmark Building Energy Use

Benchmarking is the foundation of the BEPS compliance process. Building owners must:

• Benchmark energy use through ENERGY STAR Portfolio Manager.
• Use weather-normalized data from 2018 as a performance baseline.
• Submit benchmarking reports annually to the City of St. Louis.

Accurate benchmarking allows owners to understand current performance and identify gaps.

2. Determine Your Site EUI Standard

Each building has a specific EUI threshold depending on its property type. Owners should:

• Refer to approved BEPS tables to find their property’s target.
• Compare current energy use to the required EUI standard.
• Calculate how much improvement is needed to comply.

Buildings with EUIs above the target must begin planning efficiency upgrades.

3. Choose A BEPS Compliance Pathway

St. Louis offers four compliance pathways:

• Standard Performance Path: Meet the EUI standard for your building type.
• Early Adopter Path: Achieve a 20% or 50% reduction from your 2018 baseline and meet the EUI target to earn compliance for multiple cycles.
• Narrow the Gap Path: Cut the gap between your baseline and EUI target by 50% (available in cycles 1 and 2 only).
• Custom Path: Submit an ASHRAE Level 2 audit and apply for a custom pathway based on unique building circumstances.

Each path requires different documentation and verification, but all lead to compliance if executed correctly.

4. Upgrade Building Systems

To reduce energy consumption and meet BEPS targets, property owners should invest in:

• High-efficiency HVAC systems and controls.
• LED lighting with occupancy sensors.
• Insulation and window improvements.
• Energy management systems for real-time optimization.
• Building automation upgrades.

Many upgrades also qualify for rebates or tax incentives, helping offset upfront costs.

5. Submit Verification & Documentation

By the May 4, 2025 deadline, building owners must:

• Provide performance data showing EUI compliance.
• Submit any required audits or alternative compliance applications.
• Ensure documentation is complete and filed through the city’s online portal.

Failing to report or meet requirements may result in enforcement actions.

Why Businesses Should Comply With St. Louis’s BEPS

1. Reduce Energy Costs

Improved efficiency leads to lower utility bills and maintenance costs, offering long-term financial returns.

2. Avoid Penalties

Non-compliance can lead to significant fines or restrictions on occupancy, which disrupt operations and reduce property value.

3. Enhance Market Appeal

Energy-efficient buildings are more attractive to tenants, investors, and buyers, particularly in a market that values ESG performance.

4. Contribute To Climate Goals

Meeting BEPS targets supports St. Louis’s climate action plan and demonstrates corporate environmental responsibility.

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Overcoming Compliance Challenges

1. Addressing Financial Constraints

Efficiency upgrades can be capital-intensive. However, owners can:

• Apply for utility rebate programs.
• Use low-interest green loans or PACE financing.
• Implement upgrades in stages to spread out costs.

2. Navigating Technical Requirements

The BEPS program includes complex reporting and verification steps. To simplify compliance:

• Work with certified energy auditors or consultants.
• Utilize digital tools for monitoring and reporting.
• Seek guidance from the St. Louis Building Division.

3. Adapting Older Buildings

Older facilities may need significant retrofits. Owners should:

• Prioritize quick wins like lighting upgrades and HVAC tuning.
• Leverage the custom compliance path for flexibility.
• Schedule audits to assess the most cost-effective improvement areas.

Preparing For St. Louis’s BEPS Compliance

The clock is ticking for commercial property owners in St. Louis. To stay ahead of the 2025 deadline:

• Benchmark your building’s energy use now.
• Identify your required site EUI threshold.
• Choose your compliance pathway.
• Develop and implement an energy improvement plan.
• Submit your verification on time.

By acting early, property owners can reduce risk, enhance building performance, and support a cleaner energy future for St. Louis.