BOSTON, MARCH 18, 2025…..State officials are eyeing a key date this month that will solidify the inventory of properties across Massachusetts subject to a new large building energy reporting policy taking effect later this year.
More than 30,000 properties currently appear on a draft list of “covered buildings” tied to the LBER policy, which was embedded in a 2022 clean energy and offshore wind law. The policy takes effect this fall and applies to buildings with a gross floor area of more than 20,000 square feet.
During a webinar Tuesday, Department of Energy Resources staff encouraged large building owners and stakeholders to review the list and make any corrections, as well as fill out a form to “claim” their buildings. A final list of covered buildings will be posted March 31, and owners will be notified by the state. With a listed gross floor area of 519,628 square feet, the State House at 24 Beacon St. in Boston is on the list.
“Since this is just a draft, there’s a possibility that buildings are missing from this list, and it’s also possible that some of the buildings don’t actually meet the definition of a covered building, as defined in the regulation,” Nathan Dziadul, DOER’s building energy reporting program coordinator, said.
Electric, gas and steam utilities must report usage data on behalf of building owners. Meanwhile, building owners or their agents must disclose information about other energy sources like oil, propane, wood and on-site renewable energy generation, according to DOER.
“The primary purpose of building energy reporting or benchmarking policies is to create data transparency in the market, allowing stakeholders to understand more about how buildings use energy,” Lyn Huckabee, DOER’s consumer energy and policy manager, said. “Also, as cities and towns in Mass. continue to implement building energy policies, the statewide reporting standard allows them to focus on implementing the policy, rather than worrying about how to collect the data, which is the labor-intensive part of the process.”
Tenants, investors, lenders and building managers can also use energy usage data to make “informed decisions when they lease, buy, finance, or manage commercial space,” according to Huckabee’s presentation.
The LBER policy offers a streamlined approach for most large buildings in Boston and Cambridge, which must already comply with those cities’ energy disclosure requirements, Dziadul said. Boston and Cambridge officials will be tasked with sharing energy usage data with the state for buildings that already face city-level reporting requirements there.
“We want to make reporting as simple as possible. So if you have a building reporting under BERDO or BEUDO, there will be no additional reporting under the state’s program,” Dziadul said of Boston and Cambridge’s ordinances.
Naomi Watson, analyst at software developer ClearlyEnergy, urged large building owners to be aware of potential gaps between local and state policies. While Cambridge’s Building Energy Use Disclosure Ordinance applies to buildings that are over 25,000 square feet, owners will still need to comply with the state’s smaller reporting threshold, Watson said.
A series of other implementation dates tied to the policy are coming up.
Building owners and managers, as well as utilities, face an April 30 deadline to dispute their property’s inclusion on the covered buildings list. By June 30, distribution companies, municipal utilities and building owners must submit energy usage data. DOER will publish the first disclosure reports by Oct. 31.
Buildings can be exempt from reporting requirements under certain circumstances, including if the building was vacant for a full calendar year, was vacant for more than half the year due to “natural causes” like a flood or fire, or was demolished in the past year.
DOER is working on developing additional guidance around energy reporting, including how to calculate gross floor area, potential building uses that could be exempt from the policy, and additional disclosure requirements, Huckabee said.
“This could mean what needs to be reported to more accurately reflect your building’s greenhouse gas emissions, and how we will calculate and report greenhouse gas emissions. Drafts of these guidelines will be released for comments throughout the year and as needed,” Huckabee said. “We expect that the process of qualifying buildings for this policy and reporting requirements will continue to improve as we gain more implementation experience.”
