Benchmarking Program Qualifications and Exemptions

Overview

Not every building is required to participate in the Energy Benchmarking program. There are specific qualifications for buildings that must participate, and rules that govern exemptions. Read below to learn about qualifications, exemptions, and filing for an exemption each year.

On This Page

Qualifications

Building Location

Ordinance 70474 only applies to buildings located within the CITY of St. Louis.
(The CITY of St. Louis and St. Louis COUNTY have two separate governments. 
It's confusing, we know.)

If you have properties that might be in St. Louis CITY, you can check at the St Louis CITY Tax Assessor Address & Property Search. 

If an address is found to be in the CITY, the site will display owner and parcel information.
If not, it will usually offer a link to the COUNTY Assessor site.

Since no computer database is perfect, you can double-check at the St. Louis COUNTY Tax Assessor site.

However, the City of Clayton (which is in St. Louis COUNTY) passed a benchmarking ordinance in 2025, and we can't advise whether your building is subject to that or not.
Here is Clayton's page on benchmarking. 
 

Building Ownership

If your building is federally or state owned, then it is NOT in the benchmarking program.

Parking Garages

If your building is a standalone parking garage, then it is NOT in the benchmarking program.

Gross Floor Area (GFA)

If the Gross Floor Area of your building is at least 50,000 square feet, it is in the Benchmarking Program.

The Energy Star Portfolio Manager (ESPM) definition of square footage is unique, and includes all public and supporting areas, so be sure to read the guidance on calculating GFA.

Included in Gross Floor Area

• Lobbies
• Tenant Areas
• Common Areas
• Clubhouses
• Meeting Rooms
• Break Rooms
• Atriums (count the base level only)
• Restrooms
• Elevator Shafts
• Stairwells
• Mechanical Equipment Areas
• Basements
• Storage Rooms
• Laundry Rooms

Not Included in Gross Floor Area

• Parking
• Exterior spaces
• Balconies
• Decks
• Patios
• Outdoor pool decks
• Exterior Loading Docks
• Driveways
• Covered Walkways
• Outdoor Courts (Tennis, Basketball, etc.)
• The interstitial plenum space between floors (which house pipes and ventilation)
• Crawl Spaces
• Attics

Benchmarking Exemptions

You may be exempt from reporting your property's benchmarking if:

• A demolition permit was issued during the prior calendar year, provided that demolition work has commenced and energy-related systems have been significantly compromised.
• The owner is unable to benchmark due to the failure of either a utility or a tenant (or both) to report the information necessary for the owner to complete any benchmarking submittal requirement.
• Due to special circumstances unique to the applicant’s facility and not based on a condition caused by the actions of the applicant, strict compliance with provisions of this ordinance would not be in the public interest.
• Financial hardship:
  • Building had arrears of property taxes or water or refuse charges that resulted in the property’s inclusion, within the prior two (2) years, on the city’s annual tax lien sale list.
  • Building had a court appointed receiver in control of the assets due to financial distress.
  • Building is owned by a financial institution through default by the borrower.
  • Building has been acquired by a deed in lieu of foreclosure.
  • Building has a senior mortgage subject to a notice of default.
• The building is primarily used for:
  • Manufacturing or other industrial purposes
  • Wastewater treatment
• Building Occupancy:
  • The property does not have a certificate of occupancy or temporary certificate of occupancy for all 12 months of the calendar year being benchmarked.
  • The building had average physical occupancy of less than 50 percent throughout the calendar year for which benchmarking is required.

Apply for an Exemption

1. Fill out the Annual Exemption Request form on our Benchmarking & BEPS Knowledgebase website.
2. Be sure to attach any supporting documents (such as a manufacturing license) to the request.
3. Click Submit Ticket.
4. Fill out a separate request for each property.

You must apply for an exemption each year, as circumstances may change.