Benchmarking Program Qualifications and Exemptions

Learn what buildings are required to participate in the benchmarking program, what buildings are exempt, and how to file for an exemption each year.


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.


Building Location

If your building is located within the City of St. Louis, then you are in the benchmarking program. Use the Address Validator to find out if your building is in the city limits.

Building Ownership

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

Parking Garages

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

Gross Floor Area (GFA)

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

The Gross Floor Area (GFA) is the total property square footage, as measured between the exterior walls of the building(s). This includes all areas inside the building(s) including supporting areas.

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 the benchmarking program 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:
  • 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

Please visit to apply for an annual exemption. You must apply every year before May 1st of that year. 

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