Massachusetts Energy Benchmarking: Leading the Way in Sustainability
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Massachusetts Large Building Energy Reporting (LBER) – Overview of the Massachusetts Energy Benchmarking Law
Massachusetts’ Large Building Energy Reporting (LBER) law was enacted under the 2022 Act Driving Clean Energy and Offshore Wind, codified at M.G.L. c. 25A, § 20, and implemented via 225 CMR 27.00. The law begins full effect in 2025 and requires public disclosure of energy usage for all buildings with a gross floor area ≥ 20,000 ft² (Mass.gov).
LBER is Massachusetts’ precursor to a full Building Emissions Performance Standard (BEPS), focusing initially on transparency before evolving into performance-based targets.
Who Must Report?
Building owners or operators must confirm whether their building is subject to LBER obligations:
- All buildings ≥ 20,000 ft² gross floor area, regardless of use type (commercial, industrial, institutional, multifamily).
- DOER published a Covered Buildings List (CBL) on March 31, 2025, identifying buildings required to report. Owners should verify their building’s presence and claim or dispute inclusion if needed (Mass.gov).
- Properties must complete their filing by June 30th.
Reporting Requirements
Utilities
Electric, gas, and steam utilities (including municipal utilities) must report energy usage (electricity, gas, steam) for all covered buildings directly to the Massachusetts DOER by June 30, 2025, and by May 30 each subsequent year (Foley Hoag).
Building Owners
Owners (or their agents) must report any additional energy usage not captured by utilities, including:
- Fuel oil
- Propane
- Wood
- On‑site solar and other renewable generation
Such reporting is also due by June 30th annually, starting in 2025 (Mass.gov, Foley Hoag).
Public Disclosure
DOER will compile utility‑ and owner‑reported energy usage and publish a public disclosure report each year. The first such report is scheduled for October 31, 2025 (Mass.gov).
Key Dates & Milestones
- 2022: LBER law enacted
- March 31, 2025: Final Covered Buildings List published
- April 2025: Notifications sent to building owners on the list
- June 30, 2025: First annual energy reports due from utilities and owners
- October 31, 2025: First disclosure report published to public
How to Comply: Step‑by‑Step
- Confirm coverage
- Check the Covered Buildings List published by DOER for March 2025
- If your building is listed, you must comply; if it matches criteria but isn’t listed, submit a Building Addition Form or dispute its inclusion
- Claim your building
- Claiming ensures you receive notification and can maintain correct building details (UBID, contact info)
- Gather energy data
- Utilities provide usage for electricity, gas, steam
- Owners must gather data for other fuels or on-site generation
- Submit reports
- Utility companies file directly with DOER
- Building owners report other energy sources via DOER’s platform by June 30 each year
- Prepare for disclosure
- DOER uses submitted data to create a public database published by October 31 annually
What Is Not Required
- No third‑party paid service is needed—owners can self‑report at no cost.
- Self‑certification is sufficient; third‑party verification was removed from the final rules, unlike some local programs.
Why It Matters
- Increases transparency: Enables tenants, real estate professionals, municipal planners, and the public to compare building energy use
- Supports policy development and climate goals by providing baseline data
- Lays groundwork for future emissions-based standards (BEPS) in the Commonwealth
FAQ
Q: What qualifies as a “large building”?
A: Any building or continuous structure across parcels with ≥ 20,000 square feet of gross floor area.
Q: Who sends the first notifications?
A: DOER sent letters to owners in April 2025, identifying buildings listed on the Covered Buildings List and directing next steps like claiming or disputing.
Q: What if my building uses fuel oil or solar?
A: You must report all non‑utility energy usage, including fuels like oil, propane, wood, and onsite generation, by June 30 each year.
Q: Are verification or audits required?
A: No third-party verification is required under state LBER rules—only self‑certification is necessary. However, city programs like Boston’s BERDO may have separate verification requirements.
Q: Will there be penalties for non‑compliance?
A: The state LBER law does not explicitly prescribe fines. However, building owners may face compliance enforcement through DOER’s oversight. Local laws or future emissions-based standards may introduce penalties.
Q: Who can I contact with questions?
A: Email DOER.BER@mass.gov or call the LBER Helpdesk at 888‑383‑8541 for assistance (Mass.gov).
Summary
Massachusetts’ LBER program, launching in 2025, mandates annual energy usage reporting for buildings ≥ 20,000 ft². Utilities will report standard fuel use, while owners must self-report other energy sources. Data is publicly disclosed each year, beginning October 2025. There are no third-party verification requirements, and building owners can comply free of charge. The initiative increases transparency and paves the way for future building performance standards.
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Summary:
Unearth the significance of the Massachusetts Energy Benchmarking program and its role in shaping a sustainable future for the state. Learn about the benefits for businesses and homeowners.
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