Look up your property in the City's official covered-buildings list by address, Building ID, or parcel number, then estimate your GHGI targets below. This is a preliminary guide, not a formal determination.
The program has two separate obligations. Benchmarking is annual. Performance targets apply only at the three deadlines. We manage both for you.
Report your building's energy use through Touchstone IQ by May 15 each year for the prior calendar year. The first report, covering 2025 data, is due September 15, 2026.
In the initial year and each performance-standard year, a qualified independent Energy Professional must verify your data. A discrepancy over 50% triggers a $1,000 fine.
At 2028, 2032, and 2036, your Total GHGI must be at or below your property type's target, or you'll need an approved compliance plan (BPAP) or extension.
Each performance standard is tied to a specific energy-use year, a reporting deadline, and (for the interim standards) a deadline to elect the Building Performance Action Plan pathway.
The City issues a notice of violation with a 30-day cure period before penalties apply, but the fines add up, and paying them does not clear the underlying obligation.
Per missed or inaccurate benchmarking report
Data discrepancy over 50% vs. verified data
Straight answers grounded in WHMC Chapter 15.100 and the City's Administrative Guidelines. Have a question that isn't here? Reach out, we answer these every day.
All existing buildings with a Gross Floor Area of 20,000 square feet or more that have received a certificate of occupancy, whether built before or after the ordinance was adopted. Buildings under 20,000 sq ft, one- and two-family homes, and multifamily properties with four or fewer units are excluded.
Reference: WeHo city
Two things. Benchmark annually: report your energy use through Touchstone IQ by May 15 each year (the first report, covering 2025 data, is due September 15, 2026). Meet the targets: at 2028, 2032, and 2036 your Total GHGI must be at or below your property type’s target.
GHGI is Total Greenhouse Gas Emissions Intensity, measured in kg CO2e per square foot per year. It is the compliance metric. Energy Use Intensity (EUI) and the ENERGY STAR Score are reported, but they do not determine whether you meet a standard; only GHGI does.
The first benchmarking report covers 2025 data and is due September 15, 2026, a 120-day extension from the standard May 15 date. After that, reports are due every May 15 for the prior calendar year.
You have options before any penalty. You can elect the Building Performance Action Plan (BPAP) pathway, a City-approved plan to reach compliance over time, available for either interim standard (selection is due 180 days before the deadline; November 17, 2027 for the 2028 standard). You may also qualify for an exemption or extension for financial hardship, major redevelopment, high vacancy, or a change of ownership or property type. If you miss the target with no approved BPAP, the fine equals the Social Cost of Carbon for each unachieved ton of CO2e until you comply.
A BPAP is an approved, plan-based route to compliance used instead of hitting an interim target on the deadline. It requires a retrofit plan, cost-benefit analysis, an ASHRAE Level II audit or retrocommissioning report, and a DER opportunity report, all sealed by a licensed professional. It is available only for the interim standards, not the final standard.
Yes. A first full calendar year of occupancy in 2027 to 2030 exempts a building from the First Interim Standard; 2031 to 2034 exempts it from both interim standards. These buildings still must meet the Final Standard and benchmark annually.
If your ENERGY STAR property type is not on the City’s published target table, there is no set target. You may petition the Department to add it as a unique building type, or pursue a BPAP under that eligibility criterion. Targets are never estimated or interpolated for unlisted types.
You get a warning first: the City issues a notice of violation with a 30-day cure period before any penalty. Fines then depend on the violation. Missing or inaccurate benchmarking report: up to $1,000 per instance. Data discrepancy over 50% versus verified data: $1,000 per instance. Missing a performance standard with no approved BPAP: an annual Social Cost of Carbon fine per unachieved ton. Combined failure (no report, missed target, no BPAP): up to $10 per square foot of gross floor area. Paying a fine does not clear the obligation; you still must come into compliance.
When you miss a target without an approved plan, the annual fine equals the Social Cost of Carbon for each metric ton of CO2e you fell short. Reference values in 2020 dollars are $223 per ton in 2028 and $238 per ton in 2032, subject to adjustment and the City’s fee resolution.
Residential condominiums (Common Interest Developments) of 20,000 sq ft or more must complete annual benchmarking, data verification, and disclosure upon sale, but are exempt from the GHGI performance targets and the BPAP pathway. The HOA or association board is the Owner of record and may delegate the task to a property manager in writing.
For buildings with three or more active utility accounts, SCE and SoCalGas provide aggregated whole-building data without individual tenant consent. With fewer than three accounts, you need written authorization from the customers. Utilities must deliver a complete data request within 28 days; a documented delay supports an extension.
Only in certain years. Verification by an independent Energy Professional (PE, RA, CEM, BEAP, EMP, BEMP, or another Department-recognized credential) is required in the initial reporting year and each performance-standard year. In other years you self-certify. A discrepancy over 50% between verified and self-certified data is a $1,000 fine.
Tell us about your building and we’ll map your exact obligations, deadlines, and the fastest, lowest-cost path to compliance, before penalties are ever on the table.
Speak with an EBPS specialist about benchmarking, GHGI targets, data verification, or a Building Performance Action Plan. We’ll tell you exactly where your building stands.
compliance@westhollywoodebps.com
westhollywoodebps.com
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