West Hollywood Releases BPS Targets and Administrative Guidelines

Why Did the City Adopt This Policy?

West Hollywood is one of the first cities in California to adopt a BPS policy. The EBPS reflects the priorities of the community and the City’s position as a leader on environmental stewardship. By reducing energy use and pollution from large buildings the policy will help the City reduce climate impacts, reduce energy costs, create local jobs, improve air quality in the City, and improve resiliency for residents and businesses.

What Deadlines are Coming Up?

• September 15, 2026: Submit 2025 calendar year building energy use with verification by a qualified 3rd party

• Calendar year 2027: Achieve first interim performance target over the full calendar year

• May 15, 2027: Submit 2026 calendar year building energy use (3rd party verification not required)

• November 17, 2027: Deadline to apply for a Building Performance Action Plan (if desired)

• May 15, 2028: Submit 2027 calendar year building energy use with 3rd party verification, and demonstrate compliance with interim performance target (unless approved for an exemption, extension, or alternative compliance pathway)

Benchmarking & Data Verification

All covered buildings must report whole-building energy use using ENERGY STAR® Portfolio Manager for the previous calendar year by September 15 of 2026 and by May 15 in future years. In 2026, 2028, 2032, and 2036, reporting must be verified by a qualified 3rd party (the Administrative Guidelines include a list of accepted licenses and credentials). Reports must be submitted through the the City’s benchmarking platform, BenchmarkingWeHo.org, powered by Touchstone IQ.

Building owners may request a 60-day reporting extension if they are unable to meet the deadline despite best-faith efforts. For 2026, this would extend the benchmarking deadline to November 14. Exemption requests must be sent in writing, along with any documentation, 30 days before the deadline.

Condo buildings that meet the size threshold are required to submit their energy use data, but are not required to achieve building performance targets.

Performance Targets

West Hollywood has established performance targets for three years: 2027 (2028 reporting season); 2031 (2032 reporting season); and 2035 and beyond (2036 reporting season).

The performance targets are based on a building’s Total Greenhouse Gas Intensity (Total GHGI), which reflects emissions associated with energy used by the building divided by the gross floor area (GFA) of the building. Both onsite gas use and electricity purchased from utilities count toward this GHGI metric using conversion factors detailed in the Administrative Guidelines. For electricity, this is a regional conversion factor supplied and updated annually by the EPA.

Performance targets are different for each property type. Buildings with a mix of property types use a weighted average to determine their overall Total GHGI target.

Energy use from EV chargers may be excluded, as well as sub-metered energy for parking garages, industrial process loads, outdoor swimming pools, and emergency backup power.

Buildings have flexibility in how they achieve the targets, and buildings that are not able to achieve the 2027 and 2031 targets can apply for the alternative compliance pathway.

Exceptions, Extensions, and Alternative Compliance Options

Buildings owned by public entities (other than the City) are not covered. Also, any residential building with fewer than five dwelling units are excluded from the policy. Residential condominiums are exempt from the performance standards but must submit annual energy use.

Buildings facing a financial hardship (as defined) are eligible for an exemption from an interim performance standard.

The department may grant a short-term extension for one to three years based on criteria including major redevelopment, planned demolition, high vacancy, change in ownership, change in property type, work delayed by a historical preservation review, or other conditions that materially impair compliance.

An alternative compliance pathway, known as a Building Performance Action Plan (BPAP) is available for some buildings to use for their interim performance standards. A BPAP is a customized, binding plan that details emissions reductions measures a building has or will take and commits the building to reducing emissions by at least 10 percent over a five year period. This alternative compliance pathway must be selected 180 days before the reporting deadline. For the 2028 reporting deadline, the BPAP compliance deadline is November 17, 2027.

To qualify for a BPAP, a building must meet one of the criteria listed in the Administrative Guidelines: unique building type or inappropriate target; financial infeasibility; technical infeasibility or utility limitations; equity priority buildings; cultural resource restrictions (historic buildings). The City can also approve BPAP requests on a case-by-case basis for conditions not anticipated by the Guidelines.

Applying for a BPAP requires a fair amount of planning and documentation. For example, showing financial infeasibility requires demonstrating that the incremental cost of meeting the performance target is cost prohibitive, when compared to a business-as-usual case that accounts for the cost of replacing equipment at end of life with a like-for-like replacement (and other factors). Buildings that anticipate the need for a BPAP should not delay. The City plans to release more information about applying for a BPAP soon.

Penalties

Failure to submit benchmarking data, or submission of an inaccurate report, is subject to a fine of up to $1,000. Failure to meet interim or final performance standards will be subject to a fine of the social cost of carbon ($223/ton in 2028) multiplied by the volume of unachieved greenhouse gas reductions. Buildings that fail to meet a performance target are subject to the fine annually until they achieve the target.

An owner who fails to both submit benchmarking data and meet the performance target is subject to a penalty of up to $10 per square foot of gross floor area.

Where to Learn More and Get Help

The City has set up a website with additional information and a benchmarking platform, powered by Touchstone IQ, that includes detailed support on how to benchmark your building. Additional support and resources are available on the California Building Performance Hub.

The City is making extra support available for qualified Equity Priority Buildings. This support may including benchmarking assistance and energy audits. Buildings subject to the City’s Rent Stabilization Ordinance qualify, as well as the following categories: buildings that have more than 20% of units that are on-site deed-restricted affordable housing; provide transitional housing, congregate care and senior housing, or other supportive housing; has a non-profit or community-serving tenant or owner.

 Key information, including the covered buildings list, performance targets, Administrative Guidelines, and an FAQ can be found on the City’s Equitable Building Performance Standards web page.