MA Large Building Energy Reporting Update
February 19, 2025
On December 30, 2024, the MA Department of Energy Resources (DOER) filed its final draft regulations on Large Building Energy Reporting (LBER) with the joint Committee on Telecommunications, Utilities, and Energy. This requires electricity, gas, and steam utilities to report usage data on behalf of covered buildings (20,000 square feet and above). Building owners need to report on usage of additional energy sources such as oil, propane, wood, and on-site renewable energy generation. Annually, by May 30, all energy usage needs to be provided for the previous calendar year. For 2025, the reporting deadline will be June 30, 2025.
Thanks to member engagement on this important topic, A Better City provided a robust set of comments resulting in important changes to the regulations:
- 27.02: Energy Usage for Building Owners: There was confusion about what utilities and building owners were each responsible for reporting. This was clarified under definitions for Energy Usage to read: …”Energy Usage shall mean (c) for a Building Owner, all other Energy that is not provided by a Distribution Company or Municipal Utility, including, but not limited to, any on-site site generation, delivered fuel, or other sources, consumed for any Building including Energy delivered to individual lessees and common areas of a Building in aggregate.”
- 27.04: Reporting Requirements and Process (3) (a): Energy Usage Information Not Provided by a Distribution Company or Municipal Utility: The previous draft included a requirement that building owners report energy usage if a Distribution Company or Municipal Utility did not report it. A Better City recommended that if a Distribution Company/Utility did not report this energy usage, that it should not become the burden of building owners. This section was removed entirely.
- 27.04: Reporting Requirements and Process (1) Distribution Companies: Prior draft regulations required Distribution Companies to include associated cost information in their annual energy usage reporting for buildings. A Better City recommended that associated cost information should be confidential. This resulted in associated costs being removed from the final draft regulations.
- 27.07 (2) (c): Covered Buildings Subject to Municipal Benchmarking Policies or Performance Standards: As many A Better City members report energy usage data to the City of Boston’s Building Emissions Reduction and Disclosure Ordinance (BERDO), and the City of Cambridge’s Building Energy Use and Disclosure Ordinance (BEUDO), they were concerned that BERDO/BEUDO compliant buildings would be subject to duplicative reporting requirements. A new section was added, 27.02 (2) (c), that stated that if a building owner was responsible for reporting a building’s energy use through BERDO, BEUDO, or other approved municipal ordinances or by-laws, they could submit the same information for LBER that they submit for municipal regulations.
- 27.08: Data Verification: (2) Third Party Data Verification: A Better City questioned whether 3rd party data verification was necessary given Distribution Companies and Municipal Utilities are obligated to report energy usage, and other energy usage is already reported, and 3rd party verified through BERDO and/or BEUDO. This section was removed from the regulations.
- 27.11: Enforcement and Penalties (3) Building Owners, and (4) Lessees: A Better City also questioned why there would be data discrepancy penalties for data from Distribution Companies/Municipal Utilities, and or other energy usage data that would be penalized under BERDO and/or BEUDO. This section was removed from the regulations.
There will be a Large Building Energy Reporting 101 Webinar on March 18 at 12.30PM. Register.
Please reach out to Yve Torrie if you have any questions or would like to be part of A Better City’s Buildings Policy Coalition.
