Image provided by the City of San Francisco. Copyright ©2014  

San Francisco’s Existing Commercial Buildings Energy Performance Ordinance (ECB ordinance) came into force in 2011, targeting all non-residential buildings with more than 10,000 square feet (ft2) of conditioned space (e.g. heated and/or air-conditioned). ECB aims to ensure that decision makers  (e.g. owners, managers, tenants, and investors) are able to:

  • Determine the energy performance of the building concerned, both over time and in comparison to similar buildings across the City.
  • Have clear and actionable reports from qualified auditors identifying cost-effective opportunities for enhancing building energy efficiency.

The programme specifically aims to reduce total energy consumption in non-residential buildings by 2.5% per year, achieving a total reduction of 50% by 2030 below 1990 levels. This target comes from the Existing Commercial Buildings Task Force set up by the City of San Francisco, in addition to the City’s 2013 Climate Action Strategy Update. It was also formed in response to the State of California’s goal of achieving zero net energy in 50% of existing commercial buildings by 2030.

What is it?
The ECB ordinance is a comprehensive policy initiative aimed at existing commercial buildings. It consists of benchmarking, auditing and measures to foster retro-commissioning1 and retrofitting by complementing other finance and incentive programmes from the City.

This ordinance targets all existing commercial buildings larger than 10,000 ft2, or approximately 19,000 private sector buildings and 450 public buildings. Buildings less than 2 years old and unoccupied buildings are exempt from this scheme.

How does it work?
Buildings targeted by the ECB ordinance must meet two requirements:

1) Benchmarking requirement:

Building owners or managers are required to annually submit a brief report of key benchmarking results to the San Francisco Department of Environment (SF Environment) by April 1. This is called an ‘Annual Energy Benchmark Summary’ and consists of the following data:

• Contact information and square footage

• Energy intensity (the amount of energy used per square foot)

• 1-100 ENERGY STAR score from Portfolio Manager1 (where applicable)

• Greenhouse gas (GHG) emissions from energy usage

The local electricity and natural gas provider Pacific Gas & Electric Company (PG&E) provides an automated data upload of energy data into ENERGY STAR Portfolio Manager for free. Beginning in October 2014, the City also began disclosing each Annual Energy Benchmark Summary publically through ‘DataSF’, the City’s open data portal. The reports for the first reporting year are held confidentially.

2) Audit and retro-commissioning requirement:

Requirements for the auditing procedure vary by building size, with stricter requirements applying to larger buildings. Owners can select retro-commissioning2 as an alternative to energy auditing3.

• Buildings greater than 50,000 ft2:

An audit must satisfy at least Level 2 from ASHRAE4 and consist of an intermediate survey and energy analysis. This involves a detailed building survey and energy analysis, in addition to the recommendation of capital-intensive energy saving opportunities in alignment with owner constraints and economic capacity.

• Buildings between 10,000 and 49,999 ft2:

An audit must satisfy ASHRAE Level 1 ‘basic energy analysis’. This involves a brief walk-through visit and inspection of energy bills to identify low cost or no cost energy saving measures. In both cases, qualified auditors are then required to submit a ‘Confirmation of Energy Audit’ to the City.

Both the City and the utility PG&E provide free support and training on benchmarking and how results can be used to generate cost and energy savings.

CO2 reduction
It is estimated that full compliance with the ECB ordinance will lead to a 2.5% annual improvement in efficiency for the commercial building sector, with a projected annual GHG reduction of 176,638 CO2e metric tonnes per year.

City officials are also confident that the law is helping to drive the retrofit market, as a high proportion (around 40-70%) of small commercial and multi-family building customers are implementing the energy saving opportunities identified in free audits.

Next steps
Communication and education on the value of benchmarking information is a future priority for the City. The City is also aiming to boost compliance rates for smaller and small buildings, which have been relatively low, compared to large buildings.

The ECB ordinance provides valuable lessons on how cities can use legislation to provide market decision-makers with actionable insight into the energy efficiency of their properties.

Further information
To find out more about San Francisco’s ECB ordinance, the programme’s success factors, challenges and lessons learned please refer to the report Urban Efficiency: A Global Survey of Building Energy Efficiency Policies in Cities, launched by the Tokyo Metropolitan Government and C40 in late 2014 and updated in May 2015.


1 Portfolio Manager is a free online tool provided by the U.S. Environmental Protection Agency that enables building owners and managers to track and assess energy and water use across their entire portfolio of buildings, as well as rate their buildings against top performing similar buildings in the U.S..

2  Retro-commissioning is a systematic process used for the identification and implementation of operational and maintenance improvements in existing buildings.

3 The inspection, survey or examination of a building or facility to identify current performance and efficiency improvement opportunities.

4 The American Society of Heating, Refrigerating and Air-Conditioning Engineers is an organisation committed to the advancement of indoor-environment-control technology in the heating, ventilation, and air-conditioning (HVAC) industry