West Hollywood EBPS Compliance Help | Benchmarking & GHGI Targets | Insight Energy Consulting
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Insight Energy Consulting
West Hollywood EBPS Compliance
West Hollywood EBPS Compliance
West Hollywood's building energy law (WeHo) is here. We'll get you compliant.
If you own a building of 20,000 sq ft or more in West Hollywood (WeHo), you now have annual benchmarking obligations and emissions targets at 2028, 2032, and 2036. Insight Energy Consulting handles the whole process, from data to deadlines.
First Deadline is September 15, 2026
Benchmarking, GHGI target strategy, data verification, BPAP applications, and penalty avoidance, all in one place.
Four compliance deadlines you can't miss
30-Second Check
Is your building covered, and what's your target?
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.
Step 1 · Official City List
314 buildings on the City list
Step 2 · Estimate your GHGI targets
Your result will appear here once you enter your building details.
Your Obligations
What you need to do
The program has two separate obligations. Benchmarking is annual. Performance targets apply only at the three deadlines. We manage both for you.
1
Benchmark every year
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.
2
Verify your data
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.
3
Meet the GHGI targets
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.
Key Dates
The compliance timeline
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 first deadline is September 15, 2026!
2028
First Interim Standard
- Energy use year: 2027
- Reporting deadline: May 15, 2028
- BPAP selection: Nov 17, 2027
2032
Second Interim Standard
- Energy use year: 2031
- Reporting deadline: May 15, 2032
- BPAP selection: Nov 17, 2031
2036
Final Standard
- Energy use year: 2035
- Reporting deadline: May 15, 2036
- Must be maintained in perpetuity
Why Act Early
The cost of non-compliance
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.
$1,000
Per missed or inaccurate benchmarking report
$1,000
SC-CO2
Annual fine per unachieved ton of CO2e with no approved BPAP ($223/ton in 2028)
$10 / sq ft
Answers
Frequently asked questions
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.
Getting started
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.
Targets & pathways
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.
Enforcement
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.
Condominiums & data
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.
Don't navigate WHMC 15.100 alone.
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.
Get In Touch
Free EBPS consultation
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
Website
westhollywoodebps.com
Response time
We reply to assessment requests within one business day