The case for statewide benchmarking

New analysis shows one-third of New York’s large buildings exist outside NYC

Original publication by Urban Green Council • May 21, 2025

Buildings are the number one source of greenhouse gas emissions in New York State, but we know very little about their energy use outside of New York City. Statewide benchmarking and disclosure would change that. We dug into a valuable dataset that has long flown under the radar to assess its significant potential across the state. 

Benchmarking—the requirement for large buildings to annually report energy and water use— is a well-established practice in cities and states across the country. It’s a crucial first step towards carbon savings because better data empowers building owners with energy insights, drives market demand for efficiency, and guides building upgrades that benefit energy-burdened residents. 

As a key recommendation in New York State’s climate plan for tackling greenhouse gas emissions in multifamily and commercial buildings, benchmarking is long overdue. The time to move forward is now.

Large buildings represent 25 percent of floor area beyond NYC and hold the key to big statewide savings

Although few in number, large buildings are key to climate progress because they account for a disproportionate share of energy use. For example, New York City’s benchmarking law covers 50,000 buildings larger than 25,000 SF. They make up just 5 percent of NYC’s total building stock, but cover nearly 60 percent of citywide floor area and contribute half of all carbon emissions from buildings. 

A similar pattern exists statewide. There are more than 22,000 buildings over 25,000 SF outside of NYC.^[1]According to the best available data from NYS Department of Tax & Finance 2024 New York State Property Assessment and Property Inventory. Data calculated by filtering for entries listed in each … Continue reading That’s less than 1 percent of all buildings in the rest of the state. But benchmarking those buildings would shine a light on energy use and carbon in nearly 1.8 billion square feet of additional floor space—or roughly one quarter of New York’s remaining real estate area. Explore Figure 1 to see the distribution of these buildings.

Figure 1

As expected, some of these buildings are concentrated in cities like Buffalo (1,200 buildings), Rochester (1,000 buildings) and Albany (600 buildings). But while there are roughly 3,800 large buildings in the six cities highlighted above, over 18,000 of them are distributed across suburban and rural areas throughout New York. So tracking large building emissions will clearly require a statewide effort.

Better data drives energy and carbon savings

The potential savings from benchmarking are driven by the significant value that the data provides, and the information would advance New York’s climate strategy because it:

1. Empowers owners with energy insights: Whole-building energy data can be used to inspire efficiency improvements, compare performance with similar properties, and track progress.
2. Drives the market for efficient buildings: Public data helps push demand for efficiency and highlights opportunities for operators and service providers to make energy-saving upgrades.
3. Guides equitable solutions for tenants: Transparent information supports those living in multifamily buildings because it can guide improvements that address energy burdens and housing quality.

Benchmarking itself does not require owners to improve a building’s energy use, but the EPA estimates that benchmarked buildings save about 2.4 percent in annual energy use. 

To put that in perspective, large buildings in Buffalo make up around 113.4 million SF of space. Their total annual emissions are roughly equal to 142,000 gasoline-powered cars.^[2]Calculated using U.S. DOE National Renewable Energy Laboratory data on the emissions intensity of buildings over 25,000 SF in the Rochester-Buffalo area, and applying EPA’s greenhouse gas … Continue reading By the EPA’s estimated savings, benchmarking in just the City of Buffalo could lead to carbon savings equivalent to taking 3,400 cars off the road each year.

Benchmarking is a proven approach for climate progress

Benchmarking laws are already in place in dozens of jurisdictions, including four states: Colorado, Maryland, Oregon and Washington. Since enacting its benchmarking law in 2009, New York City has seen especially strong evidence of how energy use data can drive climate progress:

• Building owners take action: Benchmarking insights often prompt energy efficiency upgrades—77 percent of facility managers reported operational changes, and 75 percent invested in new equipment after the 2009 law passed.
• Energy savings follow: Buildings over 25,000 SF cut energy use by 10 percent in just five years after a 2016 bill expanded the city’s benchmarking law to cover them (Figure 2).
• Policymakers track impact: NYC buildings that benchmark today account for over half of all emissions from the city’s building stock—making their data critical to climate planning. City leaders use the data to monitor progress and inform policies like energy codes, fuel oil phase-outs and Local Law 97. 

Figure 2

As New York State advances policies to cut emissions from buildings, benchmarking offers a simple but powerful tool to measure and guide progress statewide.

Advancing benchmarking statewide 

The Climate Leadership and Community Protection Act (CLCPA) set a mandate for New York State to reduce greenhouse gas emissions by 85 percent by the year 2050. Buildings contribute 31 percent of emissions—more than the transportation sector. But efforts to implement CLCPA policy recommendations for benchmarking and other efforts to achieve carbon reductions from the building sector have largely stalled. 

Some communities have made progress: 84 municipalities across New York State currently have reporting requirements for government-owned buildings as part of the Clean Energy Communities program. But more is needed to get all large buildings to measure and manage energy use. Two fundamental—and potentially complementary—paths could make statewide benchmarking a reality. 

1. Enact a statewide benchmarking law for large buildings

New York State legislators could adopt a requirement for owners of buildings over 25,000 SF to annually report their energy and water use through a platform like EPA’s Energy Star Portfolio Manager—the tool used by New York City and most other jurisdictions.

The process is straightforward and proven. Utilities are already required by the Public Service Commission (PSC) to provide whole-building energy data to building owners or their agents upon request for the purposes of benchmarking for properties that meet certain criteria,^[3]To protect customer privacy, a 2018 PSC Order set a 4/50 standard for utility provision of whole-building energy data, whereby the following criteria must be met by the building: 1) There are at … Continue reading which makes compliance easy for owners. And the data is made publicly available in places like New York City to enable transparency, track progress and inform smart energy policy.

To date, this legislative approach has not borne much fruit. In both 2022 and 2023, Governor Hochul included benchmarking requirements in the state’s Executive Budget Proposal, but neither survived budget negotiations. And with potential changes at the EPA creating uncertainty around the future of Portfolio Manager, an alternative approach may offer more promise. 

2. Automate benchmarking and public disclosure through New York’s new Integrated Energy Data Resource (IEDR) 

New York may have a simpler and more efficient path: enable statewide benchmarking and disclosure through the state’s Integrated Energy Data Resource (IEDR), a centralized platform developed by NYSERDA at the direction of the PSC to standardize and share utility data statewide. Early IEDR tools, like the Electric Infrastructure Assessment, show their capacity to aggregate electric, gas, and steam data across New York.

A proposed Use Case would enable whole-building energy consumption data for benchmarking.^[4]This is made feasible following a 2023 PSC Order that required utilities to transfer customer energy data to the IEDR Administrator and unlocked the potential for data access for properties that meet … Continue reading Doing so would relieve building owners of even the modest reporting burden of benchmarking, while providing energy data similar to what’s submitted through Portfolio Manager. When paired with datasets like the statewide property inventory, the IEDR could provide equivalent functionality to a benchmarking law, including public-facing, aggregated building data in line with established privacy standards to activate the building decarbonization market.

This pathway shows promise, but may not achieve all the aims of a benchmarking law alone. Utilities lack data on delivered fuels like propane and fuel oil, and that would need to come from elsewhere. And without owner-driven reporting, other strategies would likely be needed to spur efficiency improvements, such as remote audits by service providers to direct client outreach, targeted analysis by nonprofits to highlight opportunities, and data-based incentive programs designed by utilities. Ongoing input from benchmarking experts is critical to ensure the tool delivers the same benefits that a benchmarking law otherwise would.

These approaches aren’t mutually exclusive. A hybrid model—pairing owner reporting with automated, public IEDR data—may offer the most comprehensive and effective solution. Either way, it’s critical for statewide benchmarking to move forward now in order to drive decarbonization and help New York stay on track with its climate goals.

Related resources