Short answer: Commercial and multifamily owners in the City and County of Denver operate under a stricter local performance standard sitting directly on top of Colorado’s statewide Building Performance Colorado (BPC, HB 25-1269) program. Enforced by CASR under Energize Denver (DRMC Ch. 4, Art. IV / Ord. 2021-1310), buildings >=25,000 sq ft must file annual June 1 benchmarking while steering through active 2025–2027 interim Site EUI compliance toward mandatory 2030 final EUI targets.
Even smaller retail strip centers, restaurants, and apartment blocks from 5,000 to 24,999 sq ft face mandatory LED lighting compliance and electric-heat equipment standards upon burnout. Following the federal district court’s August 2026 dismissal of certain EPCA preemption counts in Restaurant Law Center v. City & County of Denver (appeals pending), CASR continues enforcing interim compliance paths and penalty determinations.
- Large Building EUI Targets (>=25,000 sq ft): Interim 2024/2025 (with CASR timeline extensions through 2026–2027 where granted) culminating in a ~30% sector-wide EUI cut by 2030.
- Small-Building Mandate (5,000–24,999 sq ft): No annual benchmarking, but prescriptive LED upgrades plus electrification requirements at mechanical/water-heating replacement.
- Denver vs. CO BPC Scope Floor: Colorado BPC starts at >=50,000 sq ft statewide; Energize Denver captures 25k–49,999 sq ft full EUI targets (plus 5k–24k burnout triggers) and enforces stricter final intensity numbers.
- Electrification Credit Advantage: Properties completing qualifying full-building electrification or rooftop/community solar receive EUI-equivalent credits under CASR rules.
Download the Energize Denver BPS & CO BPC Reference
Navigating Interim Extensions, Electrification Credits & State Overlap
Denver allows covered >=25,000 sq ft owners facing HVAC equipment supply constraints or lease-rollover friction to apply to CASR for timeline adjustments or alternate compliance paths — moving interim targets smoothly if tied to verified capital plans. Waiting passively for litigation relief carries high risk: Energize Denver’s primary Site EUI benchmark structure remains live while federal appellate briefing proceeds.
Because both Energize Denver and Colorado BPC (HB 25-1269) collect Xcel Energy whole-building datasets in Portfolio Manager, >=50,000 sq ft Denver assets should submit a unified June 1 Portfolio Manager file clearing both state and municipal dashboards at once.
- Check Penalty Differential: Non-compliance penalties run up to $0.70/kBtu beyond interim/final EUI gaps — modeling heat-pump electrification credits vs. penalties is essential.
- Verify Alternate Compliance Window: Properties granted interim extensions must deliver milestone documentation per CASR approval letters.
| Tier & Code | Covered Scope | Timeline / Milestones | Key Mechanics |
|---|---|---|---|
| Large Bldgs (>=25k sf) | Commercial & multifamily >=25k sf | Annual June 1; 2025/27 interim -> 2030 | Site EUI limits; elec credits; alternate timelines |
| Small Bldgs (5k–24.9k) | Commercial & multifamily 5k–24.9k sf | Triggered at equip burnout / schedule | LED upgrades + heat-pump equip transition |
| CO BPC Overlay (>=50k sf) | Colorado state >=50k sf tier | Active state reporting + 2026/2030 | State HB 25-1269 coordination (less strict floor) |
Compliance Execution Checklist
| Step | Owner / Team | Auditable Deliverable |
|---|---|---|
| 1. CASR Target Status Check | Compliance / Legal | Confirm interim 2025–2027 target or active alternate compliance letter on Denver hub. |
| 2. June 1 Dual Filing | Property Ops | Sync Xcel Energy meters for Energize Denver and CO BPC (>=50k sf) simultaneously. |
| 3. 5k–24k Capital Protocol | Facility Manager | Flag rooftop HVAC / water heater replacements in small Denver properties for spec check. |
Keep This Denver, CO Compliance Checklist Handy
Frequently Asked Questions
Did the Restaurant Law Center lawsuit pause Energize Denver?
No. In August 2026 the U.S. District Court dismissed key EPCA preemption claims (with appeals active), and Denver CASR continues enforcing annual June 1 benchmarking and interim/2030 EUI compliance timelines.
What rules apply to 5,000–24,999 sq ft buildings in Denver?
Buildings from 5,000 to 24,999 sq ft do not file annual EUI target reports like >=25k properties, but they face LED lighting upgrade mandates and partial electrification requirements when HVAC or water heating equipment is replaced.
Primary Authorities & Official Resources
- City & County of Denver CASR — Energize Denver Hub
- Building Performance Colorado (BPC HB 25-1269) State Guide
Informational notice: This guide summarizes enacted statutes, regulations, or pending legislative records from the primary authorities linked above as of November 14, 2026. It is not legal, accounting, or licensed engineering advice.