# New Jersey Clean Energy Act Benchmarking (N.J.S.A. 48:3-87.10): Class 4A/4C & July 1 Guide

> Canonical URL: https://bcesg.org/new-jersey-clean-energy-act-benchmarking-njsa-48-3-87-10/
> Jurisdiction: New Jersey | Status: Live (P.L. 2018, c. 17 / N.J.S.A. 48:3-87.10) | Reviewed: 2026-11-14

**Short answer:** Under New Jersey's Clean Energy Act ([P.L. 2018, c. 17; N.J.S.A. 48:3-87.10](https://www.nj.gov/bpu/newsroom/2022/approved/20220907.html)), owners of commercial (**Class 4A**) and multifamily residential (**Class 4C**, 5+ units) buildings exceeding **25,000 gross sq ft** must benchmark and submit whole-building **energy and water** data annually by **July 1** using ENERGY STAR Portfolio Manager and a DOE Unique Building Identifier (**UBID**).

For corporate logistics, pharma, and multifamily portfolios operating across the Northeast corridor, New Jersey avoids the municipal patchwork seen in [Massachusetts](https://bcesg.org/massachusetts-large-building-energy-reporting-lber-225-cmr-27-00/) and [New York City](https://bcesg.org/local-law-97-june-30-2026-deadline-file-or-extend/)—one statewide NJBPU standard governs every municipality from Newark and Jersey City down to Camden.

### Statutory Status at a Glance
- **Governing Authority:** Clean Energy Act of 2018 (P.L. 2018, c. 17; N.J.S.A. 48:3-87.10) & [NJBPU Benchmarking Order](https://www.nj.gov/bpu/newsroom/2022/approved/20220907.html).
- **Administering Agency:** New Jersey Board of Public Utilities (NJBPU).
- **Covered Tax Classes:** MOD-IV Class 4A commercial (office, industrial/warehouse, retail) & Class 4C residential (5+ units) >25,000 gross sq ft.
- **Annual Recurring Deadline:** **July 1** (following initial October 1, 2023 cycle launch).
- **Distinct Requirements:** Mandatory whole-building **water** data alongside energy, plus U.S. DOE **UBID** assignment inside Portfolio Manager.

## MOD-IV Property Class Screening & the Water + UBID Mandate

NJBPU determines building applicability using municipal tax-assessor **MOD-IV** records rather than owner self-reporting. Warehouse and industrial complexes in Middlesex, Hudson, Bergen, and Burlington counties taxed under Class 4A—and apartment complexes of 5+ units taxed under Class 4C—enter scope whenever gross floor area exceeds 25,000 sq ft.

Two compliance details routinely trigger NJBPU rejection notices: omitting **water utility meters** (New Jersey explicitly pairs water benchmarking with energy under N.J.S.A. 48:3-87.10) and leaving the **Unique Building Identifier (UBID)** custom ID field blank inside Portfolio Manager.

- **Regulated Utility Data Tools:** NJ electric and gas utilities provide automated or portal-based aggregated whole-building usage under BPU privacy/aggregation guidelines (4/5 rule thresholds).
- **Uniform Statewide Scope:** New Jersey imposes no separate city-level EUI or GHG performance cap ordinances today, though NJBPU's public benchmarking scores increasingly surface in municipal green-building and lender underwriting reviews.

| Program Dimension | New Jersey CEA Rule | Compliance Requirement |
| --- | --- | --- |
| Statutory Threshold | N.J.S.A. 48:3-87.10 | MOD-IV Class 4A commercial & Class 4C (5+ units) >25,000 sq ft |
| Covered Utilities | NJBPU Order / Portfolio Mgr | Whole-building electric, gas/thermal fuel AND water consumption |
| Property Identifier | Custom Field in ESPM | Mandatory DOE Unique Building Identifier (UBID) + NJ tax block/lot |
| Annual Filing Schedule | Post-2023 Recurring Cadence | July 1 annually via NJBPU ENERGY STAR Portfolio Manager link |

![New Jersey Clean Energy Act Energy and Water Benchmarking Program summary showing >25,000 sq ft Class 4A/4C threshold, annual July 1 deadline, UBID requirement, and NJ S679 legislative bridge.](https://bcesg.org/wp-content/uploads/2026/11/infographic-nj-cea.png)

## Strategic Link: Portfolio Manager Baselines & Pending NJ S679 Disclosure

While New Jersey's benchmarking law carries no statewide EUI penalty cap today, facility energy data feeds directly into corporate GHG reporting—particularly if New Jersey advances **NJ S679** (pending corporate climate disclosure legislation amended in 2026 to cover Scope 1 and Scope 2 emissions for firms >$1B revenue).

Compare New Jersey's July 1 schedule against [Maryland's June 1 verified BEPS deadline](https://bcesg.org/maryland-beps-comar-26-28-hb-49-compliance-guide/) and [NYC's May 1 LL84 deadline](https://bcesg.org/ll84-benchmarking-ll97-prerequisite/) to keep Mid-Atlantic property managers aligned on one quarterly utility audit cycle.

## Compliance Execution Checklist

| Step | Owner / Team | Auditable Deliverable |
| --- | --- | --- |
| 1. MOD-IV Lookup | Tax / Asset Lead | Verify parcel Class (4A/4C) and >25,000 sq ft status on municipal MOD-IV tax records & BPU list. |
| 2. UBID Assignment | Energy Analyst | Generate/confirm building UBID and map NJ municipal Block/Lot numbers inside Portfolio Manager. |
| 3. Utility + Water Sync | Property Ops | Pull 12-month aggregated electric/gas data plus municipal water bills ahead of June 1. |
| 4. Submit July 1 | Compliance Lead | Submit via NJBPU reporting link and retain confirmation receipt for ESG/NJ S679 audits. |

## Frequently Asked Questions

### Are industrial warehouses subject to New Jersey's benchmarking law?

Yes. Industrial, warehouse, logistics, retail, and office buildings taxed under New Jersey MOD-IV Class 4A that exceed 25,000 gross sq ft are covered by NJBPU benchmarking.

### Does New Jersey require water consumption reporting as well as electricity and gas?

Yes. N.J.S.A. 48:3-87.10 requires annual whole-building water benchmarking in addition to electric and natural gas/heating energy usage.

### What is a UBID and why does NJBPU require it?

A Unique Building Identifier (UBID) is a standardized geographic footprint code maintained by the U.S. DOE so NJBPU can match Portfolio Manager submissions cleanly against municipal MOD-IV parcel records.

## Primary Authorities & Official Resources

- [New Jersey Board of Public Utilities (NJBPU) — Clean Energy Act Benchmarking Order](https://www.nj.gov/bpu/newsroom/2022/approved/20220907.html)
- [Maryland BEPS (Mid-Atlantic Comparative) — BC ESG](https://bcesg.org/maryland-beps-comar-26-28-hb-49-compliance-guide/)
- [Massachusetts LBER Statewide Benchmarking — BC ESG](https://bcesg.org/massachusetts-large-building-energy-reporting-lber-225-cmr-27-00/)

*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.*