# San Francisco EBO (Ch. 20) & Chapter 30: May 1 Benchmarking, Audits & 100% Renewable Rule

> Canonical URL: https://bcesg.org/san-francisco-ebo-ch-30-renewable-electricity-compliance-guide/
> Jurisdiction: San Francisco, CA | Status: Live (Annual May 1 Bench >=10k · 5-Yr Audits · Ch. 30 100% Renewable >=50k) | Reviewed: 2026-11-14

**Short answer:** Commercial property operators in San Francisco navigate two separate Environment Code ordinances every spring: [Chapter 20 (Existing Buildings Energy Ordinance — EBO)](https://www.sfenvironment.org/san-franciscos-existing-buildings-ordinance) and **Chapter 30 (Ord. 220-19 Zero-Emissions Electricity)**. Under Ch. 20, non-residential properties starting at just **>=10,000 sq ft** (and multifamily apartments >=50,000 sq ft) must complete annual **May 1** ENERGY STAR Portfolio Manager benchmarking alongside 5-year commercial energy audits.

Under Chapter 30, commercial buildings **>=50,000 sq ft** carry an affirmative mandate to procure **100% GHG-free / renewable electricity** across base building and landlord accounts — turning clean-power tariff enrollment into an enforceable municipal law sitting a month ahead of [California AB 802's June 1 state deadline](https://bcesg.org/california-ab-802-building-energy-benchmarking-guide/).

### Statutory Status at a Glance
- **Ch. 20 Small-Commercial Reach (>=10k sf):** Non-residential 10k–49,999 sq ft owe annual May 1 Portfolio Manager reporting and 5-year ASHRAE Level I audits; >=50k commercial owe ASHRAE Level II audits every 5 years.
- **Ch. 20 Residential Scope (>=50k sf):** Multifamily buildings >=50,000 sq ft owe May 1 annual benchmarking without Chapter 30 renewable-electricity caps.
- **Ch. 30 100% Clean Electricity (>=50k Comm):** Phased across >=500k (2022), >=250k (2024), and >=50k–249k tiers, requiring 100% eligible renewable electric supply via CleanPowerSF SuperGreen, PG&E Solar Choice, or qualifying direct-access green tariffs.
- **Direct State Alignment:** Submitting PG&E whole-building feeds by May 1 satisfies SF Environment early while feeding June 1 AB 802 reporting cleanly.

## Clearing Chapter 20 Audits & Chapter 30 Clean-Power Tariffs Without Fines

Unlike numeric building emissions caps in Boston or NYC that allow natural gas retrofits over multi-year timelines, San Francisco Chapter 30 isolates commercial electricity procurement as an immediate 100% renewable requirement. Owners enrolled in default CleanPowerSF Green (lower % renewable) rather than **SuperGreen (100% renewable)** can accidentally violate Ch. 30 despite thinking their building already runs on community choice power.

Confirm every landlord electric account — common corridors, elevators, chiller plants, and vacant suites — matches a certified 100% renewable tariff, and log periodic ASHRAE Level I/II audit reports on SF Environment's portal ahead of May 1 due cycles.

- **Audit Tiering Matters:** Commercial assets 10,000–49,999 sq ft qualify for streamlined ASHRAE Level I audits rather than full Level II engineering studies.
- **Verify Direct-Access / Tenant Meters:** Master-metered or full-service commercial leases must account for landlord compliance responsibility.

| SF Ordinance | Covered Building Scope | Deadlines & Intervals | Core Requirement |
| --- | --- | --- | --- |
| Ch. 20 Benchmarking | Comm >=10k sf; Multifamily >=50k sf | Annual May 1 (Portfolio Mgr) | Energy benchmarking (meets AB 802 early) |
| Ch. 20 Energy Audits | Commercial >=10k sf (Level I/II) | Repeating 5-year audit cycles | ASHRAE Level I (10k–49k) / Level II (>=50k) |
| Ch. 30 Renewable Mandate | Commercial >=50,000 sf | Phased 2022–2030 active tiers | 100% GHG-free / renewable electricity tariff |

![Infographic covering San Francisco Environment Code Chapters 20 and 30: May 1 >=10k commercial benchmarking, 5-year energy audits, and >=50k 100% renewable electricity.](https://bcesg.org/wp-content/uploads/2026/11/infographic-sf-ebo.png)

## Compliance Execution Checklist

| Step | Owner / Team | Auditable Deliverable |
| --- | --- | --- |
| 1. PG&E / SFPUC May 1 Filing | Property Ops | Upload May 1 Portfolio Manager disclosures for >=10k comm / >=50k multi. |
| 2. SuperGreen Tariff Audit | Energy / Procurement | Verify 100% renewable power enrollment on all >=50k commercial accounts. |
| 3. 5-Year ASHRAE Audit Check | Qualified Auditor | Confirm due year for Level I/II audit or verified exemption status. |

## Frequently Asked Questions

### Does San Francisco Ch. 30's 100% renewable electricity law cover apartment buildings?

No. SF Environment Code Ch. 30 applies to non-residential commercial buildings >=50,000 sq ft, while multifamily apartments >=50,000 sq ft owe annual May 1 energy benchmarking under Ch. 20.

### What threshold triggers San Francisco's commercial energy audit requirement?

Under Ch. 20, non-residential buildings 10,000–49,999 sq ft must complete ASHRAE Level I energy audits every 5 years, and commercial buildings >=50,000 sq ft must complete Level II audits every 5 years.

## Primary Authorities & Official Resources

- [SF Department of the Environment — Existing Buildings Ordinance (Ch. 20 & Ch. 30)](https://www.sfenvironment.org/san-franciscos-existing-buildings-ordinance)
- [California AB 802 Statewide Benchmarking Guide](https://bcesg.org/california-ab-802-building-energy-benchmarking-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.*