Everything you need to know about St. Louis BEPS

What is St. Louis BEPS?

St. Louis's Building Energy Performance Standard (BEPS) is a landmark energy law that mandates strict limits on energy usage for municipal, commercial, and residential properties 50,000 square feet and larger.

Who Qualifies?

St. Louis’s BEPS covers all municipal, commercial, institutional, and multifamily buildings 50,000 sq ft or larger.

Event Most Buildings (50,000+ sq ft) Qualified Affordable Housing & Houses of Worship (50,000+ sq ft)
2026 (now)
  • Transition year between Cycle 1 and Cycle 2
  • BEIB analyzes 2025 benchmarking data and sets tightened EUI targets for Cycle 2
  • Buildings submit annual benchmarking report (non-municipal: April 1; municipal: December 31)
  • Maintain and plan energy improvements ahead of Cycle 2
  • Final year of Cycle 1 compliance period
  • Submit third-party verified 2026 benchmarking data ahead of May 2027 deadline
  • All energy efficiency improvements must be in place by end of 2026 to count toward evaluation
May 4, 2027 (Cycle 1 evaluation — affordable housing & houses of worship only)
  • Cycle 2 begins
  • Buildings must begin implementing energy efficiency improvements to meet tightened EUI targets
  • Submit annual benchmarking report
  • First compliance deadline
  • Submit third-party verified 2026 benchmarking data
  • BEIB evaluates buildings against Cycle 1 site EUI target for each property type
  • Non-compliant buildings face fines of $50–$200/day up to $1,000/year and denial of new occupancy permits
2027–2029
  • Cycle 2 active implementation period
  • Implement energy efficiency retrofits to meet tightened EUI targets
  • Submit annual benchmarking reports
  • Note: "Narrow the Gap" alternative compliance path is available for Cycle 2 but will not be offered in future cycles
  • Cycle 2 begins
  • Implement energy efficiency improvements to meet tightened EUI targets
  • Submit annual benchmarking reports
2029–2030
  • Fourth year of Cycle 2
  • All energy efficiency improvements must be in place by end of 2029 to count toward the 2030 evaluation
  • Submit third-party verified 2029 benchmarking data
  • Implement and finalize energy efficiency improvements ahead of 2030 evaluation
  • Submit annual benchmarking reports
May 4, 2030 (Cycle 2 evaluation)
  • Second compliance deadline
  • Submit third-party verified 2029 benchmarking data
  • BEIB evaluates buildings against tightened Cycle 2 EUI target
  • Non-compliant buildings face fines and denial of new occupancy permits
  • Early Adopter pathway: buildings that reduced EUI by 50%+ from 2018 baseline by Cycle 1 are already in compliance through Cycle 3
  • Second compliance deadline
  • Submit third-party verified benchmarking data
  • BEIB evaluates buildings against tightened Cycle 2 EUI target
  • Non-compliant buildings face fines and denial of new occupancy permits
2030–2034
  • Cycle 3 active period
  • BEIB sets further tightened EUI targets
  • Buildings implement additional energy efficiency improvements and submit annual benchmarking reports
  • Third-party verification required for final year of cycle
  • Cycle 3 active period
  • BEIB sets further tightened EUI targets
  • Buildings implement additional energy efficiency improvements and submit annual benchmarking reports
May 4, 2035 (Cycle 3 evaluation)
  • Third compliance deadline
  • Submit third-party verified benchmarking data
  • BEIB evaluates buildings against Cycle 3 EUI target
  • Non-compliant buildings face fines and denial of new occupancy permits
  • Third compliance deadline
  • Submit third-party verified benchmarking data
  • BEIB evaluates buildings against Cycle 3 EUI target
  • Non-compliant buildings face fines and denial of new occupancy permits

Consequences of Non-Compliance

  • Written warning first: St. Louis buildings that fail to benchmark or comply with BEPS will be issued a written warning upon initial violation. If the required information is not submitted within 60 days of the warning, a fine of $50 to $200 per day will be issued up to $1,000 per year

  • Higher fines possible: Failure by an owner to meet the requirements of BEPS within 60 days of the warning letters shall be punishable upon conviction by a fine of up to $500 per day

  • Occupancy permit denial: Buildings not in compliance will not be eligible for issuance of new residential or commercial occupancy permits

  • No monetary cap tied to sq footage (unlike DC BEPS's $10/sq ft structure) — St. Louis penalties are daily fines with an annual ceiling, plus the occupancy permit restriction which can significantly impact operations and tenant relationships.

Compliance Pathways

There are four compliance paths for BEPS.

  1. Standard Performance Path: The building is considered in compliance if the EUI for the property is equal to or lower than the EUI standard for its property type. To qualify, building must submit verification.

  2. Early Adopters Path: To incentivize investment in meaningful energy upgrades, properties can achieve compliance for multiple cycles.

    • EA 1: Buildings that reduce their EUI by 20% or greater compared to its 2018 baseline and has an EUI that is at or below the standard for its property type are considered to be in compliance for cycles 1 and 2.

    • EA 2: For buildings that reduce their EUI by 50% or greater compared to their 2018 baseline and has an EUI that is at or below the standard for its property type, they will be considered in compliance for cycles 1, 2, and 3.

  3. Narrowing the Gap Alternative Compliance Path: For those who cannot meet its targets during cycles 1 and 2, they can achieve compliance by reducing their EUI to halfway between its property type baseline EUI and the target EUI. This is only available for cycles 1 and 2.

  4. Custom Alternative Compliance Path: If a property has unique characteristics or situations that make the other compliance pathways accessible, the owner can apply for a Custom Alternative Compliance Path. This requires an Alternative Compliance Path application and ASHRAE Level 2 audit.