How EBEWE Exemptions Can Reduce the Cost of Your Audit 

In Los Angeles, buildings included in the Existing Buildings Energy & Water Efficiency (EBEWE) Program must complete energy and water audits plus retro-commissioning (A/RCx) every five years, unless they qualify for specific exemptions. For building owners, understanding these exemptions can dramatically reduce compliance costs.  

 

What A/RCx Exemptions Are Available? 

Under LAMC Division 97 (Section 91.9706.1.3), buildings may be exempt from energy audits and retro-commissioning if they meet any of the following criteria: 

 

  1. ENERGY STAR Certification 

  • Certified in the year of compliance 

  • Or certified in two of the three years prior. 

  1. Superior Energy Performance (No ENERGY STAR) 

  • A licensed CA engineer or architect certifies the building performs at least 25% better than the national median for similar buildings (based on CBECS data).  

  1. 15% Reduction in Source EUI 

  • A licensed professional certifies the building’s source energy use intensity has decreased by 15% or more compared to five years before the compliance due date.  

  1. No Central Cooling + Four Measures During Compliance Cycle 
    For buildings without central cooling—or with less than 100 refrigeration tons capacity—if four of the following six measures were completed within the five-year cycle: 

  • Common area/exterior lighting per Title 24 

  • Pipe insulation per Title 24 

  • Cool roof per LA Green Building Code 

  • Demand response program participation 

  • Solar thermal water heating 

  • New water heater (domestic hot water) per Title 24  

  1. New Building Exception 

  • Occupied for less than five years based on Temporary or permanent Certificate of Occupancy. 

 

There are parallel water-specific exemptions as well (Section 91.9706.2.3): 

  • 20% reduction in water use intensity compared to five years prior. 

  • No central cooling + two of three water measures, such as low-flow fixtures, front-loading washers, or code-compliant toilets/urinals. 

  • Or being a new building (<5 years old).  

 

Why These Exemptions Matter 

These exemptions aren’t just paperwork; they’re powerful savings tools: 

 

  • Huge Cost Reductions: Meeting an energy and water exemption can cost up to 75% less than performing a full ASHRAE Level II audit + RCx report.  

  • Proof of High Performance: Achieving ENERGY STAR certification or demonstrating tangible energy/water reductions signals strong building performance. 

  • Branding & Market Value: ENERGY STAR buildings are easier to lease, appraise higher, and attract capital aligned with ESG and sustainability goals. 

 

How Our Services Help You Capitalize 

Navigating exemptions can be tricky. There’s strict data accuracy, documentation, and licensure requirements. Yet, that’s where we excel. Let us help you in: 

 

1. Full Benchmarking & Performance Analysis 

We start by benchmarking your building in ENERGY STAR® Portfolio Manager, verifying all data, and pulling five years of usage metrics to assess qualification for: 

  • ENERGY STAR certification 

  • 15% source EUI reduction 

  • 20% water reduction 

2. Tailored Exemption Strategy 

Rather than defaulting to a full audit, we identify which exemption(s) are the most cost effective and which have the highest likelihood of approval. Whether it’s certification, EUI drop, or implemented efficiency measures, we got you covered. 

3. Certified Documentation 

All exemption claims must be certified by a CA-licensed Professional Engineer (PE) or Licensed Architect. We handle all the technical write-ups and reviews to ensure that each claim meets LADBS requirements. 

4. Measure Compliance & Verification 

If chasing an exemption based on implemented upgrades (like cool roofs or low-flow fixtures), we collect the evidence, verify they meet Title 24 or municipal code, and compile a compliant package. 

5. LADBS Submission & Appeals 

We submit your exemption directly through the LADBS portal. If the Department denies an exemption, we handle appeals per LAMC Section 98.0403.2.  

 

In practice, many clients save thousands of dollars when exemptions apply. 

 

Why Act Now? 

  • LADBS has lifted tolling and deadlines are active

  • Many building owners overpay, unaware of available exemptions. 

  • Achieving ENERGY STAR certification or reductions boosts your building’s competitive position.  

James Horan

A UC Irvine Social Ecology grad, published researcher, and Dean’s List honoree with experience in psychology, planning, and B2B design.

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