Equity First, Savings Follow: How Denver’s Compliance Assistance Program Unlocks Utility-Aligned Savings

Author:  Ben Levine

|Director of Business Development at Touchstone IQ

This article was originally published by the Association of Energy Services Professionals (AESP) Energy Intel Magazine (4th Quarter 2025).

States and cities across the U.S. are adopting building performance standards, creating new opportunities for utility-aligned technical assistance models like Denver’s Compliance Assistance Program (CAP).

Source: U.S. Department of Energy

States and cities across the U.S. are adopting building performance standards, creating new opportunities for utility-aligned technical assistance models like Denver’s Compliance Assistance Program (CAP).

Like many cities, Denver concluded that it cannot meet its climate goals without dramatically improving the performance of its existing buildings. The Energize Denver Building Performance Policy requires large buildings to benchmark annually and meet an energy efficiency goal. This policy is one tool the city is using to cut carbon pollution from the building sector.

Within that framework, the Compliance Assistance Program (CAP) was designed to answer a crucial question: what happens to buildings that serve climate-vulnerable communities, but lack the staff, capital, or expertise to navigate complex compliance rules on their own? Without help, these sites risk falling behind, facing fines, and missing out on the comfort, resilience, and cost benefits that the policy is supposed to deliver.

The CAP flips that script. It provides long-term, no-cost support to buildings that house or serve low-income residents, affordable housing, community nonprofits, and other frontline groups, so that they can meet Energize Denver’s requirements and share in the benefits of decarbonization.

For utilities and program implementers, CAP offers something more: a working template for an equity-first, concierge-style building performance program that generates a robust pipeline of demand-side management projects and aligns compliance-driven work with utility savings and equity goals. In effect, it functions like a utility Income Qualified or Hard-to-Reach building program that just happens to be anchored in a city BPS.

Building an Equity Lens Into Policy Implementation

Denver’s Office of Climate Action, Sustainability, and Resiliency (CASR) spent a full year co-designing the CAP with community stakeholders, technical advisors, and service partners before launch. The result was a shift in language from “under-resourced buildings” to “Equity Priority Buildings”, and a deliberate focus on frontline communities, including low and moderate-income residents, communities of color, older adults, non-English speakers, and others historically excluded from energy investments.

To identify candidates, CASR built an Equity Index that ranks census tracts based on environmental and socioeconomic indicators, then cross-referenced that index with data on large buildings (25,000+ sq. ft.) and affordable housing registries. This allowed the city to proactively target buildings in neighborhoods facing higher climate, economic, and housing burdens, which CASR refers to as “Equity Priority Buildings.”

Equity Priority Buildings are further defined by their role in serving climate-vulnerable communities; especially multifamily affordable housing, deeply affordable apartments, nonprofit service providers, and small businesses that operate on tight margins. Those buildings are eligible for deeper, longer-term assistance than the broader building stock, recognizing that compliance alone is not enough; they need embedded support to plan and execute improvements.

This deliberate equity lens mirrors a growing body of best practice in building performance standards and energy efficiency programs, which calls for policy goals and metrics that prioritize equitable access and outcomes, not just maximizing cost-effective savings. It also lines up closely with where utility portfolios are headed, as regulators increasingly expect equity, decarbonization, and reliability benefits to be delivered together rather than in separate silos.

Program Architecture: Service Levels, Not One-Size-Fits-All

Support within CAP is structured as a five-step continuum that aligns assistance with each building’s needs and readiness, from first touch to post audit follow through. Rather than a single audit offering, the program stages services so that owners get the right level of help at the right time.

Step 1: Outreach and Screening
Targeted outreach and application screening identify buildings that meet Equity Priority Building criteria and are likely to benefit most from the concierge support offered in the CAP. Staff explain Energize Denver requirements in plain language, describe the services available, and enroll buildings into the program.

Step 2: Benchmarking and Data Verification
Program staff provide hands-on benchmarking support by setting up or cleaning up ENERGY STAR Portfolio Manager accounts, uploading and verifying utility data, correcting square footage and use types, and submitting required benchmarking reports on behalf of owners when needed.

Step 3: Assessment and Audit Preparation
Once data is accurate, the team completes a virtual assessment using building information and engineering analysis to flag key opportunities, identify potential target adjustment or alternate compliance options, and gather the information needed to scope an effective onsite ASHRAE Level 2 audit.

Step 4: Onsite ASHRAE Level 2 Audit and Compliance Plan
Engineers conduct a comprehensive onsite ASHRAE Level 2 audit and, working with the account manager, translate the technical findings into a phased, cost-benefit-informed plan for meeting Energize Denver targets over multiple compliance years. The plan highlights measure bundles, timelines, and connections to incentives and financing.

Step 5: Post Audit Account Management and Implementation Support
After the audit, CAP account managers stay engaged to review findings with the owner, refine the compliance and project plan, help with target adjustments or other formal submissions, and support the owner as they pursue incentives, select contractors, and move into implementation.

Each participant in the CAP is assigned a dedicated account manager who serves as a single point of contact across all five steps The account manager creates building accounts in the city’s software platform Touchstone IQ, syncs existing benchmarking data, reviews performance targets, and helps the owner understand how far they are from current and future compliance thresholds. They then work with engineering partners to move the building into audit preparation and, ultimately, into implementation.

“Equity Priority Buildings are the definition of hard to reach. They are busy, resource constrained, and often overwhelmed by competing demands. When we show with long term, no cost support and stay with them from benchmarking through implementation, we see a level of engagement that traditional programs have struggled to unlock.”

— Dr. Sharon Jaye - Energize Denver Building Performance Policy Manager

The graphic below provides a simple picture of this journey: starting with benchmarking assistance, moving through onsite audits and building-improvement support, and ending with help understanding financing and incentives. For utilities, this progression will feel familiar. It looks very much like the upstream funnel of a comprehensive efficiency program, with clear stages from awareness, to data, to scoping, to projects.

The Owner Journey: From Confusion to a Concrete Plan

From an owner or property manager’s perspective, the CAP is designed to feel more like a concierge service than a traditional compliance program.

Recruitment and Enrollment: Many participants first hear about CAP through targeted outreach informed by the Equity Index: phone calls, emails, and site visits that explain the program in plain language and invite them to apply. Staff use scripts that position the program as free, tailored support tied directly to Denver’s performance requirements, with benefits like hands-on benchmarking help and no-cost Level 2 audits.

Kick-Off Call and Data Cleanup: Once approved, each building receives an approval email and schedules a kick-off call. Prior to the call, owners are asked to gather basic documentation (ESPM credentials, floor-area documentation, utility account information) so that staff can immediately start data verification and benchmarking.

On the call, the account manager walks the owner through Energize Denver requirements, reviews existing data, and sets expectations for the timeline and service levels ahead. They also initiate full-service benchmarking support: correcting square footage, ensuring meters match, and submitting reports on the owner’s behalf when needed.

Assessment and Planning: After accurate data is in place, buildings move into a virtual assessment and then onsite ASHRAE Level 2 audits for the highest-priority sites. Engineers conduct detailed onsite evaluations and, working with the account manager, produce a compliance-focused deliverable that shows how different measure packages map to near-term and long-term performance targets.

Navigation and Implementation Support: Post-audit, CAP account managers stay involved, helping owners interpret audit findings, evaluate timelines, and connect to incentives, rebates, and financing resources. Program SOPs call for ongoing check-ins, support with compliance forms (target adjustments, alternate compliance pathways, extensions), and coordination with contractors.

Importantly, the program tracks each building’s status in the shared Touchstone IQ platform, from initial contact to “post-audit implementation”, so that no site falls through the cracks. For a utility audience, this is essentially an equity-focused energy advisor model that spans the full customer lifecycle rather than a one-and-done audit.[ES1] 

Does It Work? Early Results From the Pilot and Expansion

The pilot year results provide a first look at how an equity-first assistance model performs in practice.

Targeted Reach: In the 2023 pilot year, the city identified 480 potential Equity Priority Buildings, of which 178 were approved to participate in the CAP. Among those approved, 76% fell into the highest-need equity tier, 24% were located in Neighborhood Equity & Stabilization (NEST) neighborhoods, 57% were in areas below Denver’s median income, and 70% provided affordable housing.

Benchmarking Lift: Of the 178 approved participants, 153 submitted their 2023 benchmarking data, and 32 did so for the first time. The program also supported 36 target-adjustment applications, ensuring that buildings with atypical uses or constraints could pursue more realistic performance targets.

Audit Pipeline: As the program expanded, CAP commissioned more than 160 onsite ASHRAE Level 2 audits in 2025 alone, generating investment-ready scopes of work for equity-serving buildings that previously lacked access to this level of analysis.

Qualitative Feedback. Survey responses and case studies highlight reduced administrative burden (“we would not have been able to get through this process without the assistance”), increased awareness of incentives, and stronger relationships between city staff and building owners, especially in the nonprofit and affordable housing sectors.

While savings and cost-effectiveness metrics are still being compiled, the structure is clearly set up for future DSM-style reporting. Audits catalog measures, estimate energy and cost savings, and tie each project to incentives and funding sources, all of which can be aggregated at the program level and, over time, mapped directly into utility tracking and evaluation frameworks.

Why This Matters for Utilities

Utility regulators and program administrators are increasingly pushing for equity-centered portfolios, yet equity-focused efforts remain a slice of total program spending, and many low-income or frontline communities still see limited participation. Denver’s CAP shows what it looks like when that equity work is not a side program, but the organizing principle of how a whole segment is served.

Instead of thinking of the CAP as “just” a city compliance effort, utilities can look at it as a fully formed program design that happens to be anchored in a BPS. It offers:

A concierge model utilities already understand: The account-manager-plus-engineer stack looks a lot like a utility “energy advisor” or key account program, but pointed squarely at affordable housing, nonprofits, and community-serving buildings that rarely get that level of attention.

A ready-made project pipeline: CAP’s benchmarking support, virtual assessments, and onsite Level 2 audits function exactly like the upstream stages of a DSM program, identifying measures, packaging them into projects, and keeping a running list of buildings that are ready (or almost ready) to move.

A data backbone utilities can plug into: Standardized benchmarking, data verification, and audit templates make it easier to quantify savings and track progress over time, whether the driver is a BPS target, an efficiency goal, or both.

Equity metrics baked in from day one: Because participation is defined by an Equity Index and frontline community criteria, the same infrastructure that tracks kWh, therms, and peak impacts can also report on participation parity, geographic distribution, and support per building.

Seen in that light, CAP is not just a city program that utilities can “bolt onto”. It is a structure utilities can co-design around or emulate outright: a model for an Income Qualified/Hard To Reach building program where policy expectations, customer support, and DSM objectives all run through the same set of tools and relationships.

Translating Denver’s CAP Into a Utility-Replicable Model

For utilities considering how to evolve their own offerings, whether they operate in a BPS city or not, Denver’s experience reads like a practical blueprint for a utility-style efficiency and equity program aimed at commercial and multifamily buildings rather than individual households:

1. Start with a shared equity definition: Use local data and community input to define priority buildings and create an equity index or screening tool. That same index can guide both city outreach and utility program targeting and become a common reference point in filings and stakeholder conversations.

2. Design service levels that map to readiness: Borrow Denver’s tiered approach and apply it as a utility offering: lighter-touch benchmarking and technical support for some customers, deeper virtual assessments and full audits for others, with clear criteria for when a building “graduates” to the next level.

3. Anchor the journey in a single point of contact: Treat the account manager as the core of the program, not a nice-to-have. That person (or team) owns the relationship, coordinates engineers and trade allies, and stays with the customer from first contact through installation and verification.

4. Integrate DSM incentives into the core workflow: Whether the trigger is a BPS milestone, a voluntary performance goal, or a portfolio campaign, every audit and plan should explicitly map measures to utility incentives, federal funding, and financing tools, and those resources should be part of the scripted path forward, not an appendix.

5. Measure equity outcomes alongside savings: Build CAP-style metrics like who participates, where buildings are located, and how long it takes to move from audit to project, into the same dashboards that track kWh, therms, and peak reduction. That makes it easier to demonstrate that equity and system benefits are being delivered together, not traded off.

6. Plan for continuous improvement: Treat the first year as a pilot, just as Denver did. Use lessons about communication, application design, and post-audit follow-through to refine service levels and staffing, and be explicit that the program is a learning platform for the customer and the utility.

Framed this way, programs like Denver’s CAP are not just a way to help buildings comply with policy. They are a way for utilities to reimagine their own Income Qualified/Hard To Reach and multifamily strategies, using the same concierge, data-driven, equity-first model whether or not a BPS is in place.

Conclusion: Equity as the Engine, Not the Afterthought

Energize Denver’s Compliance Assistance Program began as an answer to a simple but profound question: if building performance standards are a central tool for meeting climate goals, how do we ensure they do not deepen inequities in who benefits and who bears the cost?

The early evidence suggests that when you design for equity from the start by prioritizing vulnerable communities, investing in hands-on navigation, and aligning audits and incentives with clear performance milestones, you not only protect those most at risk, you also unlock a powerful engine for utility-aligned savings.

For utilities and program implementers, CAP is an invitation. It shows that equity-first design does not have to sit on the margins of the portfolio or be limited to modest pilots. Instead, it can sit at the heart of how we deliver energy efficiency programs, channeling a steady stream of projects, savings, and community benefits in exactly the places that have been hardest to reach.

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About the Author

Ben Levine, Director of Business Development at Touchstone IQ, is a recognized thought leader in energy efficiency, building performance standards, and decarbonization for the built environment. He has nearly a decade of experience advancing software-driven solutions for utilities, municipalities, and commercial real estate owners. Ben has supported major initiatives with organizations such as DTE Energy, LADWP, Nova Scotia Power, Consumers Energy, TECO, and the New York City Economic Development Corporation. His work includes helping NYC EDC align its decarbonization planning with emerging BPS requirements and contribution to large-scale energy and sustainability initiatives across North America.

Ben has spoken at industry events and contributed articles on topics including performance standards, compliance assistance, and the role of data platforms in accelerating energy savings. With deep expertise in regulatory frameworks and market dynamics and a strong passion for tackling energy efficiency and decarbonization at scale through software, he is dedicated to building high impact, collaborative solutions that support a more sustainable built environment.