How Massachusetts’ New Building Code Will Affect Energy Metering Requirements

The 10th Edition of the Massachusetts State Building Code (780 CMR) introduces a major new requirement for developers, building owners and facility managers: mandatory energy metering and monitoring for large new buildings.

If you own, design or operate facilities in Massachusetts, this change affects your next project. In this article, you’ll learn:

• Which buildings must comply and which may qualify for exemptions
• What equipment and data systems are now required
• How the rule connects to Massachusetts’ climate goals
• What steps to take now to avoid costly retrofits later
  
  

1. Which Projects Are Affected and Why It Matters

Under Section C405.12 of the 2021 International Energy Conservation Code (IECC), as amended for Massachusetts, all new buildings with 25,000 square feet or more of conditioned space must include systems to measure, monitor, record and report energy use. Smaller buildings can add metering voluntarily and earn efficiency credits under Section C406.10.

This threshold is deliberate.It focuses on the state’s largest energy consumers, where submetering data empowers building operators to make informed decisions that can meaningfully reduce energy use and carbon emissions.

Pro tip: If your project crosses 25,000 square feet, plan metering early in the mechanical, electrical and plumbing (MEP) design phase. Treating it as an add-on later drives up cost, complexity and the risk of missing key integration points.

2. Required Equipment and How It Works

Each qualifying building must track energy use by end-use category, including:

• HVAC systems: heating, cooling, ventilation, water heating 
• Lighting: interior and exterior
• Plug loads: outlets, office equipment, appliances
• Process loads: data centers, manufacturing, commercial kitchens
• Miscellaneous: elevators, shading, fountains, snow-melt systems

Meters or sensors must connect to a data acquisition system (DAS) that automatically collects hourly data, integrates all categories and stores at least 36 months of history. Built-in equipment monitors can qualify if they meet ±2% accuracy and required reporting standards.

Why it matters: Breaking energy use into categories helps identify the biggest savings opportunities and enables real-time performance tracking.

3. Exemptions: What’s Not Covered

Some spaces are exempt from the requirement, including:

• Residential (R-2) occupancies such as apartments and dorms under 5,000 square feet with separate utilities
• Tenant spaces under 2,500 square feet with a dedicated source meter
• Emergency-only systems like fire pumps or stairwell fans

These exemptions reflect smaller or intermittent loads where detailed metering adds limited value. Always confirm exemptions early and document them thoroughly—local officials will likely cross-check data during the permitting process.

4. Data System Requirements and Practical Use

The code requires a permanent, accessible data acquisition system capable of generating:

• Hourly, daily, monthly and annual graphical reports for each end-use
• Historical data retention for a minimum of 36 months

Look for dedicated energy management platforms that specialize in displaying meter data The most value comes when data is used for real-time decision-making, not just compliance documentation.

Bonus benefit: When paired with expert analysis, these systems can surface specific opportunities to improve performance, spot issues earlier and better understand how energy is being used.

5. Why This Change Is Bigger Than Compliance

The monitoring requirement supports Massachusetts’ broader climate framework—including LBER, BERDO, and BUEDO—which aim to cut carbon emissions through transparency and performance tracking.

For owners and operators, this shift is more than a regulatory checkbox.
It’s a chance to unlock:

• Lower operating costs through better load management
• Improved forecasting and budgeting
• Stronger ESG performance for investors and stakeholders
  
  

In short: What starts as compliance can quickly become a competitive advantage.

6. How to Prepare Now

Get ahead of compliance by integrating metering and monitoring into project planning:

1. Confirm building size and occupancy type early in design
2. Budget for end-use metering in MEP and electrical packages
3. Integrate data storage and reporting into your digital infrastructure
4. Engage an energy professional to verify compliance with both IECC 2021 and 780 CMR

Planning ahead avoids expensive rework and ensures your facility is ready for future performance-based standards.

Turning Compliance Into Insight

When implemented well, energy metering is more than a code requirement—it’s an opportunity to turn data into decisions.

The same systems that meet 780 CMR requirements can also:

• Drive predictive maintenance
• Expose hidden energy waste
• Simplify sustainability and ESG reporting