Across the United States, the energy used to power commercial buildings represents a sizeable portion of overall energy consumption and resulting greenhouse gas emissions. Until recently, building owners and managers did not have an easy way to compare the efficiency of their buildings. Through the ENERGY STAR program, the Environmental Protection Agency and Department of Energy created a tool to evaluate a building’s relative efficiency, a process called benchmarking. Recently, a growing number of cities have passed legislation requiring commercial building owners to track energy performance, as a way to help the cities meet their own climate goals. This Note examines three cities’ benchmarking legislation amidst the complex web of energy regulatory authority at the local, state, and federal levels and suggests that a successful energy benchmarking program must carefully coordinate with state regulators and local utility companies.