This paper evaluates the issue of non-energy benefits within the context of the U.S. energy services company (ESCO) industry—a growing industry comprised of companies that provide energy savings and other benefits to customers through the use of performance-based contracting. Recent analysis has found that ESCO projects in the public/institutional sector, especially at K-12 schools, are using performance-based contracting, at the behest of the customers, to partially — but not fully — offset substantial accumulated deferred maintenance needs (e.g., asbestos removal, wiring) and measures that have very long paybacks (roof replacement). This trend is affecting the traditional economic measures policymakers use to evaluate success on a benefit to cost basis. Moreover, the value of non-energy benefits which can offset some or all of the cost of the non-energy measures — including operations and maintenance (O&M) savings, avoided capital costs, and tradable pollution emissions allowances — are not always incorporated into a formal cost-effectiveness analysis of ESCO projects. Non- energy benefits are clearly important to customers, but state and federal laws that govern the acceptance of these types of benefits for ESCO projects vary widely (i.e., 0-100% of allowable savings can come from one or more non-energy categories). Clear and consistent guidance on what types of savings are recognized in Energy Savings Agreements under performance contracts is necessary, particularly where customers are searching for deep energy efficiency gains in the building sector.