The U.S. DOE Superior Energy Performance (SEP) program provides recognition to industrial and commercial facilities that achieve certification to the ISO 50001 energy management system standard and third party verification of energy performance improvements. Over 50 industrial facilities are participating and 28 facilities have been certified in the SEP program. These facilities find value in the robust, data driven energy performance improvement result that the SEP program delivers. Previous analysis of SEP certified facility data demonstrated the cost effectiveness of SEP and identified internal staff time to be the largest cost component related to SEP implementation and certification. This paper analyzes previously reported and newly collected data of costs and benefits associated with the implementation of an ISO 50001 and SEP certification. By disaggregating “sunk energy management system (EnMS) labor costs”, this analysis results in a more accurate and detailed understanding of the costs and benefits of SEP participation. SEP is shown to significantly improve and sustain energy performance and energy cost savings, resulting in a highly attractive return on investment. To illustrate these results, a payback function has been developed and is presented. On average facilities with annual energy spend greater than $2M can expect to implement SEP with a payback of less than 1.5 years. Finally, this paper also observes and details decreasing facility costs associated with implementing ISO 50001 and certifying to the SEP program, as the program has improved from pilot, to demonstration, to full launch.