Washington · Tier 2

Tier 2 requirements

In brief

By July 1, 2027, owners of Tier 2 buildings must submit, through Commerce's Clean Buildings Portal: ENERGY STAR Portfolio Manager benchmarking, an energy use intensity target (EUIt), a measured EUI, an Energy Management Plan, and an O&M program with proof of implementation, signed on Form A by the owner, energy manager and a Qualified Energy Manager. (Commerce Tier 2 page and CBPS 017, checked October 26, 2026.)

Who is covered

Buildings where nonresidential, hotel, motel and dormitory floor area exceeds 20,000 but not 50,000 gross sq ft (excluding parking garage), and multifamily residential buildings over 20,000 gross sq ft. Federal and tribal-owned buildings are excluded.

The pieces

ItemForm or toolWho
Benchmarking (12+ months of whole-building energy data)ENERGY STAR Portfolio ManagerOwner or energy manager; utilities must provide data on request
Energy use intensity target (EUIt)Form B (activity type, floor area, shift normalization)QEM establishes
Measured EUIForm C (from Portfolio Manager)QEM calculates
Energy Management PlanEMP reporting tool (required); Commerce template (optional)Energy manager develops
O&M program and proof of implementationO&M reporting tool (required); O&M Program Development Tool (optional)Owner or facility staff; QEM attests on Form A
Compliance submission and incentive enrollmentForm A (owner, energy manager, QEM signatures); Exhibit A for the multifamily enhanced incentiveSubmitted in the Clean Buildings Portal

Proof of O&M implementation

Commerce's October 22, 2026 bulletin says proof can include completed preventive-maintenance logs, screenshots of a computerized maintenance system, signed service contracts showing PM is contracted out, or other documentation of completed PM, and it is due by the reporting date or at submission, whichever is earlier. See a sample PM log (fictional building).

Performance target

Tier 2 buildings must identify an EUIt but are not required to meet it at this time.

Penalties

Commerce may assess progressive penalties for failing to submit, capped at up to $0.30 per square foot.

Sources, checked October 26, 2026 WA Dept. of Commerce, CBPS Tier 2 compliance page; Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026; Commerce guidance CBPS 016, Compliance Forms (updated June 26, 2025); WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle).