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Seattle Buildings:
Dual Compliance Requirements
Seattle CBPS and BEPS: One Strategy, Two Regulations
Navigate both Clean Buildings Performance Standard (CBPS) and Building Emissions Performance Standard (BEPS) with a unified compliance strategy
🚨 Important Regulatory Transition Alert
Building Tune-Ups Are Ending
Seattle Building Tune-Ups ordinance expires December 31, 2028. Complete your second cycle by these deadlines:
- 200k+ SF: Oct 1, 2023 ✓
- 100-199k SF: Oct 1, 2024 ✓
- 70-99k SF: Oct 1, 2025
- 50-69k SF: Oct 1, 2026
BEPS Is the Replacement
Building Emissions Performance Standard (BEPS) starts in 2027 and replaces Tune-Ups with more comprehensive emissions requirements:
- Covers same buildings as Tune-Ups
- 5-year compliance cycles
- Net-zero goals by 2045-2050
- No overlap period
Plus State CBPS
Washington State Clean Buildings Performance Standard continues alongside BEPS:
- Different requirements & deadlines
- Managed by WA Commerce
- Coordinated compliance saves time & money
- Same qualified professionals can handle both
Bottom Line: Seattle buildings face a transition from Tune-Ups (ending 2028) to BEPS (starting 2027), while also complying with state CBPS. Buildings over 50,000 SF face coordinated deadlines just 3 months apart. The key is unified planning to meet all requirements efficiently and avoid cumulative penalties exceeding $20,000 plus $4.50/SF every 5 years.
Understanding Dual Compliance
Seattle buildings over 20,000 square feet face a unique challenge: compliance with both Washington State’s Clean Buildings Performance Standard (CBPS) and Seattle’s Building Emissions Performance Standard (BEPS). These complementary regulations work together toward the same goal of reducing building emissions, but each has distinct requirements and timelines.
Why Dual Compliance Matters
BEPS was specifically designed to complement CBPS, using similar frameworks and allowing for coordinated compliance strategies. Buildings that plan for both standards simultaneously can achieve significant efficiencies in reporting, implementation, and long-term planning.
Building Coverage & Requirements
Clean Buildings Performance Standard (CBPS)
- Coverage: Commercial buildings ≥50,000 sf (active)
- Tier 2: Buildings 20,000-50,000 sf + multifamily (rules finalizing Dec 2023)
- Focus: Energy Use Intensity (EUI) targets
- Penalties: Up to $5,000 + $1.00-$1.50/sf
Building Emissions Performance Standard (BEPS)
- Coverage: All nonresidential & multifamily ≥20,000 sf
- Focus: Greenhouse Gas Intensity (GHGI) targets
- Timeline: 5-year cycles toward net-zero by 2050
- Penalties: $15,000 + $2.50-$3.33/sf
Critical Timeline Coordination
For buildings 50,000-220,000 square feet, BEPS reporting follows CBPS deadlines by only three months, making coordinated compliance essential.
Building Size
BEPS Reporting
BEPS Compliance
Net Zero Target
>220,000 sf
Oct 1, 2027
Oct 1, 2031
2041 (Non-res) / 2046 (Multi)
90,000-220,000 sf
Oct 1, 2027
Oct 1, 2032
2042 (Non-res) / 2047 (Multi)
50,000-90,000 sf
Oct 1, 2028
Oct 1, 2033
2043 (Non-res) / 2048 (Multi)
30,000-50,000 sf
Oct 1, 2029
Oct 1, 2034
2044 (Non-res) / 2049 (Multi)
20,000-30,000 sf
Oct 1, 2030
Oct 1, 2035
2045 (Non-res) / 2050 (Multi)
Compliance Requirements & Pathways
BEPS Specific Requirements
Benchmarking Verification
- Required every 5 years starting 2027-2030
- Must be performed by different Qualified Person than annual benchmarking
- Verifies accuracy of ENERGY STAR Portfolio Manager data
- All-electric buildings exempt from GHG targets after verification
GHG Report Requirements
- GHGI and compliance targets using BEPS emissions factors
- Documentation of actions to meet targets
- Major mechanical equipment inventory with age and fuel sources
- Future compliance planning for subsequent cycles
Alternative Compliance Options
BEPS Pathways
- All-electric buildings: Automatically compliant
- Alternative Compliance Payments: Available 2031-2035 only ($190/MTCO2e)
- Portfolio aggregation: Campus/portfolio GHGI targets
- Multifamily prescriptive options: First 3 cycles
- Affordable housing: Exempt through 2035
Available Deductions
- Cooking equipment: Gas stoves/grills (through 2040)
- High-intensity process: Hospital/lab equipment (through 2040)
- Condo unit equipment: In-unit gas appliances (always)
- EV charging: Electric vehicle equipment (always)
- District energy contracts: Pre-June 2024 contracts (through 2035)
Combined Penalty Risk
Non-compliance with both standards can result in significant cumulative penalties:
Up to $20,000+
Combined flat penalties for failure to report
$4.50+ /sf
Combined per-square-foot penalties every 5 years
Building Coverage & Requirements
CBPS: Energy Standard
- Metric: Energy Use Intensity (EUI) in kBtu/SF/yr
- Goal: Reduce total energy consumption
- Factors: ENERGY STAR Portfolio Manager regional emissions
- Scope: State-level program managed by Commerce
BEPS: Emissions Standard
- Metric: Greenhouse Gas Intensity (GHGI) in kgCO2e/SF/yr
- Goal: Reduce carbon emissions from energy use
- Factors: Seattle City Light local grid (93% renewable)
- Scope: City-level program managed by OSE
Critical Insight: Why Emissions Factors Matter
Seattle’s local electricity grid is 93% renewable with very low emissions, while ENERGY STAR uses regional Northwest grid factors (including Idaho, Montana) with higher fossil fuel content. This means electrification is much more effective for BEPS compliance than CBPS suggests, making it the optimal strategy for Seattle buildings.
Our Strategic Benefits & Support Resources
Efficiency Advantages of Coordinated Compliance
- Single ENERGY STAR Portfolio Manager profile serves both standards
- Same Qualified Person can handle both CBPS and BEPS requirements
- Coordinated equipment upgrades maximize investment ROI
- Streamlined documentation and record-keeping processes
- Unified long-term decarbonization planning toward net-zero
- Electrification strategy effective for both standards due to Seattle's clean grid
City Support Programs
Financial Assistance
- $17.2M federal grant for BEPS implementation support
- $3.5M in building decarbonization grants awarded 2024
- Additional grants planned for 2025
- 40% of ACP revenue directed to low-income communities
Frequently Asked Questions
Can I use RECs, offsets, or carbon credits for BEPS compliance?
No. BEPS does not allow renewable energy credits (RECs), carbon offsets, or renewable energy certificates for compliance. However, renewable natural gas (RNG) and biodiesel may be used if purchased through utility programs, utilized directly in pipelines, and third-party verified through registries like M-RETS or Green-e.
What happens if ENERGY STAR Portfolio Manager is discontinued?
Seattle’s Benchmarking law allows the city to use “ENERGY STAR Portfolio Manager or a similar rating system established by Director’s Rule.” This provision enables Seattle to adopt alternative reporting tools if the federal ENERGY STAR program is eliminated.
How are buildings with multiple uses handled?
GHGI targets are weighted by floor area for different space uses. For example, a building with 80% office space and 20% retail would calculate a weighted target based on each space type’s individual GHGIT and percentage of total floor area.
Can I make Alternative Compliance Payments instead of meeting targets?
Yes, but only for the 2031-2035 compliance cycle. ACPs are calculated at $190 per metric ton of CO2e excess over the target, covering the full 5-year period. This is a deferral option, not an opt-out – buildings must still meet targets in subsequent cycles or face penalties.
Do restaurant cooking equipment and residential gas stoves count toward targets?
Gas cooking equipment emissions can be deducted from compliance calculations through 2040 for all buildings. For residential condos, in-unit gas equipment (stoves, fireplaces, water heaters) owned by individual unit owners can always be deducted.
What are the penalties for non-compliance?
BEPS penalties are assessed 360 days after compliance deadlines. Rates are up to $10/SF for nonresidential, $7.50/SF for multifamily, and $2.50/SF for affordable housing. Failure to report carries flat penalties up to $15,000. Combined with CBPS penalties, total exposure can exceed $20,000 plus $4.50/SF every 5 years.
Let’s Get Your Energy Audit Started
Avoid Penalties.
Stay Ahead of Deadlines.
Energy audit compliance in Washington isn’t just a legal requirement – it’s a strategic move to improve efficiency and reduce costs. We’ll guide you through every step: conducting ASHRAE-compliant audits, analyzing energy performance, developing actionable plans, and submitting all required documentation to the state.
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