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CBPS compliance Deadline: Avoid continued penalties or fines by filing your report today!

What is CBPS ?

The Clean Buildings Performance Standard (CBPS) is a state-mandated energy efficiency law in Washington State that requires certain commercial and multifamily buildings to: Measure, Report, and Reduce their energy consumption to meet performance targets aimed at lowering greenhouse gas emissions.

How to Comply with CBPS

Benchmark Your Building

Use EPA's ENERGY STAR Portfolio Manager® to calculate your building's energy use intensity (EUI).

Develop Energy Management Plan

Create and implement a qualifying EMP at least one full year prior to submission.

Implement O&M Program

Develop and implement a qualifying Operations & Maintenance Plan one year before submission.

Submit Documentation

Submit all compliance documentation to the WA Department of Commerce by your deadline.

Important: Tier Requirements Differ

Tier 1: EMP and O&M must be enacted 12 months before compliance deadline.
Tier 2: EMP and O&M must be complete and implemented by July 1, 2027 (no 12-month look-back required).
Tier 2 buildings have more flexibility in timing but still need comprehensive planning.

Schedule a call

Tier 1

The Clean Buildings Performance Standard is mandatory for Tier 1 covered buildings located in the state of Washington.

Mandatory for Tier 1 Covered Buildings in Washington:

A Tier 1 covered building is a building where the sum of nonresidential, hotel, motel, and dormitory floor area exceeds 50,000 gross square feet, excluding the parking garage area.

Compliance & Reporting:

Mandatory compliance and reporting for Tier 1 covered buildings begins June 2026 for buildings greater than 220,000 sq ft.

Tier 2

The Clean Buildings Performance Standard is mandatory for Tier 2 covered buildings located in the state of Washington.

What is a Tier 2 Covered Building?

A Tier 2 building is a building where the sum of multifamily residential, nonresidential, hotel, motel, and dormitory floor areas exceeds 20,000 gross square feet, but does not exceed 50,000 gross square feet, excluding the parking garage area.

Mandatory for Tier 2 Covered Buildings in Washington:
On March 25, 2022, Governor Inslee signed the Clean Buildings expansion bill into law to include Tier 2 covered buildings.

Tier 1 and Tier 2 Compliance Requirements

Develop and implement:

Develop and implement the Energy Management Plan (EMP) and associated Operations and Maintenance Program (O&M) for each building as outlined in Sections 5 and 6 of the Clean Building Performance Standard. This step can happen concurrently with benchmarking.

Energy Management Plan (EMP):

The EMP template acts as a framework for building energy management planning in relation to the requirements of the CBPS. This optional resource can be used by building owners, authorized representatives, energy managers, or qualified persons to guide the creation of the energy management plan for Tier 1 or Tier 2 covered buildings.
An EMP outlines an organization’s goals for their building’s energy performance, tracks actual energy use of the building, reports historical energy use intensity (EUI) metrics compared to the building’s energy use intensity target (EUIt), and incorporates O&M protocols to ensure the building is operating as efficiently as possible.

O&M (Operations & Maintenance) Requirement:

  • Importance: Poor O&M can lead to energy wastage, reduced system life, and suboptimal performance even after investments in energy-efficient technologies.
  • Responsibilities: Conduct initial energy audits, gather baseline energy consumption data, and identify preliminary energy-saving opportunities.

Tier 1 compliance requirements:

  • Benchmark by measuring and tracking energy use in a building over time.
  • Implement an operations and maintenance (O&M) program in accordance with the standard.
  • Create an energy management plan (EMP).
  • Building Size: 50,000 sq ft or more.
  • Compliance Status: Mandatory (Deadlines: 2026–2028)

Tier 1 reporting schedule:

  • June 1, 2026: >220,000 sq. ft.
  • June 1, 2027: >90,000 sq. ft. but less than 220,001 sq. ft
  • June 1, 2028: >50,000 sq. ft. but less than 90,001 sq. ft

Tier 2 compliance requirements:

  • Benchmarking by measuring and tracking energy use in a building over time.
  • Implementing an operations and maintenance program. Develop a routine plan to maintain your building systems (HVAC, lighting, insulation, etc.) efficiently. Regular maintenance reduces energy waste and extends equipment life.
  • Creating an energy management plan.
  • Building Size: 20,000–49,999 sq ft
  • Compliance Status: Voluntary (for now)

Tier 2 reporting schedule:

  • July 1, 2027: >20,000 sq. ft.20,000 sq. ft.
  • Final rules expected by July 1, 2025
  • Compliance likely required starting 2027–2029

CBPS Compliance Packages

Washington’s Clean Buildings law is here. Don’t wait until 2027 your EMP + O&M must be up and running by July 1, 2026. Act now and your entire compliance package can be paid for by state incentives.

Tier I Packages (≥50k Sq.ft)

Tier I: Documentation Package

  • Energy Management Plan (EMP)
  • O&M Program (12-month look-back logs)
  • Benchmarking setup & filing
  • Forms A/B/C preparation + portal submission

50–90k sq ft – $25,000

50–90k sq ft – $25,000

50–90k sq ft – $25,000

Document Packages

Tier I: Conditional Path Package

Add-on: $15,000–$25,000

  • ASHRAE Level II Audit (Form D)
  • Investment Criteria Tool (Form F)
  • Implementation roadmap

$0.85/sf OR $2.00/sf + $0.05 per kBtu saved >15 (capped at 50% of project cost).

Example: 100k ft² office → $85k–$200k+ incentive

💰 Packages designed to ensure you capture maximum funding

Conditional Packages

Tier II Packages (20k–50k sq ft )

Tier II: Commercial $15,000

  • Energy Management Plan (EMP)
  • Operations & Maintenance Program (O&M)
  • Benchmarking setup & filing
  • Staff training + certificate
  • Incentive paperwork filing

$0.30/sf → Typical 50k building = $15,000 incentive

💰 Net cost: $0 (if incentive approved)

Commercial Package

Tier II: Multifamily $17,000

  • Energy Management Plan (EMP)
  • O&M Program tailored for multifamily
  • Benchmarking setup & filing
  • Incentive paperwork filing

$0.30/sf base; $0.75/sf with Anti-Displacement Agreement → Typical 50k = $37,500 incentive

💰 Net cost: $0 (if incentive approved)

MultiFamily Packages

Tier I Service Fees ( ≥50k Sq.ft )

Tier I: Basic Requirements

  • Benchmarking setup & filing
  • Operations & Maintenance Program (O&M)
  • Energy Management Plan (EMP)
  • Prepare & file Forms A, B & C
  • Early Adopter Incentives Application filing
50–90k sq ft
– $15,000
90-220k sq ft – $20,000
Over 220k sq ft – $25,000

$2.00/sf + $0.05 per kBtu saved >15 (capped at 50% of project cost).

Example: 100k ft² office → $85k–$200k+ incentive

💰 Packages designed to ensure you capture maximum funding

Request Pricing

Tier I: Investment/Conditional Criteria Path

For those not meeting EUIt:

  • ASHRAE Level II Audit (Form D)
  • Investment Criteria Tool (Form F)
  • Implementation roadmap

$2.00/sf + $0.05 per kBtu saved >15 (capped at 50% of project cost).

Example: 100k ft² office → $85k–$200k+ incentive

💰 Packages designed to ensure you capture maximum funding

Request Pricing

Tier II Service Fees( ≥20k–50k sq ft )

Tier II: Multifamily

  • Benchmarking setup & filing
  • Operations & Maintenance Program (O&M)
  • Energy Management Plan (EMP)
  • Prepare & file Forms A, B & C
  • Early Adopter Incentives Application filing

$0.30/sf base; $0.75/sf with Anti-Displacement Agreement → Typical 50k = $37,500 incentive

💰 Net cost: $0 (if incentive approved)

Request Pricing

Tier II: Commercial

  • Benchmarking setup & filing
  • Operations & Maintenance Program (O&M)
  • Energy Management Plan (EMP)
  • Prepare & file Forms A, B & C
  • Early Adopter Incentives Application filing

$0.30/sf → Typical 50k building = $15,000 incentive

💰 Net cost: $0 (if incentive approved)

Request Pricing
Early Adopter Incentive
Book a Consultation

Frequently Asked Questions

Are there additional incentive funds available for Tier 1 and Tier 2 buildings?
Yes, see the CBPS Incentives & Savings page for more information

Public Buildings are buildings owned by State Agencies, School and Health Districts, Colleges and Cities, Municipalities and Counties (this does not include buildings owned by a non-profit, even if the non-profit is funded by a public agency).

The Clean Buildings Portal is a database of all covered buildings. It provides building owners with a secure system to manage their building’s compliance with the Clean Buildings Performance Standard and submit applications to the Early Adopter Incentive Program. Please note: Features for Tier 2 will not be available until after July 2025.

For Tier 1, the maximum penalty is $5,000 plus an amount based on the duration of any continuing violation. The additional amount for a continuing violation may not exceed $1.50 per square foot. For more details, refer to Z5.4 Assessment of Administrative Penalties in the Clean Buildings Performance Standard.

For Tier 2, the maximum penalty is $0.30 per square foot. For more details, refer to Y5.4 Assessment of Administrative Penalties in the Clean Buildings Performance Standard.

Commerce also has a penalty calculator: CBPS 015- CBPS Penalties Estimator.xlsx | Powered by Box. Penalties are assessed for each 5-year compliance period.

Let’s Get You Compliant

Avoid Penalties.

Stay Ahead of Deadlines.

CBPS compliance isn’t just about following the law  it’s about protecting your investment. We’ll guide you through every step: benchmarking, audits, reports, and submission.

CBPS Compliance Advisor

CBPS Compliance Packages

+1 877-892-0217

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