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
| Item | Form or tool | Who |
|---|---|---|
| Benchmarking (12+ months of whole-building energy data) | ENERGY STAR Portfolio Manager | Owner 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 EUI | Form C (from Portfolio Manager) | QEM calculates |
| Energy Management Plan | EMP reporting tool (required); Commerce template (optional) | Energy manager develops |
| O&M program and proof of implementation | O&M reporting tool (required); O&M Program Development Tool (optional) | Owner or facility staff; QEM attests on Form A |
| Compliance submission and incentive enrollment | Form A (owner, energy manager, QEM signatures); Exhibit A for the multifamily enhanced incentive | Submitted 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).