The state of Washington’s Clean Building Performance Standards (CBPS) program is a statewide energy benchmarking & emissions reduction program requiring owners of existing buildings to report energy use using ENERGY STAR® Portfolio Manager®. Effective as of May 2019, this program provides building owners insight into their building’s energy efficiency and helps meet the State of Washington’s Climate Action Plan goals.
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WHAT BUILDINGS ARE COVERED UNDER WASHINGTON CBPS?
Tier 1
Non-residential, hotel, motel, and dormitory buildings over 50,000 Sq. Ft.
Tier 2
Non-residential, hotel, motel, and dormitory buildings between 20,000 and 50,000 Sq. Ft.
AND
All residential multifamily buildings over 20,000 Sq. Ft.
WHAT INFORMATION IS REQUIRED FOR BENCHMARKING?
Benchmarking reporting requires 12 calendar months of whole-building energy and building use data. For example, in 2025, building owners must report 12 months of 2024 data.
WHEN ARE WASHINGTON CBPS BENCHMARKING REPORTS DUE?
Compliance is required by June 1. The year in which different buildings begin reporting is explained below. Washington CBPS does not yet require annual benchmarking, but we strongly recommend annual benchmarking because it provides year-over-year data of your efficiency efforts.
Benchmarking reports must be submitted using the previous year’s data via ENERGY STAR® Portfolio Manager®. This is the EPA’s benchmarking tool that is used for compliance reporting in most ordinances across the country.
WHAT INFORMATION IS REQUIRED FOR BPS?
Washington CBPS has different requirements depending on the covered building tier. All buildings must benchmark, implement an operations and maintenance (O&M) program, and create an energy management plan (EMP). O&M programs must be initiated 12 months before the building’s compliance date.
Additionally, Tier 1 buildings must determine an energy use intensity (EUI) target based on their benchmarking data. If one is not identifiable or possible to achieve, the building will initiate an “investment criteria” pathway. Investment criteria pathways entail performing an ASHRAE Level II energy audit, life-cycle cost analysis, and implementing all cost-effective efficiency measures.
WHEN ARE WASHINGTON CBPS REPORTS DUE?
Tier 1 Compliance Due Date
June 1, 2026 – Buildings over 220,000 Sq. Ft.
June 1, 2027 – Buildings over 90,000 to 220,000 Sq. Ft.
June 1, 2028 – Buildings over 50,000 to 90,000 Sq. Ft.
Tier 2 Compliance Due Date
July 1, 2027 – All tier 2 covered buildings.
Buildings will need to comply every 5 years after their initial deadlines. Washington will use the benchmarking data from 2026-2028 to develop the next cycle’s targets.
WHAT IS THIRD-PARTY DATA VERIFICATION?
Third-party data verification requires owners/managers of covered buildings to hire a third-party expert who will independently review and verify the building’s benchmarking data.
While Washington CBPS does not have a standard data verification regulation, it does require a qualified person to establish energy use targets and state in writing that the Energy Management plan and Operations and Maintenance program requirements have been developed, implemented, and maintained.
A qualified person can be a Certified Energy Manager (CEM), Energy Management Professional (EMP), or a qualified energy auditor.
WHAT ARE THE PENALTIES IF YOU DON'T COMPLY WITH WASHINGTON CBPS?
The Washington State Department of Commerce is authorized to impose penalties upon failure to submit of up to $5,000 plus an additional amount for ongoing violations. This added amount can be up to $1 per square foot per year.
Tier 2 buildings may be assessed penalties up to 30 cents per square foot for failing to submit proper documentation.
HOW DO I COMPLY WITH WASHINGTON CBPS?
CONTACT US HERE to learn more and get started with compliance.
Washington CBPS compliance can be confusing and hard to navigate. Bringing on a consultant like VCA Green streamlines the entire process while ensuring accurate reporting. We also offer free consultations with our benchmarking clients to review the reports and identify inefficiencies to improve.
WHEN SHOULD I START WASHINGTON CBPS COMPLIANCE?
Ordinances such as Washington CBPS are already in effect across the country, and deadlines are rapidly approaching. Retrieving historical building data will take time, especially when coordinating with property managers and utilities.
Waiting until the last minute risks missing compliance windows resulting in fines and enforcement penalties. VCA Green takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.
WASHINGTON CBPS RESOURCES
Policy
Washington Clean Buildings Performance Standards (CBPS)
Bill Text
Washington HB1543
Enforcing Agency
Washington State Department of Commerce
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VCA GREEN PROCESS
With every phase of the process, VCA Green’s experienced and knowledgeable team is here to guide you on the results, options, and path forward to meet your compliance goals.
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