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.

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.

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.

Building Performance Standards (BPS) are often considered Phase II of these building energy use ordinances. After reporting your benchmarking data, many ordinances require you to make changes to the building’s operations or equipment to lower energy use over time.

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 energy audit and implementing all cost-effective efficiency measures.

Tier 1 Compliance Due Date

June 1, 2026 – Buildings over 220,000 Sq. Ft.

June 1, 2027 – Buildings over 90,000 Sq. Ft.

June 1, 2028 – Buildings over 50,000 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.

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.

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.

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 Green Econome 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.

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. Green Econome takes every measure to ensure complete and accurate data collection. The sooner you reach out, the sooner you will reach compliance.