Washington State Department of Commerce
Washington CBPS Summary
Washington’s Clean Buildings Performance Standard (CBPS) is administered by the Washington State Department of Commerce and requires covered building owners to track energy use, establish energy management practices, and document compliance. Requirements depend on the building’s size and use:
Tier 1: Covered nonresidential, hotel, motel, and dormitory space totaling more than 50,000 gross square feet.
Tier 2: Buildings with more than 20,000 and up to 50,000 gross square feet of combined multifamily residential, nonresidential, hotel, motel, and dormitory space, plus larger multifamily residential buildings.
Parking garage area is excluded. Mixed-use properties require a review of their floor-area breakdown.
Benchmarking Requirement
Both tiers must track building energy use in ENERGY STAR® Portfolio Manager. Dena Energy helps owners organize utility data, review building information, and determine the applicable energy use intensity target (EUIt).
Compliance Requirements and Deadlines
Unless an exemption applies, both tiers must develop and implement an Energy Management Plan (EMP) and an Operations and Maintenance (O&M) program. Tier 1 also requires an applicable energy-performance compliance pathway. Tier 2 does not currently require meeting a performance target.
June 1, 2026: Tier 1 buildings over 220,000 square feet (deadline has passed).
June 1, 2027: Tier 1 buildings over 90,000 through 220,000 square feet.
June 1, 2028: Tier 1 buildings over 50,000 through 90,000 square feet.
July 1, 2027: Tier 2 covered buildings.
Reporting repeats every five years. Start early to allow time for data collection, implementation, and documentation.
CBPS Exemptions
Some buildings qualify for an exemption based on their use, occupancy, condition, or other criteria. Owners must document exemption eligibility and obtain approval from the Washington State Department of Commerce. We can help review your building’s circumstances and prepare the application.
Contact Dena Energy for a no-cost consultation about your building’s CBPS requirements and next steps.
What Is the Benchmarking Requirement in CBPS?
Benchmarking establishes a reliable picture of your building’s energy use. We review the Portfolio Manager account, identify missing information, and help coordinate utility-data access.
To begin, we typically request:
The building address, Washington building ID, and any Washington State Department of Commerce notices.
Gross floor area, building uses, and operating schedules.
Portfolio Manager access and available historical energy records.
Electricity, natural gas, and other fuel or purchased-energy information, including tenant accounts where applicable.
Details of onsite generation, shared meters, and district energy, if present.
Existing equipment inventories, maintenance records, and energy-management documents.
Our review helps establish the building’s energy use intensity (EUI) and weather-normalized EUI (WNEUI), compare performance with the applicable target or national median where required, and identify the next compliance steps. A high ENERGY STAR score alone does not replace the full CBPS requirements.
Which Buildings Are Outside CBPS Coverage?
Federal buildings and buildings owned by federally recognized tribes are not required to comply. Buildings that do not exceed the applicable size thresholds are generally outside coverage. Parking garages are excluded from the covered floor-area calculation.
For mixed-use buildings, coverage depends on the areas assigned to different uses. We review the property details before recommending a compliance scope.
Exemptions from CBPS Compliance
Potential exemption categories include:
Qualifying periods without physical occupancy or without a certificate of occupancy.
Qualifying unconditioned or semi-heated space.
Qualifying manufacturing or industrial uses.
Qualifying agricultural structures, pending demolition, financial hardship, or national security circumstances meeting the standard’s criteria.
Each category has specific conditions and evidence requirements. Exemptions apply to individual buildings and the current compliance cycle. The rules require exemption applications no later than 180 days before the compliance date. Tier 1 owners must also recertify approved exemptions within the six months before their compliance date. Contact the department promptly if a filing date has passed. Review the department’s Tier 2 guidance or Tier 1 guidance for the applicable rules. Some Tier 1 exemptions leave benchmarking, EMP, and O&M obligations in place for nonexempt space.
Compliance Extensions
A two-year extension may be available when specified conditions are met. Applications require supporting documentation and must be submitted within the allowed window, from six months before through six months after the compliance date. An extension requires department approval; it is not automatic.
What Are the CBPS Energy Management and Audit Requirements?
Compliance goes beyond uploading utility bills. Owners must develop and implement energy-management and maintenance practices, with additional performance requirements for Tier 1 buildings.
Energy Management Plan (EMP)
The EMP establishes how the building’s energy performance will be managed. Dena Energy works with owners and facility teams to document responsibilities, energy tracking, operating practices, and improvement priorities in a practical plan for the property.
Operations and Maintenance (O&M) Program
The O&M program documents how energy-using equipment will be maintained and operated efficiently. We help organize:
Equipment and system inventories.
Preventive-maintenance tasks and schedules.
Staff and service-contractor responsibilities.
Records showing that the program is being implemented.
Preparing a document is only part of the work. We coordinate with your facility team and service contractors to identify gaps and document implementation.
Tier 1 Energy Audits and Performance Compliance
Tier 1 buildings pursuing performance compliance must follow an applicable pathway. Options include meeting the building’s EUIt, complying through investment criteria, demonstrating qualifying energy-use reductions, or completing qualifying space-heating electrification. Each pathway has its own conditions and documentation requirements.
An ASHRAE Level II (Level 2) audit is part of the investment-criteria pathway. Audit findings support the evaluation of energy-efficiency measures, project costs, and required implementation and verification. An audit is not automatically required for every covered building.
Dena Energy can help evaluate the available pathways and define the audit or specialist support your property needs.
Tier 2 Compliance
Tier 2 focuses on benchmarking, comparing weather-normalized energy use with the applicable target or national median where required, and implementing the EMP and O&M program. Meeting an energy-performance target is not currently required for Tier 2. We help owners assemble the required documentation and coordinate reporting through the Clean Buildings Portal.
For official requirements, see the Washington State Department of Commerce CBPS resources and Chapter 194-50 WAC.
How Dena Energy Can Help with Washington CBPS Compliance
Dena Energy helps Washington building owners and property managers navigate CBPS requirements, from applicability review and benchmarking to energy-management planning, O&M documentation, and compliance reporting.
Send us your property address, approximate floor area, building type, and any Washington State Department of Commerce notice to get started. Contact us today for a no-cost, no-obligation consultation.
Phone: (888) 302-3362
Email: info@dena.energy