Washington Clean Buildings Performance Standard: What Building Owners Need to Know

For commercial building owners, property managers, landlords, and real estate firms, it is no longer enough to know how much energy a building uses. Covered buildings must now document energy performance, maintain energy management practices, and, in many cases, demonstrate progress toward specific efficiency requirements. Washington’s Clean Buildings Performance Standard, commonly called CBPS, is one of the most important building energy regulations in the country.

CBPS was created to reduce energy consumption and greenhouse gas emissions from existing buildings in Washington State. The rule is based on ASHRAE Standard 100-2018, with Washington-specific amendments added. In plain English, it pushes large existing buildings to operate more efficiently, track performance more consistently, and take action when energy use is too high.

For building owners, the key question is simple: does your building fall under Tier 1 or Tier 2, and what do you need to do before the deadline?

What Is the Washington Clean Buildings Performance Standard?

The Washington Clean Buildings Performance Standard is a statewide requirement for covered buildings located in Washington. Unlike basic benchmarking ordinances that only require annual reporting, CBPS includes a broader set of building performance and documentation requirements.

Covered buildings may need to:

• Benchmark energy use

• Track energy performance over time

• Create an energy management plan

• Implement an operations and maintenance program

• Determine an energy use intensity target

• Meet the target or pursue an approved compliance pathway

• Submit compliance documentation to the Washington State Department of Commerce

The goal is not just to collect data. The goal is to reduce wasted energy in existing buildings and improve how buildings are operated over time.

Who Must Comply With CBPS?

CBPS separates covered buildings into two main groups: Tier 1 and Tier 2.

Tier 1 Covered Buildings

Tier 1 covered buildings are generally larger commercial and institutional buildings. A Tier 1 building is one where the combined floor area exceeds 50,000 gross square feet, excluding parking garage area.

Tier 1 buildings have the most extensive compliance obligations. They must benchmark energy use, create an energy management plan, implement an operations and maintenance program, and meet an energy performance metric.

The Tier 1 compliance schedule is based on building size:

• June 1, 2026: Buildings greater than 220,000 sq. ft.

• June 1, 2027: Buildings greater than 90,000 sq. ft. but less than 220,001 sq. ft.

• June 1, 2028: Buildings greater than 50,000 sq. ft. but less than 90,001 sq. ft.

For owners of large buildings, this means preparation should already be underway. CBPS compliance is not something to start a few weeks before the deadline.

Tier 2 Covered Buildings

Tier 2 expands the standard to smaller buildings and multifamily properties. Tier 2 covered buildings include buildings where the combined gross floor area exceeds 20,000 square feet but does not exceed 50,000 square feet, excluding parking garage area.

Tier 2 also includes multifamily residential buildings that are 50,000 square feet or larger.

The Tier 2 reporting deadline is July 1, 2027.

Tier 2 buildings are not currently required to meet an energy use intensity target in the same way Tier 1 buildings are. However, they still have important compliance responsibilities, including benchmarking, creating an energy management plan, and implementing an operations and maintenance program.

What Is Benchmarking?

Benchmarking is the process of measuring and tracking a building’s energy use over time. For CBPS, benchmarking helps establish how much energy a building uses and allows owners to compare performance against a target or baseline.

Benchmarking usually involves gathering utility data, confirming building details, setting up or updating ENERGY STAR Portfolio Manager, and making sure the building’s information is accurate.

For owners, clean benchmarking data is critical. Incorrect square footage, missing meters, outdated property use details, or incomplete utility records can create inaccurate compliance records. If the inputs are wrong, the reported energy performance may be wrong too.

What Is an Energy Use Intensity Target?

Energy Use Intensity, or EUI, measures how much energy a building uses relative to its size. It is typically expressed as energy used per square foot per year.

Under CBPS, Tier 1 buildings must meet an energy performance metric. One way to do this is to meet the building’s energy use intensity target, often called EUIt. This target is based on building type and operating characteristics.

If a Tier 1 building meets its target, the building can demonstrate compliance through that pathway. If it does not meet the target, the owner may need to pursue another compliance pathway, such as the investment criteria pathway.

What Is the Investment Criteria Pathway?

The investment criteria pathway is an alternative route for Tier 1 buildings that may not meet the required EUI target.

This pathway generally involves conducting an energy audit and implementing cost-effective energy efficiency measures. The point is to show that the building owner has evaluated energy-saving opportunities and completed the required improvements that make financial and technical sense under the standard.

For building owners, this is where CBPS becomes more than reporting. If a building is not performing well enough, owners may need to move from data collection into audits, planning, and implementation.

What Is an Energy Management Plan?

An Energy Management Plan, or EMP, is a documented strategy for managing a building’s energy performance. It helps building owners and facility teams track energy use, identify operational changes, and maintain a structured process for improving performance.

A strong EMP may include energy tracking, roles and responsibilities, building operating characteristics, energy efficiency measures, staff training, and procedures for ongoing review.

The value of an EMP is that it turns energy management into a repeatable process instead of a once-a-year scramble.

What Is an Operations and Maintenance Program?

An operations and maintenance program, often called O&M, focuses on how building systems are maintained and operated.

This matters because many buildings waste energy not because the equipment is broken, but because systems are not being managed properly. HVAC schedules may be outdated. Sensors may be inaccurate. Controls may be overridden. Equipment may run after hours. Maintenance issues may quietly increase energy use over time.

CBPS requires covered buildings to have an O&M program because efficient buildings depend on consistent operations, not just efficient equipment.

Why Building Owners Should Start Early

CBPS compliance has long lead times for a reason. Owners may need time to confirm covered status, gather utility data, review building information, identify missing meters, calculate EUI, develop an EMP, create an O&M program, complete an audit, and implement efficiency measures.

Waiting until the deadline creates unnecessary risk.

Common problems include:

• Missing utility data

• Incorrect gross floor area

• Incomplete meter lists

• Outdated occupancy or operating hours

• Portfolio Manager setup issues

• Lack of internal responsibility

• No existing EMP or O&M documentation

• Not enough time to complete required improvements

The earlier owners start, the more options they have.

How IE Energy Helps With Washington CBPS Compliance

IE Energy helps building owners navigate Washington Clean Buildings Performance Standard requirements from start to finish.

Our team can assist with benchmarking, utility data collection, Portfolio Manager setup, EUI review, energy audits, operations and maintenance documentation, energy management planning, and compliance reporting.

We work with building owners, property managers, landlords, and commercial real estate teams that need clear guidance, accurate documentation, and practical next steps.

Final Takeaway

Washington’s Clean Buildings Performance Standard is not just another reporting requirement. It is a statewide framework for improving the energy performance of existing buildings.

For Tier 1 buildings, compliance may require meeting an EUI target or pursuing an investment-based pathway through energy audits and efficiency measures. For Tier 2 buildings, owners must still benchmark, create an energy management plan, and implement an operations and maintenance program.

The best approach is to start early, clean up building data, understand the applicable tier, and build a compliance plan before the deadline becomes urgent.

CBPS is complex, but the strategy is straightforward: know what applies, document the building correctly, understand performance, and take action early.