# Clean Buildings Associates: full text of the Washington Clean Buildings Tier 2 guides

> Clean Buildings Associates is a private company (Voraus LLC). We are not affiliated with or endorsed by the Washington State Department of Commerce. Free templates and guidance are available at commerce.wa.gov/cbps. Every fact below was checked against the cited Commerce, RCW, WAC or City of Seattle source on October 27, 2026. Incentive figures as of October 24, 2026.


---

URL: https://cleanbuildingsassociates.com/
Title: Washington Clean Buildings Tier 2 filing, flat fee
Last updated: 2026-10-27

# Washington Clean Buildings Tier 2 filing preparation

A 30,000 sq ft building could earn about $9,000. We prepare your Tier 2 filing for a flat fee per building. Funding is first-come, first-served, and the deadline is July 1, 2027.
Reviewed and signed by a credentialed Qualified Energy Manager
Incentives are paid directly to you by your utility, typically 4–8 weeks after Commerce reserves them.

Estimate your incentive (https://cleanbuildingsassociates.com/washington/incentive/)Fees and quotes → (https://cleanbuildingsassociates.com/pricing/)

For buildings of 20,001 to 50,000 sq ft (nonresidential) and multifamily buildings over 20,000 sq ft.

(https://cleanbuildingsassociates.com/sample-package/)
From our sample filing package for Example Commons, a fictional 30,000 sq ft office. Not a real submission.

Sources and notes (3)Commerce figures as of October 24, 2026; facts checked October 27, 2026.

- WA Dept. of Commerce, Tier 2 Early Adopter Incentive Program page, figures as of Oct. 24, 2026: nearly $13.6M awarded; over $136M remaining of $150M. commerce.wa.gov Source (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- Base incentive is $0.30 per sq ft of eligible gross floor area (RCW 19.27A.220). Multifamily owners signing an Anti-Displacement Agreement may get up to $0.75/sq ft or the cost of compliance, whichever is lower. Estimates only. Not guaranteed: incentives are paid by participating utilities from available tax credits, first-come, first-served, and may be partial, delayed or zero. Requires full compliance (not an extension) and a participating utility. Source (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.220)
- Commerce program update (Clean Buildings Bulletin), Oct. 22, 2026. Timing varies by utility and starts after Commerce review. Source (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)

IThe practice

We prepare the complete Tier 2 package for a flat fee per building. A partner Qualified Energy Manager reviews, signs and submits it. Your part takes about two hours.

## Included in every package

-
### Benchmarking
Portfolio Manager property and 12+ months of utility data.

-
### Forms B and C
EUIt inputs and measured EUI, for the QEM to confirm.

-
### Equipment inventory
Built from your nameplate photos or a short video.

-
### O&M program and proof
The program, plus PM logs or service records as proof.

-
### Energy Management Plan
On Commerce's template, with the reporting tools.

-
### Incentive enrollment
Early Adopter application, with Exhibit A for multifamily.

-
### Commerce questions
Answered within five business days, at no extra charge.

- See the sample package → (https://cleanbuildingsassociates.com/sample-package/)

IIProcess

## Four steps, in order

-
01
### Coverage check
Send the address and floor area. We confirm Tier 2 coverage and estimate the incentive. No charge.

-
02
### Engagement
Sign our terms and the utility data authorizations. Utility data takes a few days to about four weeks.

-
03
### Preparation
We build every document in the package, from Portfolio Manager to the Energy Management Plan.

-
04
### Signature and submission
Our partner QEM reviews, signs Form A with you and submits, with your incentive enrollment.

Most packages take three to six weeks of our time, mostly waiting on utility data.

IIIWho does what

## You, us, and the partner QEM

### You

- Send the address and floor area
- Sign the engagement and utility data authorizations
- Send nameplate photos or a short video
- Sign Form A with the QEM
- Takes about 2 hours of your time

### We prepare

- Portfolio Manager property and utility data
- Forms B and C drafts
- Energy Management Plan, O&M program and proof
- Incentive enrollment and Commerce responses

### Partner QEM

- Reviews the package independently
- Sets the EUIt and signs Form A
- Submits in the Clean Buildings Portal
- May decline to sign; we never press

How a QEM qualifies under WAC 194-50-030Who signs
Every package is reviewed and signed by a Qualified Energy Manager (QEM) who meets Washington's definition. The QEM must be designated by the building owner and qualify by one of two routes.

### Route A: Commerce training plus experience
Completed Commerce's Clean Buildings Tier 2 training, and at least one of:

- Two years of educational or professional experience with commercial building operations or building energy management
- A full-time energy-efficiency fellowship or internship of six months or more, supervised by a QEM, Qualified Person or qualified energy auditor, that produced a successful compliance application
- Building Operator Certification (BOC) Level I

### Route B: a Qualified Person
Training, expertise and three years of professional experience in building energy use analysis, plus any of:

- Washington-licensed professional architect or engineer
- Building Operator Certification (BOC) Level II
- Building commissioning provider certified by an ANSI/ISO/IEC 17024:2012 accredited organization
- Qualified energy auditor
- Certified Energy Manager (CEM), Association of Energy Engineers, in current standing
- Energy Management Professional (EMP), Energy Management Association
- South Seattle College Sustainable Building Science Technology B.A.S. degree, or an equivalent approved by Commerce

Source, checked October 27, 2026 WAC 194-50-030, definitions of qualified energy manager and qualified person (as amended by WSR 26-15-112, effective Aug. 21, 2026) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-030); consistent with Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g). Commerce does not vet QEMs; owners confirm qualifications. Our partner QEM will be listed by name and credential, with permission, once an agreement is signed.

We never sign, stamp or do engineering, or hold your passwords. You get the partner QEM's name and credential in writing before you engage us. Clean Buildings Associates is a trade name of Voraus LLC, based in Seattle.

Sources, dated (9)Every figure on this site comes from a Commerce page, guidance document or statute, re-checked monthly. Last checked October 27, 2026.

- WA Dept. of Commerce, Tier 2 Early Adopter Incentive Program page (last updated Oct. 26, 2026) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- WA Dept. of Commerce, Tier 2 Incentive Participating Utilities list (Smartsheet, linked from the incentive page) (https://app.smartsheet.com/b/publish?EQBCT=44fd9cf0b7894373aa5887aebc8f4fb6)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
- Commerce guidance CBPS 016, Compliance Forms (updated June 26, 2025) (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)
- Commerce guidance CBPS 028, Tier 2 Compliance through Exemption, published Aug. 4, 2026 (https://deptofcommerce.box.com/s/ktdcc5as0j33waeq1v63lsp2uvlaiazq)
- Commerce guidance CBPS 044, Extension Guidance, published July 17, 2026 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)
- RCW 19.27A.220 (early adoption incentive program) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.220)

IVRequirements

## What Tier 2 asks of an owner

-
### Benchmark
12+ months of energy use in Portfolio Manager, as EUI (Form C) against a target, the EUIt (Form B).

-
### Energy Management Plan
How energy use is managed, tracked and improved.

-
### O&M program and proof
A maintenance program for the equipment, and proof it is carried out.

Federal and tribal-owned buildings are not covered. Is my building Tier 2? (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)

The first Tier 2 report is due July 1, 2027. Not submitting can cost up to $0.30 per square foot.
WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)The base incentive is $0.30 per sq ft, paid by your utility, first-come, first-served.
RCW 19.27A.220 (early adoption incentive program) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.220). Not guaranteed; funds are limited.

Full requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/) · Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/) · Exemptions (https://cleanbuildingsassociates.com/washington/exemptions/)

VIFees

Fees
Quoted per building · reply within one business day

- Flat fee per building
Fixed in writing before work starts. Never a percentage of your incentive.

- QEM review and signature included
A credentialed partner QEM reviews, signs Form A and submits.

- Volume pricing for portfolios
Lower per-building fees for three or more buildings.

- Pay-after-approval option
A small deposit; the balance once Commerce accepts the filing.

- Commerce questions included
Responses within five business days, at no extra charge.

Also available: a bring-your-own-QEM package, exemption or extension applications, and an optional upkeep plan.
Request a quote (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request)Email hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) with the address and floor area. Written quote within one business day.

Scope, exclusions and payment options → (https://cleanbuildingsassociates.com/pricing/)

XCorrespondence

Send the building address and floor area. We reply within one business day with a coverage check and an incentive estimate.

hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com)

Clean Buildings Associates is based in Seattle and operated by Voraus LLC.

---

URL: https://cleanbuildingsassociates.com/washington/
Title: Washington Clean Buildings Tier 2 guides
Last updated: 2026-10-27

Washington

# Clean Buildings Tier 2 guides
Plain-English, dated and sourced. Start with the coverage test.
Last updated October 27, 2026 · Checked against primary sources

Short, sourced guides to Washington's Clean Buildings Performance Standard for Tier 2. Each gives the answer first, dated key facts, and the primary source.

## Start here

- Is my building Tier 2?The coverage test: floor area, use, parking and ownership. (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)
- Tier 2 requirementsWhat must be submitted, on which forms, and who signs. (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Deadlines and penaltiesEvery Tier 2 date, the notice process and the $0.30 per sq ft cap. (https://cleanbuildingsassociates.com/washington/deadlines-penalties/)

## Preparing the filing

- Energy Management PlanThe required elements, in one table. (https://cleanbuildingsassociates.com/washington/energy-management-plan/)
- O&M program and proofInventory, preventive tasks and the proof Commerce accepts. (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/)
- Qualified Energy ManagerWho can sign a Tier 2 filing, and what each signature means. (https://cleanbuildingsassociates.com/washington/qualified-energy-manager/)

## Incentive and alternatives

- Early Adopter IncentiveCalculator, fund status, participating utilities, timing. (https://cleanbuildingsassociates.com/washington/incentive/)
- ExemptionsThe eight categories, Commerce's guidance for each, and the deadline. (https://cleanbuildingsassociates.com/washington/exemptions/)
- ExtensionsThe window, accepted reasons, and what extending costs you. (https://cleanbuildingsassociates.com/washington/extension/)

## By building type and city

- Multifamily and condo/HOAWhich space counts, who signs, and the enhanced incentive. (https://cleanbuildingsassociates.com/washington/multifamily-condo/)
- Seattle: Tier 2, benchmarking and BEPSHow the state filing and the two city programs overlap. (https://cleanbuildingsassociates.com/washington/seattle/)

## Reference

- GlossaryTier 2 terms in one line each, with sources. (https://cleanbuildingsassociates.com/washington/glossary/)
- Readiness checklist (PDF)Everything to gather before a Tier 2 filing starts. (https://cleanbuildingsassociates.com/washington/readiness-checklist/)

## More questions
When would the incentive arrive?After Commerce reviews and certifies your compliance and reserves the incentive, Commerce reported in October 2026 that utility payment timelines range from four to eight weeks. Commerce's own review time is not published. Your utility may ask you for a W-9. (Source: Clean Buildings Bulletin, Oct. 22, 2026.)
Can my property manager or chief engineer be the QEM?Yes, if they meet the CBPS 017 qualifications, including Commerce's free Tier 2 training. If they do, our bring-your-own-QEM package fits: we prepare everything and they review, sign and submit.
Should I file an extension instead?Only if you truly need more time. A two-year extension can be requested between six months before and six months after the deadline (Jan. 1, 2027 to Jan. 1, 2028 for Tier 2), but an extension does not earn the incentive. (Source: Commerce Tier 2 compliance page and CBPS 044.)
How do you compare with other Tier 2 services?Several private companies now offer Washington Tier 2 help. Their published terms, checked Oct. 27, 2026 (prices change, so ask each for a current quote): The lowest published price with a QEM's review and signature included is Tier 2 Desk's $3,900 ($2,400 if you bring your own QEM). Evergreen Compliance drafts the documents only, for $2,250 per building; your own QEM then reviews, signs and submits, and that QEM's fee is extra. Tier Two Partners charges $0.12 per eligible sq ft for one building plus a separate QEM fee. Easy BPS (Pilotlight) charges $5,500. Sheehan Engineering charges $5,750 for virtual service. Vert charges $12,000. WA Energy Managers describes a team of Qualified Energy Managers, publishes no price, and says its fee comes out of your incentive, quoted in writing in advance. Some engineering and mechanical firms quote building by building. We charge one flat fee per building with review and signature by our partner QEM included, with portfolio pricing, a lower fee if you bring your own QEM, and a pay-after-approval option. Ask us for a quote. Whoever you choose, the incentive is paid by your participating utility after Commerce certifies compliance, and it is not guaranteed.
Are you the Clean Buildings Helpdesk?No. The free Clean Buildings Helpdesk is run by the Smart Buildings Center (smartbuildingscenter.org), and some utilities run their own help desks. Clean Buildings Associates is a separate, private, paid service operated by Voraus LLC.
What do I have to do?About 2 hours in total: a short questionnaire, signing utility data authorizations, sending equipment nameplate photos (or a short video walk-round), creating your Clean Buildings Portal account and granting shared access, and signing Form A.
Multifamily: what's the Anti-Displacement Agreement?Multifamily owners who rent to residential tenants and sign Commerce's Anti-Displacement Agreement (Exhibit A) may be eligible for the enhanced incentive of up to $0.75 per sq ft or the estimated cost of compliance, whichever is lower. Read the agreement before signing; it adds tenant-protection commitments.
Are you part of the state?No. Clean Buildings Associates is a private company (Voraus LLC). We are not affiliated with or endorsed by the Washington State Department of Commerce.
Do you visit the building?Usually not. We work from your utility data, documents, nameplate photos and a short video walk-round. If a site visit is needed, we'll quote it first.
What happens after compliance?Tier 2 reporting repeats every five years, and the O&M program and energy management plan must keep being implemented. Our optional upkeep plan handles the annual Portfolio Manager update and reminders.

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- WA Dept. of Commerce, Tier 2 Early Adopter Incentive Program page (last updated Oct. 26, 2026) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/
Title: Is my building Tier 2? Washington Clean Buildings
Last updated: 2026-10-27

Washington · Coverage

# Is my building Tier 2?
Last updated October 27, 2026 · Checked against primary sources

Short answer
Is my building covered by Washington's Tier 2 rules?
Yes, if it is in Washington and has more than 20,000 and up to 50,000 gross sq ft of nonresidential, hotel, motel and dormitory space, or it is a multifamily building over 20,000 gross sq ft. Parking garages don't count. Federal and tribal-owned buildings are not covered. The first report is due July 1, 2027.

Key factsChecked October 27, 2026

- Nonresidential: More than 20,000 and up to 50,000 gross sq ft, excluding parking Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Multifamily: Over 20,000 gross sq ft, no upper limit WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Not covered: Federal buildings and buildings owned by federally recognized tribes Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- First report: July 1, 2027, then every five years WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Floor area: Measured to exterior walls; parking, docks and exterior space excluded CBPS 008 (https://deptofcommerce.box.com/s/6vzfdjvvgunytzq3n3k896jxr5oqd094)

## The four-step test

| Step | Question | If yes |
| 1. Location | Is it in Washington, and not owned by the federal government or a federally recognized tribe? | Go to step 2. Federal and tribal-owned buildings are not covered. |
| 2. Use | Is it multifamily residential: sleeping units, or more than five dwelling units with mainly permanent occupants? | Tier 2 if over 20,000 gross sq ft, with no upper size limit. |
| 3. Size | Is the nonresidential, hotel, motel and dormitory floor area over 20,000 and up to 50,000 gross sq ft, excluding parking? | Tier 2. Over 50,000 is Tier 1, which has different rules. |
| 4. Exemption | Does a listed condition, such as no occupancy or pending demolition, affect more than 50% of the floor area? | You may apply for an Exemptions (https://cleanbuildingsassociates.com/washington/exemptions/) instead, by about January 1, 2027. |

## Measuring gross floor area
Measure to the outside surface of the enclosing walls. From Commerce guidance CBPS 008:

| Count in floor area | Leave out |
| Offices, lobbies, restrooms, break rooms | Parking |
| Mechanical rooms and equipment storage | Outside bays and docks |
| Elevator shafts and stairwells (once per floor) | Covered walkways and breezeways |
| Semi-heated space | Balconies, decks and patios |
| Mezzanines that add usable floor area | Crawl spaces |

## Edge cases

- No letter from Commerce: Coverage depends on the building, not the letter. Commerce says it may not reach every owner and that this does not remove the duty to comply. Check the Tier 2 Data Pool in the Clean Buildings Portal.

- Condominiums: Individually owned units are not counted. Common areas and association-owned space are. See Multifamily and condo/HOA (https://cleanbuildingsassociates.com/washington/multifamily-condo/).

- Separate structures: A space joined to the main building only through unconditioned space is treated as a separate building (CBPS 008).

- Over 50,000 sq ft nonresidential: That is Tier 1, with a performance target to meet. This site covers Tier 2 only.

## If it is Tier 2
Read the Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/) and the Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/), then work through the Readiness checklist (PDF) (https://cleanbuildingsassociates.com/washington/readiness-checklist/).
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
- Commerce guidance CBPS 008, Measuring Gross Floor Area, updated Apr. 9, 2026 (https://deptofcommerce.box.com/s/6vzfdjvvgunytzq3n3k896jxr5oqd094)
- Commerce, Early Adopter Incentive Guidebook: Tier 2 Buildings (V3) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- Commerce guidance CBPS 034, Condominium Guidance, published Dec. 12, 2024 (https://deptofcommerce.box.com/s/s1mjiueonyl868lxmso3otng4b4iq7zx)
Related guides

- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Multifamily and condo/HOA (https://cleanbuildingsassociates.com/washington/multifamily-condo/)
- Exemptions (https://cleanbuildingsassociates.com/washington/exemptions/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/tier-2-requirements/
Title: Washington Clean Buildings Tier 2 requirements
Last updated: 2026-10-27

Washington · Tier 2

# Tier 2 requirements
Last updated October 27, 2026 · Checked against primary sources

Short answer
What does a Tier 2 building have to submit?
By July 1, 2027, the owner submits in Commerce's Clean Buildings Portal: Portfolio Manager benchmarking, an energy use intensity target (Form B), measured EUI (Form C), an Energy Management Plan and an O&M program with proof it is in use, plus both reporting tools. The owner, energy manager and a Qualified Energy Manager sign Form A.

Key factsChecked October 27, 2026

- Deadline: July 1, 2027, then every five years WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Target: Identify the EUIt; meeting it is not required Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Signers: Owner, energy manager and QEM on Form A CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- O&M proof: By the reporting date or at submission Commerce bulletin, Oct. 22, 2026 (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)

- Penalty cap: $0.30 per sq ft of gross floor area RCW 19.27A.250 (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)

## 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 |
| 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
Completed preventive-maintenance logs, CMMS screenshots or a current signed PM service contract, due by the reporting date or at submission, whichever is earlier (Commerce bulletin, Oct. 22, 2026). Details in O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/); see a sample PM log (https://cleanbuildingsassociates.com/sample-package/#pm-log) (fictional building).

## Performance target
Tier 2 buildings must identify an EUIt but do not have to meet it. By statute, Tier 2 performance standards cannot take effect before the end of the 2031 legislative session.

## Penalties
Up to $0.30 per sq ft of gross floor area, after a notice with at least 30 days to comply. See Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/).

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
- Commerce guidance CBPS 016, Compliance Forms (updated June 26, 2025) (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- RCW 19.27A.250 (Tier 2 covered buildings: reporting, penalties) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)
Related guides

- Is my building Tier 2? (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)
- Energy Management Plan (https://cleanbuildingsassociates.com/washington/energy-management-plan/)
- O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/deadlines-penalties/
Title: Tier 2 deadlines and penalties ($0.30/sq ft cap)
Last updated: 2026-10-27

Washington · Dates

# Deadlines and penalties
Last updated October 27, 2026 · Checked against primary sources

Short answer
When is Tier 2 due, and what is the penalty?
Tier 2 reports are due July 1, 2027, then every five years. An owner who misses it receives a notice with at least 30 days to comply. If documentation still isn't submitted, Commerce assesses up to $0.30 per sq ft of gross floor area for that compliance period: up to $9,000 for a 30,000 sq ft building.

Key factsChecked October 27, 2026

- Compliance date: July 1, 2027 WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Cycle: Every five years after that RCW 19.27A.250 (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)

- Maximum penalty: $0.30 per sq ft of gross floor area WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Notice period: At least 30 days to comply after a NOVCI WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Penalty use: Deposited to the low-income weatherization account RCW 19.27A.250 (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)

## Every Tier 2 date

| Date | What happens | Source |
| By January 1, 2027 | Last day to apply for an exemption (applications open two years before the deadline) | CBPS 028; Commerce Tier 2 page |
| January 1, 2027 | Extension window opens | CBPS 044 |
| July 1, 2027 | Compliance report due in the Clean Buildings Portal | WAC 194-50-160 |
| By the reporting date | Proof the O&M program is implemented | Commerce bulletin, Oct. 22, 2026 |
| January 1, 2028 | Extension window closes; an extension adds up to two years | CBPS 044 |
| Every five years | Next report, starting from the 2027 date | RCW 19.27A.250 |
| Not before end of 2031 session | Earliest a Tier 2 performance standard can take effect | RCW 19.27A.250 |

## If the deadline is missed

- Notice. Commerce issues a notice of violation and corrective instruction (NOVCI) with at least 30 days to comply.
- Respond within 30 days. Submit compliance, apply for an exemption or extension if still eligible, pay the penalty, or request a hearing. Missing the response date waives the hearing.
- Comply in time. Fines are waived, and the owner may still apply for the incentive.
- No compliance. The maximum of $0.30 per sq ft is assessed for that compliance period, the incentive may be lost, and interest accrues once the debt is past due.

## What the cap means

| Gross floor area | Maximum penalty | Base incentive if compliant |
| 20,001 sq ft | $6,000 | about $6,000 |
| 30,000 sq ft | $9,000 | about $9,000 |
| 50,000 sq ft | $15,000 | about $15,000 |
| 80,000 sq ft (multifamily) | $24,000 | about $24,000 |

Penalty: WAC 194-50-160 Y5.4. Incentive: base rate of $0.30 per sq ft of eligible floor area (RCW 19.27A.220), paid by a participating utility, not guaranteed. Commerce's Tier 2 Penalties Estimator (CBPS 038) does the same arithmetic.

## Tenants
Penalties cannot be passed on to tenants who provide access to energy data and spaces and respond to the owner's compliance requests. Collected penalties go to the state's low-income weatherization account.
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
- RCW 19.27A.250 (Tier 2 covered buildings: reporting, penalties) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 028, Tier 2 Compliance through Exemption, published Aug. 4, 2026 (https://deptofcommerce.box.com/s/ktdcc5as0j33waeq1v63lsp2uvlaiazq)
- Commerce guidance CBPS 044, Extension Guidance, published July 17, 2026 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- Commerce CBPS 038, Tier 2 Penalties Estimator (Excel), June 27, 2025 (https://deptofcommerce.box.com/s/83ap3xsg08xl2gr4h6oxjiameobsnkys)
Related guides

- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Extensions (https://cleanbuildingsassociates.com/washington/extension/)
- Exemptions (https://cleanbuildingsassociates.com/washington/exemptions/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/energy-management-plan/
Title: Tier 2 Energy Management Plan (EMP) requirements
Last updated: 2026-10-27

Washington · Preparing the filing

# Energy Management Plan
Last updated October 27, 2026 · Checked against primary sources

Short answer
What does a Tier 2 Energy Management Plan need?
A written plan, kept by an energy manager the owner designates and signed by the owner every year, that tracks the building's energy use against its target and sets out how energy is managed. It includes the O&M program and is reported on Commerce's mandatory EMP reporting tool. Commerce's template is optional.

Key factsChecked October 27, 2026

- Standard: CBPS Section 5, explained in CBPS 037 CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Written by: The energy manager the owner designates CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Owner signature: Reviewed and signed annually CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Reporting tool: Mandatory; attached to the application Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Template: CBPS 039, optional CBPS 039 (https://deptofcommerce.box.com/s/4uqrtc93xk5yj7mvz7qhpyhlj0b06e99)

## What the plan must contain
Summarized from CBPS Section 5 and Commerce guidance CBPS 037:

| Element | What it means in practice |
| Energy accounting | Energy use tracked in ENERGY STAR Portfolio Manager. |
| Baseline | EUI and weather-normalized EUI for the initial compliance year. |
| Annual updates | Net energy use, EUI and weather-normalized EUI, each year. |
| Comparison to target | Annual EUI against the EUIt. Tier 2 buildings without a target use Portfolio Manager's national median. |
| Operating changes | Occupancy, weekly hours and schedules: original, current, and their effect on energy use. |
| Audit measures | Recommended energy efficiency measures from any audit, and those implemented. |
| Occupant information | How occupants are told to use windows, thermostats and lighting efficiently. |
| Training plan | Energy-related training for the people who operate and maintain the building. |
| Capital plan | Equipment to replace with efficient, ENERGY STAR equipment where applicable. |
| Contact list | Efficient-equipment suppliers, a qualified energy auditor, the energy manager and the owner. |
| Lighting schedule and survey | Lighting power density, savings potential and a satisfaction survey. Not required after a utility-program lighting upgrade in the last five years. |
| O&M program | Included in the EMP. See O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/). |
| Annual access and signature | Shared with occupants and stakeholders each year; reviewed and signed by the owner each year. |

## Easy to miss

- The owner's dated annual signature inside the plan.
- A record of how the plan was made available to occupants.
- The lighting schedule and survey, when lighting has not been upgraded through a utility program in five years.
- A training plan specific to the building's systems, not a generic statement.

## Templates
Commerce's EMP template (CBPS 039) is optional; an existing plan is fine if it meets the standard. The EMP reporting tool is mandatory and is attached to the compliance application. See a sample EMP page (https://cleanbuildingsassociates.com/sample-package/#energy-management-plan) (fictional building).
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- Commerce guidance CBPS 037, Energy Management Plan and O&M Guidance, published Oct. 1, 2026 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce CBPS 039, Energy Management Plan Template, July 24, 2025 (https://deptofcommerce.box.com/s/4uqrtc93xk5yj7mvz7qhpyhlj0b06e99)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
Related guides

- O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Qualified Energy Manager (https://cleanbuildingsassociates.com/washington/qualified-energy-manager/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/operations-maintenance-program/
Title: Tier 2 O&M program and proof of implementation
Last updated: 2026-10-27

Washington · Preparing the filing

# O&M program and proof
Last updated October 27, 2026 · Checked against primary sources

Short answer
What O&M proof does Tier 2 need?
A written O&M program for the building's energy-using systems: an equipment inventory, preventive tasks and frequencies, and records showing the work is done. Commerce accepts completed PM logs, CMMS screenshots or a current signed PM service contract. Repair invoices alone don't show preventive maintenance. Proof is due by the reporting date.

Key factsChecked October 27, 2026

- Standard: CBPS Section 6 and Annex L, explained in CBPS 037 CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Systems: Envelope, hot water, HVAC, refrigeration, lighting, controls, power CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Reporting tool: Mandatory; attached to the application Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Proof due: By the reporting date or at submission, whichever is earlier Commerce bulletin, Oct. 22, 2026 (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)

- Optional tool: O&M Program Development Tool, CBPS 040 CBPS 040 (https://deptofcommerce.box.com/s/pkoedpqfrmht0to6pndqyailx3w3r740)

## What the program must contain
From CBPS Section 6, Normative Annex L and Commerce guidance CBPS 037:

| Element | Detail |
| Scope | Envelope, domestic hot water, HVAC, refrigeration, lighting, controls, power distribution and on-site generation. |
| Equipment inventory | Every energy-using system, flagging anything past its useful life for the capital plan. |
| Tasks and frequencies | Inspection and maintenance per manufacturer requirements. CBPS Annex D and ASHRAE/ACCA 180 are references. |
| Tracking method | Manual or CMMS: where records live and who can reach them. |
| Records | Written or electronic proof that tasks were done. |
| Access statement | Safe, reasonable access to all covered equipment. |
| Emergency information | Staff and agency notification procedures, readily available. |
| Revision triggers | Renovations, use changes, component changes, systems missing objectives, or a provider's documented recommendation. |
| Tenant improvements | A process so space changes don't raise net energy use beyond what a new use justifies. |

## Proof Commerce accepts

| Accepted as proof | Not enough on its own |
| Completed PM logs: spreadsheets, photos of paper logs, or CMMS screenshots | Invoices for reactive repairs |
| Work orders and invoices for scheduled servicing of energy-intensive equipment | Invoices for upgrades or replacements |
| A current, signed PM service contract listing the equipment and scope | A blank task list with no completion record |

The last row is our reading of the requirement that records verify implementation; the others are listed in CBPS 037.

## Tier 1 vs Tier 2
CBPS 037's one-year implementation history applies to Tier 1 initial filings. For Tier 2, Commerce's October 2026 bulletin asks for proof by the reporting date or at submission, whichever is earlier.

## Tools
The O&M reporting tool is mandatory. Commerce's O&M Program Development Tool (CBPS 040, Excel) is optional. See a sample PM log (https://cleanbuildingsassociates.com/sample-package/#pm-log) (fictional building).
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- Commerce guidance CBPS 037, Energy Management Plan and O&M Guidance, published Oct. 1, 2026 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce CBPS 040, O&M Program Development Tool, Jan. 21, 2026 (https://deptofcommerce.box.com/s/pkoedpqfrmht0to6pndqyailx3w3r740)
Related guides

- Energy Management Plan (https://cleanbuildingsassociates.com/washington/energy-management-plan/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Readiness checklist (PDF) (https://cleanbuildingsassociates.com/washington/readiness-checklist/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/qualified-energy-manager/
Title: Qualified Energy Manager (QEM) for WA Tier 2
Last updated: 2026-10-27

Washington · Who signs

# The Qualified Energy Manager
Who can sign a Tier 2 filing, and what each signature means.
Last updated October 27, 2026 · Checked against primary sources

Short answer
Who can sign a Tier 2 filing as the QEM?
A Qualified Energy Manager designated by the owner who has completed Commerce's free Tier 2 training plus two years of building-operations or energy-management experience (or a supervised fellowship, or BOC Level I), or who is a Qualified Person. The QEM sets the EUIt, calculates the EUI, submits, and signs Form A.

Key factsChecked October 27, 2026

- Required: A QEM is required for Tier 2 compliance Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Definition: WAC 194-50-030, as amended Aug. 21, 2026 WAC 194-50-030 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-030)

- Signs: Form A, with the owner and energy manager CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- Vetting: Commerce does not vet QEMs; owners confirm qualifications CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- Representatives: Shared access lets a representative work in the portal CBPS 016 (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)

## Signatures on Form A

- Building owner: Ultimately responsible; reviews, approves and signs.

- Energy manager: Develops and maintains the EMP; signs Form A. Can be the owner, an employee, a tenant or a contractor.

- Qualified Energy Manager: States in writing on Form A that the EMP and O&M program have been developed, implemented and maintained; signs Form A.

## Who qualifies as a QEM
Who signs
Every package is reviewed and signed by a Qualified Energy Manager (QEM) who meets Washington's definition. The QEM must be designated by the building owner and qualify by one of two routes.

### Route A: Commerce training plus experience
Completed Commerce's Clean Buildings Tier 2 training, and at least one of:

- Two years of educational or professional experience with commercial building operations or building energy management
- A full-time energy-efficiency fellowship or internship of six months or more, supervised by a QEM, Qualified Person or qualified energy auditor, that produced a successful compliance application
- Building Operator Certification (BOC) Level I

### Route B: a Qualified Person
Training, expertise and three years of professional experience in building energy use analysis, plus any of:

- Washington-licensed professional architect or engineer
- Building Operator Certification (BOC) Level II
- Building commissioning provider certified by an ANSI/ISO/IEC 17024:2012 accredited organization
- Qualified energy auditor
- Certified Energy Manager (CEM), Association of Energy Engineers, in current standing
- Energy Management Professional (EMP), Energy Management Association
- South Seattle College Sustainable Building Science Technology B.A.S. degree, or an equivalent approved by Commerce

Source, checked October 27, 2026 WAC 194-50-030, definitions of qualified energy manager and qualified person (as amended by WSR 26-15-112, effective Aug. 21, 2026) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-030); consistent with Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g). Commerce does not vet QEMs; owners confirm qualifications. Our partner QEM will be listed by name and credential, with permission, once an agreement is signed.

## Who can act for the owner in the portal?
Commerce can grant “shared access,” which lets an authorized representative view, update or submit an application on the owner's behalf (CBPS 016). Exemption and extension applications can be filed by the owner or an authorized representative (Commerce Tier 2 page; CBPS 044). Clean Buildings Associates never uses owner credentials and never signs Form A.

## Our model
We prepare roughly 80% of the work. A partner QEM independently reviews it, signs and submits. Or bring your own QEM, at a lower flat fee. You receive the partner QEM's name and credential in writing before you engage us.

Find a QEM yourself: Commerce links a free QEM training and directory through the Smart Buildings Center.

Resources

- WAC 194-50-030, definitions of qualified energy manager and qualified person (as amended by WSR 26-15-112, effective Aug. 21, 2026) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-030)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
- Commerce guidance CBPS 016, Compliance Forms (updated June 26, 2025) (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 044, Extension Guidance, published July 17, 2026 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)
Related guides

- Energy Management Plan (https://cleanbuildingsassociates.com/washington/energy-management-plan/)
- O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/incentive/
Title: Tier 2 Early Adopter Incentive calculator ($0.30/sq ft)
Last updated: 2026-10-27

Washington · Incentive

# The Tier 2 Early Adopter Incentive
Last updated October 27, 2026 · Checked against primary sources

Short answer
How much is the Tier 2 incentive?
A base $0.30 per sq ft of eligible floor area, about $9,000 for 30,000 sq ft. Multifamily owners renting to residential tenants who sign an Anti-Displacement Agreement can get up to $0.75 per sq ft or the cost of compliance, whichever is lower. Participating utilities pay it after Commerce certifies full compliance. Not guaranteed.

Key factsChecked October 27, 2026

- Base rate: $0.30 per sq ft; excludes parking, unconditioned and semi-heated space RCW 19.27A.220 (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.220)

- Enhanced (multifamily): Up to $0.75 per sq ft or cost of compliance, whichever is lower Commerce incentive page (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)

- Fund: $150 million; over $136 million left as of October 24, 2026 Commerce incentive page (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)

- Utilities: 24 participating; those over 25,000 customers must Commerce utilities list (https://app.smartsheet.com/b/publish?EQBCT=44fd9cf0b7894373aa5887aebc8f4fb6)

- Payment timing: Four to eight weeks after Commerce reserves it Commerce bulletin, Oct. 22, 2026 (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)

## Fund status
As of October 24, 2026, Commerce reports nearly $13.6 million awarded to Tier 2 owners whose buildings were certified compliant, over $6.7 million paid by utilities, and over $136 million left of the $150 million program. Funding is first-come, first-served. (Commerce incentive page, last updated Oct. 26, 2026; checked October 27, 2026.)

## How payment works

- Calculation: Commerce calculates the incentive by utility and fuel type and notifies the utilities and the Department of Revenue.

- Several utilities: Split by each participating utility's share of energy use. If one serving utility doesn't participate, Commerce can have the participating one pay the whole incentive.

- Funding: Utilities pay from public utility tax credits, so payments may be reduced or delayed to match a utility's ability to pay.

- Timing: Four to eight weeks after Commerce reserves the incentive (Commerce bulletin, Oct. 22, 2026).

- Paperwork: Your utility may require a W-9.

## Participating utilities (24)

- Avista
- Benton County PUD
- Cascade Natural Gas
- Chelan County PUD
- City of Ellensburg
- Clallam County PUD
- Clark Public Utilities
- Cowlitz PUD
- Franklin County PUD
- Grant County PUD No. 2
- Grays Harbor County PUD No. 1
- Inland Power & Light
- Jefferson County PUD No. 1
- Lewis County PUD No. 1
- Mason County PUD No. 3
- NW Natural
- Orcas Power & Light Cooperative
- Pacific Power
- Peninsula Light Co.
- Puget Sound Energy
- Richland Energy Services
- Seattle City Light
- Snohomish County PUD No. 1
- Tacoma Power

## Questions
How much is the incentive, and is it certain?No, it is not guaranteed. The base incentive is $0.30 per sq ft of eligible gross floor area; multifamily owners who sign an Anti-Displacement Agreement may get up to $0.75 per sq ft or the cost of compliance, whichever is lower. Your utility pays it, not us, from its available public utility tax credits, so payments may be partial, delayed or zero. (Source: Commerce incentive page, checked Oct. 26, 2026.)
When would the incentive arrive?After Commerce reviews and certifies your compliance and reserves the incentive, Commerce reported in October 2026 that utility payment timelines range from four to eight weeks. Commerce's own review time is not published. Your utility may ask you for a W-9. (Source: Clean Buildings Bulletin, Oct. 22, 2026.)
Multifamily: what's the Anti-Displacement Agreement?Multifamily owners who rent to residential tenants and sign Commerce's Anti-Displacement Agreement (Exhibit A) may be eligible for the enhanced incentive of up to $0.75 per sq ft or the estimated cost of compliance, whichever is lower. Read the agreement before signing; it adds tenant-protection commitments.
Which utilities participate?Commerce lists 24 participating utilities, including Seattle City Light, Puget Sound Energy, Tacoma Power, Avista, Snohomish County PUD and Clark Public Utilities. Utilities with more than 25,000 customers must participate. (Commerce participating utilities list, checked October 27, 2026.)
Does an extension or exemption earn the incentive?No. The incentive requires full compliance.

Resources

- WA Dept. of Commerce, Tier 2 Early Adopter Incentive Program page (last updated Oct. 26, 2026) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- WA Dept. of Commerce, Tier 2 Incentive Participating Utilities list (Smartsheet, linked from the incentive page) (https://app.smartsheet.com/b/publish?EQBCT=44fd9cf0b7894373aa5887aebc8f4fb6)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- RCW 19.27A.220 (early adoption incentive program) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.220)
- RCW 19.27A.240 (incentive payment administration) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.240)
Related guides

- Multifamily and condo/HOA (https://cleanbuildingsassociates.com/washington/multifamily-condo/)
- Extensions (https://cleanbuildingsassociates.com/washington/extension/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/exemptions/
Title: Washington Tier 2 exemptions: categories, deadline
Last updated: 2026-10-27

Washington · Tier 2

# Exemptions
Last updated October 27, 2026 · Checked against primary sources

Short answer
Can my Tier 2 building be exempt?
Yes, if one or more listed conditions, such as no occupancy, pending demolition or financial hardship, affect more than 50% of its floor area. Apply in the Clean Buildings Portal by about January 1, 2027, six months before the deadline. No QEM is needed. An exemption lasts one cycle and does not earn the incentive.

Key factsChecked October 27, 2026

- Deadline: About January 1, 2027 Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Opens: Up to two years before the compliance date Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Threshold: Conditions affecting more than 50% of floor area CBPS 028 (https://deptofcommerce.box.com/s/ktdcc5as0j33waeq1v63lsp2uvlaiazq)

- QEM: Not required to apply Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Validity: Current compliance cycle only Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

## Categories

| Category | Commerce guidance |
| No certificate of occupancy | CBPS 021-A (https://deptofcommerce.box.com/s/sa5nih1ttkm3mzuwnhrqxkefzgqsgacb) |
| No physical occupancy | CBPS 021-B (https://deptofcommerce.box.com/s/1cjcc800ecij3zgm86zek77q6aulesfc) |
| Unconditioned and semi-heated space | CBPS 021-C (https://deptofcommerce.box.com/s/88wlr155egx1dt7g946yj39oiraa7iz4) |
| Manufacturing or industrial (IBC Group F or H) | CBPS 021-D (https://deptofcommerce.box.com/s/5cc1l5vo52qc9cificwxxllgkqjavfdl) |
| Agricultural structure | CBPS 021-E (https://deptofcommerce.box.com/s/y46ol86e9urm0pgv7offoihzx4ceitac) |
| Pending demolition | CBPS 021-F (https://deptofcommerce.box.com/s/r6w8kb50w9axhmfl5kbkyoop0794xcqr) |
| Financial hardship | CBPS 021-G (https://deptofcommerce.box.com/s/ymxgycz5usi4gk67rcn5a4b2ahqhoy83) and the CBPS 009 reporting tool |
| National security | Annex Y6.7(4) of the standard |

## Rules

- Threshold: One or more categories together affecting more than 50% of the floor area.

- Scope: Building by building. Not by portfolio.

- Who files: The owner or an authorized representative. No QEM needed.

- Validity: The current five-year cycle only.

- Incentive: None. An exemption does not earn the incentive.

Date note: Commerce's Tier 2 page says “no later than six months before” the compliance date; CBPS 028 says “no later than 180 days prior” (January 2, 2027). We treat January 1, 2027 as the safe deadline.
We also prepare exemption applications for a flat fee. Request a quote (https://cleanbuildingsassociates.com/pricing/).

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 028, Tier 2 Compliance through Exemption, published Aug. 4, 2026 (https://deptofcommerce.box.com/s/ktdcc5as0j33waeq1v63lsp2uvlaiazq)
Related guides

- Extensions (https://cleanbuildingsassociates.com/washington/extension/)
- Is my building Tier 2? (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)
- Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/extension/
Title: Washington Tier 2 extension: window and reasons
Last updated: 2026-10-27

Washington · Tier 2

# Extensions
Last updated October 27, 2026 · Checked against primary sources

Short answer
Can I get more time to file Tier 2?
Yes. Owners can request a two-year extension in the Clean Buildings Portal between six months before and six months after the July 1, 2027 deadline (January 1, 2027 to January 1, 2028). It needs one accepted reason, supporting documentation and the extension reporting tool. An extension does not earn the incentive.

Key factsChecked October 27, 2026

- Window: January 1, 2027 to January 1, 2028 CBPS 044 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)

- Length: Two years WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Needs: Documented reason and the extension reporting tool Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Incentive: Not earned by an extension Commerce incentive page (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)

- Afterward: Submit compliance or an exemption CBPS 044 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)

## Accepted reasons (at least one)

- Circumstances beyond your control that substantially interfere with compliance
- Recent change of ownership
- Financial restrictions
- New construction, additions or major remodels
- Benchmarking is complete, but more time is needed for the EMP and O&M program

## Timeline

| Date | Step |
| January 1, 2027 | Earliest date to apply |
| July 1, 2027 | Compliance deadline |
| January 1, 2028 | Last date to apply |
| Up to two years later | Extended compliance date; then file compliance or an exemption |

## Extension or full compliance?

| | File an extension | Comply now |
| Incentive | None | Base $0.30 per sq ft if a participating utility serves the building (not guaranteed) |
| Paperwork | Extension reporting tool plus documentation of the reason | Full package: benchmarking, EUIt, EMP, O&M, Form A |
| Afterward | The full filing is still due at the end of the extension | Next report in five years |

A 30,000 sq ft building could forgo about $9,000 by extending. We prepare either one for a flat fee; request a quote (https://cleanbuildingsassociates.com/pricing/).

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 044, Extension Guidance, published July 17, 2026 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
Related guides

- Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/)
- Exemptions (https://cleanbuildingsassociates.com/washington/exemptions/)
- Early Adopter Incentive (https://cleanbuildingsassociates.com/washington/incentive/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/multifamily-condo/
Title: Multifamily and condo/HOA Tier 2 rules (WA)
Last updated: 2026-10-27

Washington · Building types

# Multifamily and condo/HOA
Last updated October 27, 2026 · Checked against primary sources

Short answer
Do apartment and condo buildings fall under Tier 2?
Apartment buildings over 20,000 gross sq ft are Tier 2, with no upper size limit. In a condominium, individually owned units are not counted: the owners' association is the owner, and its common areas and association-owned space are covered above 20,000 sq ft. Rental owners can seek a higher incentive by signing an Anti-Displacement Agreement.

Key factsChecked October 27, 2026

- Threshold: Over 20,000 gross sq ft, no upper limit WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- Multifamily means: Sleeping units, or more than five dwelling units, mainly permanent occupants CBPS 034 (https://deptofcommerce.box.com/s/s1mjiueonyl868lxmso3otng4b4iq7zx)

- Condo owner: The owners' association CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- Enhanced incentive: Up to $0.75 per sq ft or cost of compliance, whichever is lower Commerce incentive page (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)

- Condo penalty base: Common space only CBPS 034 (https://deptofcommerce.box.com/s/s1mjiueonyl868lxmso3otng4b4iq7zx)

## Which space counts

| Building | What counts toward Tier 2 | Result |
| Rental apartments, one owner | All floor area except parking | Tier 2 above 20,000 sq ft, any size |
| Condominium, units individually owned | Common areas only: lobbies, corridors, mechanical rooms, shafts, association amenities and storage inside the envelope | Tier 2 if common space exceeds 20,000 sq ft |
| Condominium with association-owned commercial space | Common areas plus the connected association-owned commercial space | Tier 2 at 20,000 to 50,000 sq ft |
| Commercial space in a condo building | The contiguous commercial space | Tier 2 at 20,000 to 50,000; Tier 1 above 50,000 |
| One owner of more than five connected units | Those units, if over 20,000 sq ft | Meets the multifamily definition: Tier 2 |

Unconditioned common space still counts for coverage but may support an exemption (CBPS 034).

## Who signs and applies

- Condominium: The owners' association is the building owner and signs.

- Several owners: One designated user prepares the application; every owner signs, so each needs a SAW login and a portal account.

- Management company: Can prepare and submit once an owner grants it shared access in the portal.

## The enhanced incentive

| | Base incentive | Enhanced incentive |
| Rate | $0.30 per eligible sq ft | Up to $0.75 per eligible sq ft, or the cost of compliance if lower |
| Who | Any compliant owner with a participating utility | Owners renting to residential tenants |
| Extra step | None | Sign the Anti-Displacement Agreement (Exhibit A) and attach a rent schedule |

The agreement commits that compliance will not be used to justify rent increases. The rent schedule lists each unit's rate with no tenant names, and states whether the rates apply to existing tenants only or to new tenants too. For condominiums, the incentive is based on the common and commercial space.

## Practical notes

- Utilities must provide energy data to owners on request, including for tenant-occupied buildings.
- Penalties cannot be passed on to tenants who cooperate with data and access requests.
- In Seattle, the same building usually also reports to the City. See Seattle: Tier 2, benchmarking and BEPS (https://cleanbuildingsassociates.com/washington/seattle/).
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- Commerce guidance CBPS 034, Condominium Guidance, published Dec. 12, 2024 (https://deptofcommerce.box.com/s/s1mjiueonyl868lxmso3otng4b4iq7zx)
- Commerce, Early Adopter Incentive Guidebook: Tier 2 Buildings (V3) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- WA Dept. of Commerce, Tier 2 Early Adopter Incentive Program page (last updated Oct. 26, 2026) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- RCW 19.27A.250 (Tier 2 covered buildings: reporting, penalties) (https://app.leg.wa.gov/RCW/default.aspx?cite=19.27A.250)
Related guides

- Is my building Tier 2? (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)
- Early Adopter Incentive (https://cleanbuildingsassociates.com/washington/incentive/)
- Seattle: Tier 2, benchmarking and BEPS (https://cleanbuildingsassociates.com/washington/seattle/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/seattle/
Title: Seattle buildings: Tier 2, benchmarking and BEPS
Last updated: 2026-10-27

Washington · Seattle

# Seattle: Tier 2, benchmarking and BEPS
Last updated October 27, 2026 · Checked against primary sources

Short answer
Does a Seattle building have to do Tier 2 and the city programs?
Usually, yes. Seattle nonresidential and multifamily buildings over 20,000 sq ft report energy benchmarking to the City every June 1 and face BEPS emissions requirements starting 2027 to 2030. Washington's Tier 2 report, due July 1, 2027, is separate. One accurate Portfolio Manager property feeds all three.

Key factsChecked October 27, 2026

- City benchmarking: Over 20,000 sq ft; report each year by June 1 seattle.gov benchmarking (https://www.seattle.gov/environment/climate-change/buildings-and-energy/energy-benchmarking)

- City portal: Portfolio Manager still required; submit in the new City portal seattle.gov portal (https://www.seattle.gov/building-and-energy-portal)

- BEPS first step: Verified benchmarking and a GHG report by a Qualified Person, 2027 to 2030 seattle.gov BEPS (https://www.seattle.gov/environment/climate-change/buildings-and-energy/building-emissions-performance-standard)

- BEPS targets: Initial 2031 to 2035; net zero 2041 to 2050 seattle.gov BEPS (https://www.seattle.gov/environment/climate-change/buildings-and-energy/building-emissions-performance-standard)

- State Tier 2: July 1, 2027, to Commerce Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

## Three programs side by side

| | Washington Tier 2 | Seattle benchmarking | Seattle BEPS |
| Run by | WA Dept. of Commerce | City of Seattle | City of Seattle |
| Covers | Nonresidential 20,001 to 50,000 sq ft; multifamily over 20,000 | Nonresidential and multifamily over 20,000 sq ft | Nonresidential and multifamily over 20,000 sq ft |
| Requires | Benchmarking, EUIt, Energy Management Plan, O&M program | Annual Portfolio Manager report | Verified benchmarking and a greenhouse-gas report, then emissions targets |
| When | July 1, 2027, then every five years | Every June 1, for the prior year | First steps 2027 to 2030 by size; targets 2031 to 2035; net zero 2041 to 2050 |
| Filed in | Clean Buildings Portal | Seattle Building & Energy Portal | City of Seattle |
| Professional | Qualified Energy Manager | Owner or a provider the owner adds | Qualified Person |

## Where the work overlaps

| Work item | Tier 2 | Benchmarking | BEPS |
| Portfolio Manager property and 12 months of data | Yes | Yes | Yes |
| Floor area and use types | Yes | Yes | Yes |
| Energy Management Plan and O&M program | Yes | No | No |
| Greenhouse-gas report and targets | No | No | Yes |

## A sensible order

- Check the building's City status and fix the Portfolio Manager property first; every program reads from it.
- Claim the building in the Seattle Building & Energy Portal and add your providers as members. The City says providers cannot claim a building for you.
- Use the same corrected property for Tier 2 Form C and the EUIt inputs.
- Look up the building's BEPS dates on the Seattle Benchmarking Map. The smallest buildings have until 2030 for the first step.
The City offers free BEPS coaching through the Seattle Building Emissions Navigator and warns owners about misleading third-party solicitations. Clean Buildings Associates is a private firm, not affiliated with the City of Seattle or Commerce, and does not prepare BEPS greenhouse-gas reports.
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- City of Seattle, Energy Benchmarking (SMC 22.920) (https://www.seattle.gov/environment/climate-change/buildings-and-energy/energy-benchmarking)
- City of Seattle, Building Emissions Performance Standard (BEPS) (https://www.seattle.gov/environment/climate-change/buildings-and-energy/building-emissions-performance-standard)
- City of Seattle, Seattle Building & Energy Portal (https://www.seattle.gov/building-and-energy-portal)
- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
Related guides

- Multifamily and condo/HOA (https://cleanbuildingsassociates.com/washington/multifamily-condo/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Deadlines and penalties (https://cleanbuildingsassociates.com/washington/deadlines-penalties/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/glossary/
Title: Washington Clean Buildings Tier 2 glossary
Last updated: 2026-10-27

Washington · Reference

# Glossary
Last updated October 27, 2026 · Checked against primary sources

Terms used in Washington Clean Buildings Tier 2 filings, one line each.

- Authorized representative: A person or firm the owner allows to act in the Clean Buildings Portal, usually through shared access. CBPS 016 (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)

- BEPS: Seattle's Building Emissions Performance Standard: greenhouse-gas targets for Seattle nonresidential and multifamily buildings over 20,000 sq ft. A city law, separate from the state standard. seattle.gov BEPS (https://www.seattle.gov/environment/climate-change/buildings-and-energy/building-emissions-performance-standard)

- Benchmarking: Tracking a building's whole-building energy use over time in ENERGY STAR Portfolio Manager and comparing it with its own history and its target. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Building owner: The entity holding title to the building. For a condominium, the owners' association. CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- CBPS: Clean Buildings Performance Standard: Washington's building energy standard (WAC 194-50), administered by the Department of Commerce. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Clean Buildings Portal: Commerce's online system for compliance, exemption, extension and incentive applications. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- CMMS: Computerized maintenance management system. Screenshots of completed tasks are accepted as O&M proof. CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Energy Management Plan (EMP): The building's written plan for tracking and managing energy use. It includes the O&M program and is signed by the owner annually. CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Energy manager: The person the owner designates to develop and maintain the EMP. Can be the owner, staff, a tenant or a contractor. Signs Form A. CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- ENERGY STAR Portfolio Manager (ESPM): The U.S. EPA's free benchmarking tool, required for Tier 2 and for Seattle benchmarking. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- EUI: Energy use intensity: annual site energy use divided by gross floor area, in kBtu per sq ft. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- EUIt: Energy use intensity target, set on Form B by the QEM from activity type, floor area and operating hours. Tier 2 must identify it, not meet it. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- Exemption: Relief for one compliance cycle when listed conditions affect more than 50% of floor area. Due six months before the deadline. CBPS 028 (https://deptofcommerce.box.com/s/ktdcc5as0j33waeq1v63lsp2uvlaiazq)

- Extension: A two-year delay, requested from six months before to six months after the deadline. It does not earn the incentive. CBPS 044 (https://deptofcommerce.box.com/s/e8zop6ygzg43eg5ofkjyzquoxc972aps)

- Form A: The compliance signature form, signed by the owner, the energy manager and the QEM. CBPS 017 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)

- Form B: The form that records the energy use intensity target (EUIt) inputs. CBPS 016 (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)

- Form C: The form that reports measured energy use and EUI from Portfolio Manager. CBPS 016 (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)

- Gross floor area (GFA): Square feet measured to the outside of the enclosing walls, including lobbies, mechanical rooms and shafts; excluding parking, docks and exterior space. CBPS 008 (https://deptofcommerce.box.com/s/6vzfdjvvgunytzq3n3k896jxr5oqd094)

- NOVCI: Notice of violation and corrective instruction. Gives at least 30 days to comply before a penalty is assessed. WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

- O&M program: The operations and maintenance program for energy-using equipment: inventory, preventive tasks, tracking and records. CBPS 037 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)

- Qualified Energy Manager (QEM): The person who must review, set the EUIt and sign a Tier 2 filing, qualified by Commerce training plus experience, or as a Qualified Person. WAC 194-50-030 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-030)

- Shared access: A portal permission that lets a representative view, update or submit for the owner without the owner's credentials. CBPS 016 (https://deptofcommerce.box.com/s/mjd6vcnngcm44zf3pziqvfptngrhyfsj)

- Tier 2 covered building: A Washington building with more than 20,000 and up to 50,000 gross sq ft of nonresidential, hotel, motel and dormitory space, or multifamily over 20,000 sq ft, excluding parking. Commerce Tier 2 page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)

- WNEUI: Weather-normalized EUI: EUI adjusted for the weather of the reporting year. WAC 194-50-160 (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
- Commerce guidance CBPS 037, Energy Management Plan and O&M Guidance, published Oct. 1, 2026 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)
- WAC 194-50-160, Tier 2 standard (Normative Annex Y: compliance, NOVCI, penalties) (https://app.leg.wa.gov/wac/default.aspx?cite=194-50-160)
- City of Seattle, Building Emissions Performance Standard (BEPS) (https://www.seattle.gov/environment/climate-change/buildings-and-energy/building-emissions-performance-standard)
Related guides

- Is my building Tier 2? (https://cleanbuildingsassociates.com/washington/is-my-building-tier-2/)
- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- Readiness checklist (PDF) (https://cleanbuildingsassociates.com/washington/readiness-checklist/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/washington/readiness-checklist/
Title: Tier 2 readiness checklist (PDF download)
Last updated: 2026-10-27

Washington · Reference

# Tier 2 readiness checklist
Last updated October 27, 2026 · Checked against primary sources

Download the checklist (PDF, 1 page) (https://cleanbuildingsassociates.com/downloads/tier-2-readiness-checklist.pdf)
17 items to have ready before a Tier 2 filing starts. Utility data is usually the slowest, so request it first.

## Building facts

- WA Building ID and the owner of record Commerce's notice letter or the Tier 2 Data Pool in the Clean Buildings Portal.
- Gross floor area, excluding parking Measured to CBPS 008; sets Tier 2 coverage and the incentive amount.
- Primary use and weekly operating hours The QEM needs these for the energy use intensity target (Form B).
- Every electric and gas utility, with account numbers Each one must supply 12 months of data; tenants may need to authorize.

## Access and people

- Clean Buildings Portal account for the owner (SAW login) Every owner signs; one designated user prepares the application.
- Shared access granted to whoever prepares the filing Lets a representative work without your password.
- A named energy manager Develops and maintains the EMP and signs Form A. Can be staff or a contractor.
- A Qualified Energy Manager (QEM) Required for Tier 2; reviews, sets the EUIt and signs Form A.

## Energy data

- ENERGY STAR Portfolio Manager property Create it or locate the existing one; note the Property ID.
- 12+ months of whole-building energy use Request it from each utility now; this is usually the slowest step.

## Operations and maintenance

- Inventory of energy-using equipment HVAC, water heating, lighting, controls, refrigeration, envelope; nameplate photos work.
- Preventive-maintenance task list and frequencies Per manufacturer guidance; the O&M Program Development Tool is optional.
- Proof the PM is happening Completed PM logs, CMMS screenshots or a current signed PM service contract. Repair invoices alone do not count.

## Plan and incentive

- Energy Management Plan, signed by the owner Commerce template optional; attach the EMP reporting tool.
- O&M reporting tool completed Mandatory attachment to the compliance application.
- W-9 ready for each participating utility Utilities pay the incentive and most ask for one.
- Multifamily rentals: Exhibit A and a rent schedule Only for the enhanced incentive; no tenant names or personal data.
Want it done for you? Send the address and floor area to hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) for a free coverage check and incentive estimate.

Resources

- WA Dept. of Commerce, CBPS Tier 2 compliance page (https://www.commerce.wa.gov/cbps/tier-2-compliance/)
- Commerce guidance CBPS 017, Roles and Responsibilities, v3.0, published July 30, 2026 (https://deptofcommerce.box.com/s/xnzylg43oqlfd2djmtgfohpyw6h6tf0g)
- Commerce guidance CBPS 037, Energy Management Plan and O&M Guidance, published Oct. 1, 2026 (https://deptofcommerce.box.com/s/bd6l272i0o9hbyf9ps4jaw8j3u9m8212)
- WA Dept. of Commerce, Clean Buildings Bulletin, Oct. 22, 2026 (reposted by BOMA Greater Seattle) (https://www.bomaseattle.org/news/737456/Clean-Buildings-Update-OM-Requirements-for-Tier-1--Tier-2-Buildings.htm)
- Commerce, Early Adopter Incentive Guidebook: Tier 2 Buildings (V3) (https://www.commerce.wa.gov/cbps/cbps-grants-incentives/cbps-tier2-early-adopter-incentive/)
Related guides

- Tier 2 requirements (https://cleanbuildingsassociates.com/washington/tier-2-requirements/)
- O&M program and proof (https://cleanbuildingsassociates.com/washington/operations-maintenance-program/)
- Energy Management Plan (https://cleanbuildingsassociates.com/washington/energy-management-plan/)
Need it done?
One flat fee per building, QEM signature included.
Request a quote → (https://cleanbuildingsassociates.com/pricing/)

---

URL: https://cleanbuildingsassociates.com/pricing/
Title: Fees: flat fee per Tier 2 building, quoted on request
Last updated: 2026-10-27

Fees

# Fees
One flat fee per building, quoted in writing before you engage us. No percentage of your incentive.

Fees
Quoted per building · reply within one business day

- Flat fee per building
One fixed price per building, agreed in writing before any work starts. Never a percentage of your incentive.

- QEM review and signature included
A credentialed partner Qualified Energy Manager independently reviews, signs Form A and submits.

- Volume pricing for portfolios
Lower per-building fees for three or more buildings with the same owner or property manager.

- Pay-after-approval option
Start with a small deposit; the balance is due once Commerce accepts the filing.

- Responses to Commerce questions included
If Commerce asks questions or sends a deficiency notice, we prepare the responses within five business days at no extra charge.

Also available: a bring-your-own-QEM package, exemption or extension applications, and an optional upkeep plan.
Request a quote (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request)Email hello@cleanbuildingsassociates.com (mailto:hello@cleanbuildingsassociates.com?subject=Quote%20request) with the building address and floor area. We reply within one business day with a written quote, a coverage check and an incentive estimate.

## Not included

- Engineering, stamps, energy audits or equipment work.
- Commerce or utility fees (none are currently charged for Tier 2 filing).
- Site visits (rarely needed; quoted first if they are).

## Referral credits
If a non-signing referrer, such as a property manager, earns a referral credit for your building, we disclose it to you in writing before you sign.

## Incentive
Incentives are paid by your utility, not by us, and are not guaranteed. A 30,000 sq ft building at the base rate of $0.30 per sq ft could earn about $9,000. Estimate yours (https://cleanbuildingsassociates.com/washington/incentive/).

See the refund policy (https://cleanbuildingsassociates.com/refund/) and terms (https://cleanbuildingsassociates.com/terms/).

---

URL: https://cleanbuildingsassociates.com/sample-package/
Title: Sample Tier 2 filing package (fictional building)
Last updated: 2026-10-27

Work product

# The sample filing package
A complete Tier 2 package for Example Commons, a fictional 30,000 sq ft Seattle office. Every name, address, account number and reading is invented. It shows the standard of work you would receive.

In brief
This is a demonstration, not a compliance submission. In a real engagement the Qualified Energy Manager confirms the EUIt and EUI, and the owner, energy manager and QEM sign Commerce's current Form A in the Clean Buildings Portal. Commerce's own free templates are at commerce.wa.gov/cbps.

(https://cleanbuildingsassociates.com/samples/building-profile.webp)01Building profile · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/form-b-euit.webp)02Form B: EUIt draft inputs · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/form-c-eui.webp)03Form C: measured EUI draft · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/energy-management-plan.webp)05Energy Management Plan · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/om-program.webp)06O&M program · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/pm-log.webp)07O&M proof: preventive-maintenance log · fictional building, not a real submission (https://cleanbuildingsassociates.com/samples/incentive-enrollment.webp)09Incentive enrollment summary · fictional building, not a real submission

Contents of a package

- 01Building profile
- 02Form B: EUIt draft inputs
- 03Form C: measured EUI draft, with 12 months of energy data
- 04Equipment inventory
- 05Energy Management Plan
- 06Operations and maintenance program
- 07O&M proof of implementation: PM log, CMMS index, service contract
- 08Form A placeholder (signed by the owner, energy manager and QEM; never by us)
- 09Incentive enrollment summary
Prepared to
Commerce CBPS guidance and templates, checked October 27, 2026.
Your time
About two hours: a questionnaire, utility authorizations, nameplate photos, portal shared access, and your Form A signature.

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## Frequently asked questions

### Is my building Tier 2?
Probably, if it is in Washington and its nonresidential, hotel, motel and dormitory floor area is more than 20,000 and no more than 50,000 gross sq ft (excluding parking garage), or it is a multifamily building over 20,000 gross sq ft. Federal and tribal-owned buildings are not covered. Commerce mailed notification letters to owners. (Source: Commerce Tier 2 compliance page, checked Oct. 26, 2026.)

### What's the deadline and the penalty?
Tier 2 compliance must be submitted by July 1, 2027, then every five years. Commerce may assess penalties for failing to submit, capped at $0.30 per sq ft. (Source: Commerce Tier 2 compliance page, checked Oct. 26, 2026.)

### How much is the incentive, and is it certain?
No, it is not guaranteed. The base incentive is $0.30 per sq ft of eligible gross floor area; multifamily owners who sign an Anti-Displacement Agreement may get up to $0.75 per sq ft or the cost of compliance, whichever is lower. Your utility pays it, not us, from its available public utility tax credits, so payments may be partial, delayed or zero. (Source: Commerce incentive page, checked Oct. 26, 2026.)

### When would the incentive arrive?
After Commerce reviews and certifies your compliance and reserves the incentive, Commerce reported in October 2026 that utility payment timelines range from four to eight weeks. Commerce's own review time is not published. Your utility may ask you for a W-9. (Source: Clean Buildings Bulletin, Oct. 22, 2026.)

### Who has to sign? What's a QEM?
Tier 2 compliance requires a Qualified Energy Manager (QEM). Per Commerce guidance CBPS 017 (v3.0, July 30, 2026), a QEM has completed Commerce's free Tier 2 training and has two years of building-operations or energy-management experience (or a supervised fellowship, or BOC Level I), or is a Qualified Person. Form A is signed by the building owner, the energy manager and the QEM. Clean Buildings Associates never signs; our partner QEM does.

### Can my property manager or chief engineer be the QEM?
Yes, if they meet the CBPS 017 qualifications, including Commerce's free Tier 2 training. If they do, our bring-your-own-QEM package fits: we prepare everything and they review, sign and submit.

### Should I file an extension instead?
Only if you truly need more time. A two-year extension can be requested between six months before and six months after the deadline (Jan. 1, 2027 to Jan. 1, 2028 for Tier 2), but an extension does not earn the incentive. (Source: Commerce Tier 2 compliance page and CBPS 044.)

### Can I do this myself for free?
Yes. Commerce publishes free templates (Energy Management Plan template, O&M Program Development Tool, reporting tools) at commerce.wa.gov/cbps, offers free QEM training, and the Smart Buildings Center runs a free Clean Buildings Helpdesk. Many utilities also offer free Clean Buildings Accelerator programs. We're for owners who would rather pay a flat fee than do it themselves.

### How do you compare with other Tier 2 services?
Several private companies now offer Washington Tier 2 help. Their published terms, checked Oct. 27, 2026 (prices change, so ask each for a current quote): The lowest published price with a QEM's review and signature included is Tier 2 Desk's $3,900 ($2,400 if you bring your own QEM). Evergreen Compliance drafts the documents only, for $2,250 per building; your own QEM then reviews, signs and submits, and that QEM's fee is extra. Tier Two Partners charges $0.12 per eligible sq ft for one building plus a separate QEM fee. Easy BPS (Pilotlight) charges $5,500. Sheehan Engineering charges $5,750 for virtual service. Vert charges $12,000. WA Energy Managers describes a team of Qualified Energy Managers, publishes no price, and says its fee comes out of your incentive, quoted in writing in advance. Some engineering and mechanical firms quote building by building. We charge one flat fee per building with review and signature by our partner QEM included, with portfolio pricing, a lower fee if you bring your own QEM, and a pay-after-approval option. Ask us for a quote. Whoever you choose, the incentive is paid by your participating utility after Commerce certifies compliance, and it is not guaranteed.

### What if Commerce asks questions about the filing?
We answer them. If Commerce sends questions or a deficiency notice after submission, we prepare the responses within five business days, at no extra charge, for the QEM to review and resubmit. Commerce review times vary, and Commerce decides whether a filing is accepted.

### Are you the Clean Buildings Helpdesk?
No. The free Clean Buildings Helpdesk is run by the Smart Buildings Center (smartbuildingscenter.org), and some utilities run their own help desks. Clean Buildings Associates is a separate, private, paid service operated by Voraus LLC.

### Are you affiliated with WA Commerce, the Clean Buildings Helpdesk, or a cleaning company?
No. Clean Buildings Associates is a private company (Voraus LLC). We are not affiliated with the Washington State Department of Commerce, the Smart Buildings Center's Clean Buildings Helpdesk, or any cleaning or janitorial company. "Clean Buildings" in our name refers to Washington's Clean Buildings Performance Standard, the law we help owners file under.

### What do I have to do?
About 2 hours in total: a short questionnaire, signing utility data authorizations, sending equipment nameplate photos (or a short video walk-round), creating your Clean Buildings Portal account and granting shared access, and signing Form A.

### How long does it take?
Usually 3 to 6 weeks of our time. The slowest step is utility data: getting 12 months of usage into ENERGY STAR Portfolio Manager can take from a couple of days to about 4 weeks depending on the utility and tenant authorizations.

### Multifamily: what's the Anti-Displacement Agreement?
Multifamily owners who rent to residential tenants and sign Commerce's Anti-Displacement Agreement (Exhibit A) may be eligible for the enhanced incentive of up to $0.75 per sq ft or the estimated cost of compliance, whichever is lower. Read the agreement before signing; it adds tenant-protection commitments.

### Are you part of the state?
No. Clean Buildings Associates is a private company (Voraus LLC). We are not affiliated with or endorsed by the Washington State Department of Commerce.

### Do you visit the building?
Usually not. We work from your utility data, documents, nameplate photos and a short video walk-round. If a site visit is needed, we'll quote it first.

### What happens after compliance?
Tier 2 reporting repeats every five years, and the O&M program and energy management plan must keep being implemented. Our optional upkeep plan handles the annual Portfolio Manager update and reminders.