Tier 2 Energy Management Plan (EMP) requirements

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
Written by: The energy manager the owner designates CBPS 037
Owner signature: Reviewed and signed annually CBPS 037
Reporting tool: Mandatory; attached to the application Commerce Tier 2 page
Template: CBPS 039, optional CBPS 039

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.
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 (fictional building).

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