Washington · Preparing the filing
O&M program and proof
Last updated · 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 facts · checked October 27, 2026
- Standard
- CBPS Section 6 and Annex L, explained in CBPS 037 CBPS 037
- Systems
- Envelope, hot water, HVAC, refrigeration, lighting, controls, power CBPS 037
- Reporting tool
- Mandatory; attached to the application Commerce Tier 2 page
- Proof due
- By the reporting date or at submission, whichever is earlier Commerce bulletin, Oct. 22, 2026
- Optional tool
- O&M Program Development Tool, CBPS 040 CBPS 040
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 (fictional building).
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