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:

ElementDetail
ScopeEnvelope, domestic hot water, HVAC, refrigeration, lighting, controls, power distribution and on-site generation.
Equipment inventoryEvery energy-using system, flagging anything past its useful life for the capital plan.
Tasks and frequenciesInspection and maintenance per manufacturer requirements. CBPS Annex D and ASHRAE/ACCA 180 are references.
Tracking methodManual or CMMS: where records live and who can reach them.
RecordsWritten or electronic proof that tasks were done.
Access statementSafe, reasonable access to all covered equipment.
Emergency informationStaff and agency notification procedures, readily available.
Revision triggersRenovations, use changes, component changes, systems missing objectives, or a provider's documented recommendation.
Tenant improvementsA process so space changes don't raise net energy use beyond what a new use justifies.

Proof Commerce accepts

Accepted as proofNot enough on its own
Completed PM logs: spreadsheets, photos of paper logs, or CMMS screenshotsInvoices for reactive repairs
Work orders and invoices for scheduled servicing of energy-intensive equipmentInvoices for upgrades or replacements
A current, signed PM service contract listing the equipment and scopeA 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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