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Complying with the Washington Clean Buildings Performance Standard


The Clean Buildings Performance Standard is in effect and the first deadlines are fast approaching. To comply with the Standard, building owners will need to take the following steps:

  1. Report and track building energy performance using the Energy Star Portfolio Manager against a target determined by the buildings’ use.

  2. Develop and submit an Energy Management Plan and an Operations and Maintenance Program to ensure that the building(s) are meeting and will continue to meet all current and future energy targets.

  3. If the buildings’ energy use is not meeting energy targets, develop and implement comprehensive measures to ensure compliance.

Buildings will be categorized into two groups, defined below. Tier 1 buildings will need to meet energy use intensity targets by the indicated dates. At this time, Tier 2 buildings simply have to report and submit all documentation but do not necessarily need to meet the energy use intensity targets.

Tier 1 Buildings: over 50,000 SF (excluding parking garage area)

  • 220,001 + SF                                     June 1, 2026

  • 90,001 – 220,000 SF                    June 1, 2027

  • 50,000 – 90,000 SF                       June 1, 2028

Tier 2 Buildings: 20,000 – 50,000 SF and all multifamily residential > 20,000

  • Reporting starts July 2027

  • At this time, Tier 2 buildings do not need to demonstrate compliance with energy use targets.


It will take a dedicated and specialized team to put together all of the documents for compliance. Responsibilities can be shared and can certainly overlap the defined roles provided by the Department of Commerce. A building owner can play any role defined in the standard other than those with specifically defined minimum credentials, and they can determine how they would like these different roles to overlap. No specific qualifications are required for the roles of building manager, building operator, or energy manager. The building owner holds ultimate responsibility for ensuring their building complies with the Standard.

Roles that require specific credentials include:

Qualified Person

A person having training, expertise and three years professional experience in building energy use analysis and any of the following:


  1. A licensed professional architect or engineer in the state of Washington;

  2. A person with Building Operator Certification (BOC) Level II by the Northwest Energy Efficiency Council (NEEC);

  3. A commissioning professional certified by an ANSI/ISO/IEC 17024:2012 accredited organization;

  4. A qualified energy auditor;

  5. A certified energy manager (CEM) in current standing, certified by the Association of Energy Engineers (AEE)

  6. An energy management professional (EMP) certified by the Energy Management Association (EMA).


Qualified Energy Manager (Tier 2 only)

An individual designated by the building owner who:

  1. has two years of experience, including educational and/or professional experience, with commercial building operations and/or building energy management in addition to successful completion of clean buildings tier 2 training program as specified by the AHJ; or

  2. meets the definition of a qualified person.


Qualified Energy Auditor

A person acting as the auditor of record having training, expertise and three years professional experience in building energy auditing and any one of the following:


  1. A licensed professional architect or engineer.

  2. A building energy assessment professional (BEAP) certified by the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE).

  3. A certified energy auditor (CEA) certified by the Association of Energy Engineers.


Commissioning Agent (may overlap with Qualified Energy Auditor)

A person who is certified by an ANSI/ISO/IEC 17024:2012 accredited organization to lead, plan, coordinate, and manage commissioning teams and implement the commissioning process, and with experience commissioning at least two projects of similar size and of similar equipment to the current project and at least on in the last three years. This experience includes the writing and education of verification checks and functional test plans.

The chart below shows a breakdown of responsibilities and which roles can overlap on certain responsibilities.

Washington Clean Buildings Performance Standard
WA CBPS Roles Chart


BEE Engineers can act as your Qualified Person and coordinate any additional work needed by credentialed professionals for your Clean Buildings Performance Standard compliance reporting. For buildings in Seattle, the same credentials will work for the Seattle Building Emissions Performance Standard compliance reporting. Reach out today to find out how we can help.

Please refer to the Washington State Clean Buildings Performance Standard version of ASHRAE Standard 100-2018 and official guidance provided by the WA Department of Commerce. This article is intended for informational purposes only.


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