Across the Pacific Northwest and nationwide, state legislatures, municipal leaders, and energy agencies are enacting outcome-based policies to curb energy consumption and carbon emissions in existing structures. Policies like the Oregon Building Performance Standard (OR BPS / HB 3409) and the Washington Clean Buildings Performance Standard (CBPS) are transforming building compliance from a passive goal into an active legal requirement. To avoid steep financial penalties, protect asset valuations, and lower operating costs, building owners must navigate two foundational industry standards:
- ASHRAE Standard 100-2024: The recognized model standard (Energy and Emissions
Building Performance Standard for Existing Buildings) establishing Energy Use Intensity (EUI) targets, Greenhouse Gas Intensity (GHGI) goals, Operations & Maintenance (O&M) protocols, and Energy & Emissions Management Plans. - ASHRAE Standard 211-2018: The national standard defining consistent methodologies, scope of work, and standardized reporting for commercial building energy audits.
Achieving compliance under these standards requires an accredited, certified technical leader. At Smart Optimal Solutions (SOS-Net Zero Energy), our compliance and energy consulting services are led by Jeff Taylor, CEM®, Commercial Project Manager and Energy Consultant.
The CEM Advantage: Qualified Technical Leadership
Both ASHRAE Standard 100-2024 and Standard 211-2018 mandate that energy audits, baseline calculations, and official compliance submittals be completed by a recognized “Qualified Energy Auditor” (QEA) or “Qualified Person”.
Jeff Taylor’s Certified Energy Manager (CEM®) credential-issued by the Association of Energy Engineers (AEE) and accredited under ANSI/ISO/IEC Standard 17024-meets the explicit criteria required to perform, verify, and sign off on technical building assessments and state compliance forms across Oregon and Washington.
Pacific Northwest BPS Mandates: Oregon & Washington Frameworks
State regulatory frameworks vary by building size, property type, and implementation timeline. SOS provides complete technical management to keep building portfolios on schedule and fully compliant.
1. Oregon Building Performance Standard (OR BPS / ODOE) Enacted under HB 3409 and administered by the Oregon Department of Energy (ODOE), OR BPS establishes strict compliance reporting requirements for existing commercial structures:
Tier 1 Requirements: Owners must complete 12 continuous months of net energy usage tracking using EPA ENERGY STAR Portfolio Manager (Form C), document Energy Use Intensity (EUI) versus Energy Use Intensity Targets (EUlt) (Form B), and submit a formal Operations & Maintenance (O&M) program and Energy Management Plan (EMP).
Audit & LCCA Mandates: If a Tier 1 building exceeds its EUlt, the owner must notify ODOE at least 180 days prior to their deadline[cite: 5], perform an ASHRAE-compliant Energy Audit (Form E)[cite: 5], and complete a Life Cycle Cost Assessment (Form L) using NIST Handbook 135 criteria to implement cost-effective Energy Efficiency Measures (EEMs)[cite: 5].
Tier 2 Requirements: Owners of covered properties must complete whole-building energy benchmarking (Form C) and establish baseline EUlt metrics (Form B) by July 1, 2028[cite: 5, 8].
2. Washington Clean Buildings Performance Standard (WA CBPS) Under Washington state law, commercial buildings are subject to strict, mandatory EUI targets based on ASHRAE 100 frameworks:
Tier 1 Covered Buildings ($\ge$ 50,000 sq ft): Mandatory compliance schedules are currently active. Buildings failing to meet EUI targets must complete energy audits, execute EEMs, and establish continuous O&M and EMP programs.
Tier 2 Covered Buildings (20,000 to 50,000 sq ft): Owners must have their Energy Management Plans (EMP) and Operations & Maintenance (O&M) programs fully implemented by July 1, 2026, with baseline energy benchmarking and reporting due by July 1, 2027.
ASHRAE Standard 211-2018: Standardized Commercial Energy Audits
When buildings exceed state energy targets under ASHRAE 100-2024, ASHRAE Standard 211-2018 dictates the required auditing methodologies. Standard 211 applies to all commercial
properties (excluding single-family homes, low-rise residential structures of 3 stories or less, and manufactured housing).
Led by Jeff Taylor, CEM, SOS executes all three standardized audit tiers:
Level 1 (Walk-Through Analysis): Focuses on low-cost/no-cost Energy Efficiency Opportunities (EEOs), identifies baseline energy use profiles, and establishes building benchmarking metrics.
Level 2 (Energy Survey and Analysis): Provides a detailed breakdown of building energy consumption, evaluates specific Energy Conservation Measures (ECMs) with itemized material/labor cost estimates, projects annual utility bill savings, and delivers clear economic return-on-investment (ROI) analysis.
Level 3 (Detailed Analysis of Capital-Intensive Modifications): Employs dynamic building energy modeling and rigorous engineering calculations to evaluate complex, high-capital mechanical and structural retrofits.
Capital Stacking: Unlocking Subsidies & Early Compliance Grants
Achieving BPS compliance should build long-term asset value, not strain operating budgets. SOS specializes in Capital Funding Stacking—pairing mandatory building retrofits with utility rebates, state grants, and green financing:
Oregon BERI Program ($12 Million ODOE Grant Fund): Administered by the Oregon Department of Energy, the Building Energy Reduction Incentive (BERI) program offers early compliance incentives of up to $100,000 for Tier 1 buildings and up to $50,000 for Tier 2 buildings. Funding offsets costs for benchmarking ($0.35/sq ft), EMP/O&M development ($0.05/sq ft), energy audits ($0.35/sq ft), and project compliance ($0.10/sq ft, up to $0.85/sq ft total). Applications require an energy audit conducted by an ODOE-approved Qualified Energy Auditor (Jeff Taylor, CEM)[cite: 5, 8]. Utility Rebate Capture: As an active Energy Trust of Oregon Trade Ally since 2002, Jeff coordinates directly with regional utilities—including the Energy Trust of Oregon (Portland General Electric, Pacific Power, NW Natural), Clark Public Utilities, and BPA-funded consumer-owned utilities-to maximize cash incentives for HVAC, controls, and LED lighting retrofits.
Washington CEEP Grant Layering: We blend utility incentives with Washington State’s Community Energy Efficiency Program (CEEP) grants (administered via the WSU Energy Program through June 30, 2027), driving out-of-pocket project costs down to near-zero.
Specialized Financing: As a CEM-led firm, SOS qualifies projects for Property Assessed Clean Energy (PACE) third-party engineering reviews, Fannie Mae High Performance Building (HPB) Assessments for multifamily properties, and USDA EQIP On-Farm Energy / REAP grants for agricultural/rural commercial facilities.
Take Action: Schedule Your Baseline BPS Compliance Assessment
Navigating ASHRAE 100-2024 targets, ASHRAE 211 energy audits, and Oregon/Washington BPS deadlines doesn’t have to be an administrative or financial guessing game.
To help building owners stay ahead of state enforcement, Smart Optimal Solutions offers baseline compliance consultations to evaluate your facility’s EUI profile, audit requirements, and eligible grant funding.
Stop guessing about efficiency mandates. Start maximizing your operational returns.
Contact Smart Optimal Solutions today to schedule a consultation with Jeff Taylor CEM, and keep your facilities compliant, sustainable, and profitable.
Written by Jeff Taylor – SOS Consultant
