Navigating the WA State Clean Building Performance Standard

Commercial building owners throughout Washington State will be required to reduce greenhouse gas emissions in the face of the Clean Buildings Performance Standard¹ (CBPS) and subsequent expansion bill of 2022. The bill requires owners of existing buildings to conform to state-mandated specific, energy performance targets that must be met by designated deadlines. If they cannot meet these targets, they must implement energy efficiency measures or face fines. The first of the deadlines for meeting the mandates are less than two years away. The goal is to enhance building efficiency, lower operational costs, and contribute to the state’s broader environmental objectives.

Who does the WA CBPS impact and what is the compliance reporting schedule?

Owners of existing buildings that are 20,000 sq. ft. and larger need to benchmark their energy consumption, create an energy management plan, and an operations and maintenance (O&M) plan. Buildings are categorized into two main categories referred to as Tier 1 and Tier 2. Tier 1 building compliance deadlines are as soon as June 1, 2026, for buildings with more than 220,000 square feet. Campuses can get an exemption from their Tier 1 target if the university is implementing a decarbonization plan. Tier 2 buildings must report on benchmarking, energy management plans, and operations and maintenance programs by July 1, 2027.

Tier 1. Compliance Schedule

Existing commercial buildings with more than 50,000 gross square feet (excluding parking). Compliance reporting for Tier 1 buildings begins in June 2026 for buildings larger than 220,000 square feet.

• June 1, 2026: > 20,000 sq. ft.
• June 1, 2027: > 90,000 sq. ft. but less than 220,001 sq. ft.
• June 2028: > 50,000 sq. ft. but less than 90,001 sq. ft.

Tier 2. Compliance Schedule

Buildings that are existing residential buildings or commercial buildings smaller than 50,000 square feet.

• July 1, 2027: > 20,000 - < 50,001 sq. ft. (Includes all multifamily > than 20,000 sq. ft.)

How do I make sure my building(s) meet the WA CBPS requirements?

Understanding and navigating the new limits introduced as part of the Clean Buildings Performance Standard can be overwhelming and stressful for building owners. Each journey toward compliance may look different but rest assured, the right collaborator will meet you at any point. The CBPS mandate requires 4 basic steps:

1. Building & Audit Benchmarking
2. Develop Plan: Develop energy management plan and/or operations & maintenance (O&M) program. (Often must be completed 12 mo. before reporting.)
3. Execute Project: Implement the identified energy efficiency projects and upgrades, while meeting related incentive program requirements.
4. Measure & Document: Conduct measurement and verification to assess the effectiveness of the improvements, ensuring they meet the expected energy performance outcomes and comply with WA Clean Building Performance Standards. Document the results and make any necessary adjustments to maintain compliance.

Repeat step 4 every 5 years until building = Net-Zero.

Trane® is ready to collaborate with you and help in your journey towards compliance.

Where do I begin?

Trane can help guide building owners through the CBPS building benchmarking process. Once building performance is understood, our engineers can help to develop the required energy management and operations and maintenance plans. If necessary, experienced energy consultants can perform detailed energy audits of properties. Understanding the specific requirements of the WA standards is crucial. Therefore, reviewing the guidelines and setting clear, achievable goals is essential. Engaging with experienced energy consultants can help provide valuable insights and recommendations tailored to your building’s needs.

By taking these initial steps, building owners can create a strategic plan to help enhance energy efficiency, reduce emissions, and meet the compliance with state regulations. Trane^® offers several alternative procurement pathways to support speed, transparency, and efficiency toward your compliance needs including a long-standing partnership with Omnia partners (a public purchasing network) and as a qualified and authorized WA State Dept. of Enterprise Services (DES) energy services company under the DES ESPC program.

How can Trane Help?

Trane is a global leader in air conditioning systems, services, and solutions. We offer comprehensive support to building owners striving for compliance with the Washington State Building Performance Standards through our robust services and unparalleled expertise.

• Trusted Advisor: Trane can be your building’s energy manager to help you minimize your building’s energy use without compromising indoor environmental quality. ​
• Benchmark: Trane will connect your utility data into ENERGY STAR Portfolio Manager to determine your building’s energy performance over the last 1 - 2 years​.
• Document: Write an Energy Management Plan (EMP)​.
• Develop & Implement: Develop and implement an Operations & Maintenance program for each building. Plan must be implemented 12 months prior to compliance dates.
• Submit: Submit documentation through the Clean Building Portal, verifying the building(s) Energy Usage has been met, the EMP is complete, and the O&M plan has been implemented for a minimum of 12 months.

Trane can also provide comprehensive solutions for lighting, water conservation and management strategies, building envelope improvements, and alternative energy strategies, including solar and other renewable energy sources. Our team of seasoned professionals brings deep industry knowledge and a proven record of helping buildings meet regulatory requirements. By collaborating with Trane, building owners gain access to innovative technologies and customized solutions that not only can help in their journey towards compliance but also help with operational efficiency and reducing costs.

1. https://www.commerce.wa.gov/cbps/
2. https://www.epa.gov/system/files/documents/2022-12/12%2009%202022_OAR%20IRA%20Overview_vPublic.pdf
3. https://www.dol.gov/agencies/whd/IRA

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