West Coast
California layers city programmes on top of a state programme, and the real constraint is utility data access. Three of the six major California utilities need no client document at all, while two need heavy owner-signed packages. Washington State adds an absolute-target standard that is not a benchmarking programme at all.
California
Statewide AB 802, owner filed annually. Condominiums are statutorily excluded from the state programme. Shopping centers are tested per building above 50,000 square feet.
Sort a California portfolio by fuel and utility, never by property or city. A building with a live notice and a blocked electric utility can often still have its gas request submitted the same day, and that partial unblock is where the schedule is won.
Los Angeles
EBEWE. City filing satisfies the state programme, but a city exemption does not, so exempt buildings over 50,000 square feet may still owe the state. Condominiums are covered and the association files.
LADWP is blocked until an owner letter of authorisation exists, but SoCalGas is open with no client document. Open the gas half of every property immediately and let it backfill during the LADWP wait.
San Francisco
Non-residential from 10,000 square feet, the lowest threshold we work with. City filing satisfies the state programme.
Both fuels are PG&E, so every San Francisco property sits behind the same attestation gate with no partial-fuel workaround. Commercial energy audits run on rolling five-year per-building dates.
San Jose
City filing satisfies the state programme. Exemptions are due a month before the filing itself, which catches people out.
Both fuels are PG&E here as well, so the attestation is the gate for the whole property. Separate building identifiers are assigned on request where a campus should be split.
Washington State
Clean Buildings Performance Standard. Not just benchmarking, it requires an energy management plan, an operations and maintenance programme, and a performance target.
The test is a single building, not the aggregate of a campus, and parking is excluded. Watch the band inversion, a building just under 50,000 square feet is due eleven months earlier than one just over it. Extensions can be filed up to six months after a missed deadline.
Seattle
Fully stacks with the state standard. Two filings, and neither satisfies the other.
A new city portal launched in mid 2026, so the submission path should be re-verified before filing. Building tune-ups are in their second cycle, and there are nine alternative compliance paths, two of which can be answered from public data in minutes.
Regulatory dates, thresholds, penalties, and program mechanisms change, and several of the programs above have draft elements that are not yet settled. Nothing on this page is a determination about a specific building. Confirm the current requirement for the individual property before acting, and we will do that with you.
Not sure which rulebook applies?
Mailing city is not the same as jurisdiction, and one property can sit in two programs at once. Give us the address and we will check it properly.
Tell us what is on your plate. We will help you sort it out.
A notice, a deadline, a portfolio, or simply a question. You do not need to have it organized before you call.