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the Clean Buildings Performance Standard in Washington State

The Clean Buildings Performance Standard, which is not a benchmarking programme.

Washington asks for an energy management plan, an operations and maintenance programme, and a performance target. Benchmarking is the ruler, not the grade.

No obligation. We will tell you if you do not need us.
the Clean Buildings Performance Standard at a glance
What it requires Plan, programme, target An energy management plan, an operations and maintenance programme, and a performance standard.
Tier 1 Staggered June 2026 to 2028 By size band, largest first.
Tier 2 July 1, 2027 Includes all multifamily from 20,000 sq ft.
Pathways Four, not two Meet the target, investment criteria, a 15 percent reduction, or heat pump electrification.

Dates and thresholds change. We confirm the current requirement for your specific building before anyone acts on it.

What the standard actually asks of a building.

Washington is an absolute-target state. Commerce publishes target energy use intensity by building type in advance, which means a building can owe a performance standard having never benchmarked in its life. Benchmarking is how you measure against the target, not the obligation itself.

There are four compliance pathways rather than two: meet the target, satisfy the investment criteria, achieve a 15 percent reduction, or electrify with heat pumps. Choosing well requires modelling all four rather than defaulting to the obvious one.

Two structural details matter more than anything else here. The test is a single building rather than the aggregate of a campus, with parking excluded, so center and campus totals over-tier every time. And there is a band inversion: a building just under 50,000 sq ft is due eleven months earlier than one just over it.

What decides your outcome
Per building, not per campus
Commerce tests a single building rather than the aggregate of a campus, and parking is excluded. Center totals over-tier and over-count every time.
Watch the band inversion
A building just under 50,000 sq ft is due eleven months earlier than one just over it. Anything within a few thousand feet of that line should be planned to the earlier date.
Late extensions are allowed
Extensions can be filed up to six months after a missed deadline and last two years. Check that before panicking about a missed date.
The services behind this page

How we get you to the standard

Establish the position, choose the route, then document the work.

1
Establish the real position
Verified floor area, clean data, and the gap to the standard expressed in the terms the programme actually uses.
2
Model the options
All four pathways modelled, because the investment criteria and the 15 percent reduction routes are frequently cheaper than chasing the absolute target.
3
Sequence the work
Measures ordered against your capital plan and your board calendar, with incentives factored in rather than left on the table.
4
Document as you go
Every measure, invoice and audit recommendation captured while it is happening. Reconstructing this later is the expensive way.
5
File and follow through
Plan, programme and performance documentation submitted to Commerce for your tier and band, with extensions filed where the window allows.
The exposure, honestly

Notice-driven penalties, and an extension window most owners do not know exists.

Commerce cites five thousand dollars plus a per-square-foot amount, and enforcement is notice-driven rather than automatic. Before quoting exposure to anyone, we check the extension position.

Extensions can be filed up to six months after a missed deadline and are valid for two years, which is unusual and genuinely useful. Always check that window before assuming a building is in trouble.

Received a letter?

What a Commerce letter usually means.

Washington publishes no covered building list, so the letter is how you learn you are covered.

Send us the letter
Building Owner Notification Letter
Commerce’s notice that your building is subject to the standard, with its tier and date. If you have not received one and think you should have, request it rather than waiting.
Non-compliance notice
Enforcement is notice-driven. Before assuming penalty exposure, check the extension window, which stays open up to six months after a missed deadline and is valid for two years.

Send us the letter itself, not a summary. We read it for the six things that decide the response: who sent it, which building and identifier it names, what period it covers, what it says you failed to do, the cure date, and whether it is a first notice or an escalation. We never quote a running penalty total, and we cure first, then talk to the regulator.

Why boards bring us in

Performance standards are where the money is, and where bad advice is most expensive.

Built for boards
Most of our clients are condo and co-op boards and the managers who serve them. We present in plain English, on your meeting schedule.
We read the primary sources
Twenty-six jurisdictions, each with its own portal, deadline and enforcement style. We work from the ordinance, the regulator’s FAQ and the covered building list, not from last year’s memory.
Credentialed
Certified Energy Manager on staff, Portfolio Manager specialists, and the credentials the verification work requires.
One accountable partner
We are not engineers and we do not pretend to be. We manage the process, coordinate the right vendors, and own the outcome.
Owners and managers we work with
FirstService Residential Legum & Norman EJF Real Estate Services Comsource Management Barkan Management Howard University Regency Centers Montgomery County Green Bank

Questions about the Clean Buildings Performance Standard

No, and this is the most important misunderstanding in Washington. The targets are absolute and published in advance, so a building can owe a performance standard without ever having benchmarked.

Possibly not. Extensions can be filed up to six months after a missed deadline and are valid for two years. That is the first thing we check.

Benchmarking plus an energy management plan and an operations and maintenance programme, submitted by July 1, 2027. No energy use intensity target applies to Tier 2, and the plan and programme are expected to be up and running before the filing date, which in practice means during 2026.

Keep reading

The pages that usually matter next for a Washington building.

Annual filing Benchmarking in Washington The annual filing, what is reported, and how we keep the record clean. Qualified Person Verification in Washington Third-party data verification and the square footage work that moves every number. Everything we do here Full services in Washington Everything Honeydew manages here, compliance and energy services together.
What is BEPS? All Honeydew services Every region we serve Latest rule changes on the blog

Know your position before the next deadline.

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