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Energy benchmarking in Washington State

Washington benchmarking, which is how the Clean Buildings standard is measured.

Washington has no standalone annual benchmarking filing. Benchmarking is a required part of Clean Buildings compliance, together with an energy management plan and an operations and maintenance programme.

No obligation. We will tell you if you do not need us.
What Washington requires
Who is covered Tiered, from 20,000 sq ft Every covered building over 20,000 sq ft has to benchmark and put an energy management plan and an operations and maintenance programme in place. Only nonresidential buildings over 50,000 sq ft also have to meet an energy use intensity target.
Annual deadline June 2026 to 2028, and July 2027 Tier 1 runs by size band: over 220,000 sq ft by June 1, 2026, 90,001 to 220,000 by June 1, 2027, and 50,001 to 90,000 by June 1, 2028. Tier 2 is due July 1, 2027.
What is measured Absolute EUI target Commerce publishes target energy use intensity by building type in advance, so a building can owe a standard having never benchmarked.
Filed with Washington State Commerce Filed with Commerce.

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

Benchmarking here is a component, not a programme.

Most states run benchmarking as its own annual filing. Washington does not. Benchmarking is one of the deliverables inside the Clean Buildings Performance Standard, submitted with an energy management plan and an operations and maintenance programme on your tier and band date.

That has a practical consequence people miss: the targets are absolute and published in advance, so a building can owe a performance standard having never benchmarked in its life. Benchmarking is the ruler, not the grade.

Every covered building over 20,000 sq ft owes the benchmark, the plan and the programme. Only nonresidential buildings over 50,000 sq ft also have to meet an energy use intensity target, which is why Tier 2 buildings are frequently relieved once someone explains what they actually owe.

Local detail that changes the answer
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 the benchmark ready

Data first, then the plan and programme documents that travel with it.

1
Confirm tier and band
Per building, with parking excluded. Campuses tier smaller than owners expect, and the band inversion means anything near 50,000 sq ft should be planned to the earlier date.
2
Assemble the data
Washington utilities backfill whole-building data retroactively, so this is rarely the urgent item. Gas with fewer than three separately billed tenants is the genuine lead-time problem.
3
Build the benchmark
Twelve months of complete, verified data in Portfolio Manager, with floor area confirmed.
4
Prepare plan and programme
The energy management plan and operations and maintenance programme, which Tier 2 buildings are expected to have running before the filing date.
5
Submit for your date
Filed with Commerce on your band deadline, with the extension route checked if a date has already passed.
If the filing is late

A performance standard you can owe without ever having benchmarked.

Because Washington targets are absolute and published in advance, the obligation does not depend on a benchmarking history. That catches owners who assume no filing means no exposure.

We also do not sell Washington work on data urgency, because the utilities backfill retroactively. The honest lead-time item is the plan and programme work, not the data.

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 owners hand Washington to Honeydew

We file across twenty-six jurisdictions and track the rule changes in each one rather than working from last year’s version.

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.
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.
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

Washington benchmarking questions

Coverage here turns on building-by-building floor area with parking excluded and multifamily and parking subtracted before testing the Tier 1 line. Send us the address and we will confirm it against the jurisdiction’s own records rather than estimating.

Tier 1 is staggered from June 2026 through 2028 by size band, and Tier 2 is due July 1, 2027. Extensions can be filed up to six months after a missed deadline and are valid two years.

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.

Most residential condominiums and cooperatives are excluded from the state standard, though Seattle buildings can still be covered by the city programme. That distinction catches boards out, so we confirm both.

Yes, the state runs an early adopter incentive programme, and it has covered a meaningful share of compliance cost for buildings that moved early. We check eligibility before quoting the work.

Keep reading

The pages that usually matter next for a Washington building.

Performance standard BEPS in Washington The performance standard, the pathways, and what the exposure really is. 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

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