WASHINGTON CLEAN BUILDINGS + ENERGY BENCHMARKING

Expert Compliance Strategies for Tier 1 and Tier 2 Buildings

Square feet under our purview
Verified gross floor area across active CBPS engagements
0buildings under management
0owners & portfolios served
$5,750Flat fee, Tier 2 — EMP + O&M, complete
Jun 2027Tier 1 deadline, 90–220k SF buildings
$0.75/SFEnhanced multifamily incentive (Anti-Displacement Agreement)
PE + CEMYour Qualified Person, on every page
Why one firm matters

CBPS work has to be prepared and signed by qualified professionals. That’s us, in-house.

PE
Licensed in Washington

Establishes your EUIt and attests the EMP and O&M program as your Qualified Person.

CEM
Certified Energy Manager

Serves as the Qualified Energy Manager Tier 2 buildings must designate.

ESPM
ENERGY STAR Partner

Builds and verifies the benchmarking data Commerce relies on for compliance.

The engineer who benchmarks your building is the one who writes the plan, builds the O&M program, and signs the filing. No hand-offs, no subcontracted signatures.

One building or twenty-two

Washington Clean Buildings Act compliance for a single property or an entire portfolio — the deliverable is identical.

Every building gets the same document architecture: the same Energy Management Plan structure, the same 10-sheet O&M workbook, the same benchmarking format. A portfolio owner sees one uniform system across every property — one training, one review cycle, one place the records live.

One building

Flat fee, 8–10 weeks, complete: gap analysis through Clean Buildings Portal filing. You get the same system our portfolio clients run.

A portfolio

Auto groups, housing authorities, industrial holdings, multi-site owners. Type-and-repeat efficiency: shared program architecture, per-building specifics, portfolio pricing, one point of contact who has walked every roof.

How we get you compliant

Four steps from "where do we stand?" to Commerce-ready.

1

Gap analysis — know your position before you commit budget

We benchmark in ENERGY STAR Portfolio Manager, establish weather-normalized EUI, calculate your EUIt under Section 7.2, and compare. You get a written finding: your pathway, what you already have that counts, and what's actually missing. Fixed fee, credited toward the engagement — it often shrinks your scope.

2

Energy Management Plan — built around how your building runs

A Section 5 EMP names accountable people, tracks EUI against EUIt, sets goals, addresses training, and carries a capital outlook. We shape it to your actual operating schedule and equipment, prepare it as your Qualified Person, and sign it — with implementation date-stamped and evidenced.

3

O&M record copy — built on what you already do

Section 6 doesn't require throwing out your existing preventive maintenance — it requires covered systems documented, maintained on defined frequencies, and demonstrably performed. We map your current practices against the standard, write only the gaps, and deliver one workbook holding the program and the proof: inventory, PM plan, frequency calendar, logbook, and trackers.

Not doing anything yet? That's fine. We build the customized O&M program from scratch, then either coach your staff on running it or help you engage and scope a maintenance vendor to carry it out.

4

Ongoing energy manager — so the next cycle is a review, not a rebuild

Buildings re-report every five years, and an EMP goes stale the moment a chiller changes. On annual retainer we keep ESPM data verified, review maintenance records, update the plan as the building changes, and flag drift before it becomes a missed target.

Requirements by tier

Which rules apply to your building?

Your schedule

8–10 weeks, kickoff to Commerce-ready.

The whole engagement — including the parts where we need your team. Click a phase bar. Gold dots mark the weeks your team is involved.

Sheehan Engineering work Buffer for review & portal

Weeks 9–10 are deliberate buffer for review cycles and Clean Buildings Portal processing — the reason we quote 8–10 weeks rather than promising 6 and slipping.

See the actual deliverables

Flip through an Energy Management Plan. Click through the O&M workbook.

Most firms describe their deliverables. We'd rather show you. Below: a simplified look at how the Section 5 EMP and the 10-sheet O&M Program workbook are built — not the full documents, but the structure and the level of rigor to expect.

Energy Management Plan — simplified sample pages
CLEAN BUILDINGS PERFORMANCE STANDARD
Energy
Management Plan
Sample Office Building — Tier 2 Covered Building
Prepared per WAC 194-50 §5.1 · ANSI/ASHRAE/IES 100-2018 as amended
Qualified Person: Washington-licensed PE, CEM
CONTENTSWAC 194-50 §5.1
  • Executive Summary (5.1.2.2 – 5.1.2.4)1
  • Acknowledgments (5.1.3 / 5.1.4)2
  • Introduction5
  • Usage and Area Breakdown5
  • Building Envelope Description and Condition5
  • Mechanical, Electrical, and Plumbing Systems6
  • Lighting Systems · Other Energy Consuming Equipment7
  • State and Local BEPS Compliance Coverage7
  • Building Contacts · Service Providers & Utilities (5.1.1 / 5.1.2.11)8
  • Property Details (5.1.2.5)10
  • Benchmarking and Performance Monitoring (5.1.2.1 / 5.2)11
  • Continuous Improvement Efforts (5.1.2.6 – 7)14
  • Operations & Maintenance Program (5.1.2.14 / 6.2 / 6.3)16
  • Equipment Inventory (5.1.2.10 / 5.1.2.12 – 13 / 6.6 / L2)17
  • Capital Management Plan (5.1.2.10 / 6.5 / 6.6)24
Sheehan Engineering PLLCContentsWA Clean Buildings Performance Standard · WAC 194-50
EXECUTIVE SUMMARY§5.1.2.2 – 5.1.2.4
KPIsEUIWNEUIEUItNET ENERGY USE
CURRENT (2025)51.951.459.01,834,220
PRIOR (2024)53.252.859.01,880,140
BASELINE (2024)53.252.859.01,880,140

EUI in kBtu/sf/yr; net energy use in kBtu. Weather normalization per NOAA TMY degree-day regression. EUIt established under §7.2.3 from ANSI/ASHRAE/IES 100 Table 7-2a/2b by building activity type and climate zone.

The building performs 7.1 kBtu/sf/yr below its energy use intensity target. Compliance posture, the implemented O&M program (§6), and the capital outlook (§5.1.2.10) are documented herein.

Sheehan Engineering PLLCPage 1 of 41WA Clean Buildings Performance Standard · WAC 194-50
ENERGY BENCHMARKING§5.1.2.1 / 5.2
Figure 1 — Monthly consumption by fuel (kBtu)
Electric — GridNatural Gas
Figure 2 — Annual EUI vs. EUIt
EUIt 59.0
53.22024
51.92025
20242025
Electric — Grid (kBtu)1,411,0201,376,480
Natural Gas (kBtu)469,120457,740
EUI / EUIt (kBtu/sf)53.2 / 5951.9 / 59
Sheehan Engineering PLLCPage 13 of 41WA Clean Buildings Performance Standard · WAC 194-50
EQUIPMENT INVENTORY§5.1.2.10 / 6.6 / Annex L2
IDSystemMake / ModelCapacityFuelInstalled
RTU-1Packaged RTUTrane YSC0605 ton / 120 MBHElec / NG2015
RTU-2Packaged RTUTrane YSC0605 ton / 120 MBHElec / NG2015
RTU-3Packaged RTUTrane YSD0907.5 ton / 150 MBHElec / NG2015
WH-1Storage DHWA.O. Smith BTR-8075 gal / 76 MBHNG2019
EF-1..4Exhaust fansGreenheck SP-A≤ 400 cfm ea.Elec2015
LTGInterior/site lightingLED retrofit, photocell + scheduleElec2016

Install years recovered from nameplate serial-date codes where records were absent. Inventory carries nameplate photos, refrigerant type, and control sequence notes in the delivered document; each asset maps to its PM task set and capital strip.

Sheehan Engineering PLLCPage 18 of 41WA Clean Buildings Performance Standard · WAC 194-50
CAPITAL MANAGEMENT PLAN§5.1.2.10
Packaged Rooftop Units (RTU-1 through RTU-5, Trane YSC/YSD series)
CONDITIONMixedRated fair to good at audit
INSTALLED2015
PUBLISHED LIFE15 yrASHRAE
REMAINING4 yr
REPLACEMENT STRATEGYMaintenance-first; watch window 2030–2032
Gas Water Heater (WH-1, A.O. Smith BTR-80)
CONDITIONGood
INSTALLED2019
PUBLISHED LIFE12 yrASHRAE
REMAINING5 yr
REPLACEMENT STRATEGYReplace-on-failure; ENERGY STAR® or heat-pump DHW at end of life per §6.6

Reaching published service life is a monitoring milestone, not a replacement trigger. A named window funds a reserve and stages spares; §5.1.2.10 requires identification of equipment for replacement with energy-efficient and ENERGY STAR® rated equipment in the event of failure.

Sheehan Engineering PLLCPage 27 of 41WA Clean Buildings Performance Standard · WAC 194-50
OPERATIONS & MAINTENANCE PROGRAM§5.1.2.14 / 6.2 / 6.3

§5.1.2.14 makes the O&M program a required element of the energy management plan — the plan is not complete without it, and it is not current if the workbook has gone stale. The program is governed by Section 6 and Annex L: asset inventory, task set with CORE/ELECTIVE basis, frequencies, responsible parties, and the logbook that constitutes implementation evidence.

The 10-sheet workbook is previewed below ↓

Delivered EMPs run 30–50 pages, reviewed and signed annually by the owner per §5.1.4.
Sheehan Engineering PLLCPage 33 of 41WA Clean Buildings Performance Standard · WAC 194-50
O&M Program workbook — simplified sheet views

Every task carries a basis (CORE or ELECTIVE), a frequency, and the §6 performance objectives it serves — and the logbook holds the proof the standard asks for.

SESHEEHAN
ENGINEERING
CLEAN BUILDINGS PERFORMANCE STANDARD
The Washington
Clean Buildings
Playbook
Deadlines, penalties, incentives, and the documents that prove compliance.
2026 EDITIONTIER 1 & TIER 2
Free download

The 2026 playbook, verified to the July 2026 Integrated Document.

Eleven pages, written for owners rather than engineers: every deadline by tier and size, the penalty math including the mitigation-plan detail that cuts the rate by 80%, the incentive rates and what's left in the fund, the Tier 1 pathway when you're over the target, and exactly what the two required documents contain.

  • Which tier you're in, on one graphic
  • The clock that starts twelve months before your deadline
  • Over or under the bar — and what happens next
  • Published fees, so the math is yours to run
Get the free playbook
Transparent pricing

One flat fee.

No pricing behind a sales call. Every engagement includes the gap analysis, both compliance documents, training, portal filing, and the Early Adopter incentive application.

Tier 2 · 20–50k SF & Multifamily
$5,750
flat fee — complete compliance package
  • Gap analysis & ESPM benchmarking, WNEUI + EUIt
  • Section 5 EMP, signed by your Qualified Energy Manager
  • Section 6 O&M record-copy workbook + staff training
  • Clean Buildings Portal submission
  • Early Adopter incentive application ($0.30–$0.75/SF)
Incentive frequently covers the entire fee
Tier 1 · over 50,000 SF
$7,500
flat fee — EMP + O&M + benchmarking & filing
  • Gap analysis & pathway determination
  • Section 5 EMP, signed by your Qualified Person (PE/CEM)
  • Section 6 O&M record copy with 12-month look-back structure
  • Forms & portal submission
  • Investment-criteria pathway? Level 2 audit scoped after the gap analysis
Fixed scope, no hourly surprises

Fees apply to a single building with complete utility data access. Portfolios, campuses, and buildings with incomplete energy histories quoted individually — usually after the gap analysis, which is credited either way.

Estimate your net cost

Washington’s Early Adopter incentive pays per square foot for early compliance — for many Tier 2 buildings it exceeds our entire fee. Slide to your size.
Your tierTier 2
Sheehan flat fee$5,750
Early Adopter incentive at $0.30/SF– $9,000
Net position$0

Common questions

WA Clean Buildings FAQ

Do I have to replace my existing maintenance program?

No. If your current preventive maintenance covers the systems and frequencies the standard requires, it can be used as-is — it just has to be documented and demonstrably implemented. We map your existing practices against Section 6 and fill only what's missing.

What counts as proof my O&M program is "implemented"?

Completed maintenance records tied to a documented plan — logs showing the tasks in your program were performed on the equipment in your inventory, on the frequencies you committed to. A written plan with no records behind it is the most common gap we find, and it's exactly what the record copy solves.

Who is a Qualified Person, and do I need one?

Tier 1 compliance requires a Qualified Person — typically a licensed PE, Certified Energy Manager, or credentialed equivalent — to establish the EUIt and attest that the EMP and O&M program were developed, implemented, and maintained. Tier 2 requires a designated Qualified Energy Manager. Sheehan Engineering serves in either role.

How long does compliance take?

8–10 weeks from kickoff to portal submission, including your team's review time — see the schedule above. Commerce's review after submission typically adds 4–8 weeks. Starting early protects your incentive eligibility.

How much does it cost?

$5,750 flat for a Tier 2 building, $7,500 flat for Tier 1 — gap analysis through portal submission. For Tier 2 buildings, the Early Adopter incentive ($0.30/SF, or $0.75/SF enhanced multifamily) frequently covers the full fee.

What happens if I miss my EUIt target?

You won't automatically be fined. Tier 2 buildings calculate the target but aren't required to meet it. Tier 1 buildings that miss follow the investment-criteria pathway: an ASHRAE Level 2 audit identifies measures, and if they aren't cost-effective over the equipment's life, you can achieve compliance without implementing them.

What happens after I submit?

Buildings re-report every five years, with twelve consecutive months of compliant data inside the window before each deadline. The EMP and O&M program are meant to run continuously in between — which is why we offer ongoing energy management rather than treating submittal as the finish line.

YOUR ROADMAP TO COMPLIANCE

Get in Touch

Whether you know your needs or have questions on the requirements, we are here to help.

Fill out the form or get in touch below:

Email kevin@sheehan-eng.com

Call (773) 312-2898