Washington Clean Buildings · Tier 2 guide
Seattle benchmarking vs. state Tier 2
If you own a Seattle building over 20,000 sq ft, you may already file energy data with the City every June. That does not replace Washington's Clean Buildings Tier 2 filing due July 1, 2027. Here is how the city and state rules differ, and what they share.
Three different Seattle-area requirements
A Seattle building over 20,000 sq ft can sit under more than one program. They are separate:
| Program | Who runs it | What it measures | Main deadline |
|---|---|---|---|
| Seattle Energy Benchmarking (SMC 22.920) | City of Seattle | Annual energy use reported in ENERGY STAR Portfolio Manager | June 1 each year for the prior calendar year (Seattle Energy Benchmarking) |
| Washington Clean Buildings Tier 2 (CBPS) | WA Department of Commerce | Energy use intensity (EUI), plus an Energy Management Plan and O&M program | July 1, 2027 (then every five years) (Commerce, Tier 2 compliance) |
| Seattle BEPS (Building Emissions Performance Standard) | City of Seattle | Greenhouse gas intensity (GHGI), not EUI | First verification/GHG report as early as Oct. 1, 2027 for the largest buildings; smaller buildings follow later (Seattle BEPS FAQs) |
Seattle's own FAQ is plain: complying with one does not mean the building has complied with the other (Seattle BEPS FAQs).
Seattle benchmarking vs. state Tier 2
| Seattle Energy Benchmarking | State Tier 2 (CBPS) | |
|---|---|---|
| Where it applies | Seattle buildings over 20,000 sq ft (nonresidential and multifamily) | Covered buildings anywhere in Washington that meet Tier 2 size rules |
| What you file | Annual Portfolio Manager report to the City | Benchmarking (Forms B and C), EMP, O&M program, reporting tools, Form A signed by a QEM |
| Performance target today | Report energy use (no state-style EUI target in the city benchmarking law itself) | Commerce: Tier 2 buildings are not required to meet a performance target at this time; they still must report and maintain EMP/O&M (Commerce, Tier 2 compliance) |
| Cadence | Every year by June 1 | First compliance by July 1, 2027, then every five years |
| Who signs | Building owner (or designee) reports to Seattle | A Qualified Energy Manager (QEM) signs and submits to Commerce |
What you can reuse
- ENERGY STAR Portfolio Manager. Seattle benchmarking and state Tier 2 both use Portfolio Manager. The account you keep for the City is the same tool Commerce expects for CBPS benchmarking (Commerce, Tier 2 compliance; Seattle Energy Benchmarking).
- Twelve months of whole-building energy data. If your Seattle filing already has clean, complete utility data, that history helps your Tier 2 Forms B and C work. Your QEM still has to complete and submit the state forms.
- O&M overlap. Seattle's Building Tune-Ups ordinance is winding down as the state's O&M program requirements begin. Seattle's FAQ says timing those together is meant to avoid a double O&M mandate (Seattle BEPS FAQs). You still need a Tier 2 O&M program that meets Commerce's rules.
What Seattle benchmarking does not cover
- It does not create your Tier 2 Energy Management Plan.
- It does not replace Form A or a QEM's signature in the Clean Buildings Portal.
- It does not meet Seattle BEPS (emissions) deadlines when those apply to your building size.
- Official city notices come from seattle.gov addresses. Seattle warns that third-party solicitations may misstate deadlines or ask for payment to "complete" benchmarking (Seattle Energy Benchmarking).
Condo note (city vs. state)
Seattle BEPS covers residential condo buildings over 20,000 sq ft as multifamily, with the owners' association as the building owner. State Tier 2 is different: coverage turns on association-owned common space (and any association-owned commercial space) over 20,000 sq ft, not the sum of individually owned units (Seattle BEPS FAQs; see also our condo guide). If Commerce sent a Tier 1 or Tier 2 notification letter, Seattle's FAQ says the association should confirm with Commerce whether an exemption applies.
Practical next steps for a Seattle owner
- Keep the annual Seattle benchmarking filing current (June 1).
- Confirm whether the building is Tier 2 with Commerce (Portal / notification letter). Size rules: Is my building Tier 2?
- Plan the July 1, 2027 Tier 2 package: QEM, EMP, O&M, Forms B/C. Free QEM training dates: What a QEM does.
- If the building is large enough for early BEPS dates, read Seattle's BEPS FAQ separately. We prepare state Tier 2 draft documents; we do not sell Seattle BEPS compliance services.
Quick answers
Does my June 1 Seattle benchmarking filing satisfy Tier 2?
No. Seattle Energy Benchmarking is an annual city report. Washington Tier 2 is a separate Commerce filing due July 1, 2027, with EMP, O&M, and a QEM signature. Seattle's FAQ states that complying with one law does not mean you have complied with the other.
Can I use the same Portfolio Manager account for both?
Yes. Both programs use ENERGY STAR Portfolio Manager. Clean Seattle data helps, but your QEM still completes and submits the state forms in the Clean Buildings Portal.
Is Seattle BEPS the same as Clean Buildings Tier 2?
No. Seattle BEPS is an emissions standard (greenhouse gas intensity). Washington CBPS is an energy standard (EUI). Different metrics, different agencies, different deadlines.
Official sources
Want to know where your building stands?
Send us a building name or address and we'll reply with a free one-page Building Snapshot: our preliminary assessment of likely Tier 2 status from public information (for the owner or QEM to confirm), the deadline, the potential maximum penalty, an incentive estimate and a to‑do list. If you go ahead, we prepare draft documents on Commerce's templates for your QEM to review, revise, approve and submit.