Washington Clean Buildings · Tier 2 guide
Tier 2 for condo associations
Condo buildings are treated differently under Washington's Clean Buildings rules. Many condo boards are covered by Tier 2 and don't know it, and others assume they're covered when they aren't. This guide summarizes Commerce's condominium guidance.
Who is responsible: the association
Where a condominium is subject to the standard, the "building owner" is the owners' association (WAC 194-50-030). So the board is the party that reports to Commerce, not individual unit owners.
Individual units don't count
Individually owned residential condo units are not subject to the standard, and their floor area is not included in the gross floor area calculation. The exception: if one person or entity owns more than five units interconnected through conditioned space on contiguous property, with more than 20,000 gross sq ft, that meets the multifamily definition and requires Tier 2 compliance (CBPS 034).
What does count: common space and association commercial space
- Common space means the building's corridors (lobbies, hallways, mechanical rooms, elevator shafts) and resident amenities owned by the association (recreation center, pool, athletic facilities, libraries).
- Limited common elements such as storage count as common space if they're inside the building's thermal envelope and owned or maintained by the association. Doorsteps, stoops, porches, balconies, decks and patios outside the thermal envelope don't count.
- Conditioned, unconditioned and semi-heated common space inside the thermal envelope all count toward coverage. Unconditioned space may support an exemption if the remaining area is under 20,000 sq ft.
When a condo building is Tier 2
- Common space over 20,000 sq ft: that space must meet Tier 2 requirements.
- Common space plus interconnected association-owned commercial space between 20,000 and 50,000 sq ft: Tier 2.
- Commercial space between 20,000 and 50,000 sq ft: Tier 2. Contiguous commercial space over 50,000 sq ft: Tier 1.
Source: Commerce CBPS 034, Condominium Guidance. For condo common elements and unit boundaries, Commerce points to RCW 64.90.
Penalties and incentives are based on common space
Only the condo's common space square footage is subject to the standard, and the incentive is determined by the common and/or commercial space, not the whole tower (CBPS 034). Commerce's example: a 450,000 sq ft tower with 48,000 sq ft of common space. At the published $0.30 per sq ft base rate, 48,000 sq ft works out to an estimated $14,400 incentive or a maximum penalty of the same amount (arithmetic only; incentive first-come, not guaranteed; Commerce incentive page).
What a condo board needs for Tier 2
- Confirm the common-space area from the declaration, survey maps and plans, or ask your property manager. Your QEM confirms the final gross floor area.
- Pick a Qualified Energy Manager (QEM). Tier 2 requires one. Commerce offers free QEM training, and Commerce decides eligibility; the Smart Buildings Center lists QEMs (Smart Buildings Center).
- Set up the Clean Buildings Portal account in the association's name, and confirm ownership on the Tier 2 Data Pool tab.
- Benchmark the common-area meters in ENERGY STAR Portfolio Manager (12 consecutive months of data).
- Prepare the EMP and O&M program for the association's equipment (boilers, elevators, corridor lighting, ventilation, pool equipment), then have the QEM review, approve and submit by July 1, 2027.
Full deadline, penalty and incentive details: Tier 2 deadline, penalties and incentive.
Quick answers
Do condo owners have to comply with Clean Buildings individually?
No. Individually owned residential condo units are not subject to the standard. Where a condo building is covered, the owners' association is the building owner.
Is my condo building Tier 2 because it's over 20,000 sq ft in total?
Not necessarily. Unit floor area isn't counted. Coverage depends on association-owned common space (and any association-owned commercial space) exceeding 20,000 sq ft.
Is the condo incentive based on the whole building?
No. Commerce says the incentive for condos is based on the common space and/or commercial space, and penalties apply only to common space square footage.
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.