Washington Clean Buildings · Tier 2 guide
Tier 2 extension vs. compliance: which is right?
If July 1, 2027 looks tight, an extension can add two years, but only for specific reasons, and it is not the same as complying. Here's how the two compare.
What an extension is
Commerce: "Extensions are not a compliance pathway; they provide building owners with additional time to pursue CBPS compliance." An extension lasts two years and is requested in the Clean Buildings Portal no sooner than six months before and up to six months after the compliance date (CBPS 044, Extension Guidance). For the July 1, 2027 Tier 2 date, six months before is January 1, 2027 (our arithmetic).
Who qualifies (Tier 2)
You need at least one of these reasons, with supporting documents (Commerce, Tier 2 compliance; CBPS 044):
- Beyond your control: for example a declared natural disaster or supply-chain delays that substantially interfere with compliance.
- Change of ownership: you bought the building within 12 months before (or on) the compliance date.
- Financial restrictions affecting cash flow (severe hardship may instead fit the financial hardship exemption).
- New construction: a permitted construction, remodel or demolition affecting at least 10% of the floor area that prevents 12 consecutive months of energy data.
- EMP and O&M: benchmarking is complete but more time is needed for the Energy Management Plan and O&M program. CBPS 044 says this type must include completed Forms B and C, which are QEM tasks.
Every extension application also needs Commerce's Extension Reporting Tool (CBPS 042), which asks why the extension is needed, what has been done so far, and the plan and pathway to compliance.
Side by side
| Comply by July 1, 2027 | Request an extension | |
|---|---|---|
| Who can use it | Every Tier 2 building | Only buildings with a qualifying reason and documents |
| What you submit | Benchmarking (Forms B and C), EMP, O&M program, both reporting tools, Form A by the QEM | Extension application, Extension Reporting Tool, supporting documents |
| Early adopter incentive | Can be applied for with the compliance application (first-come, not guaranteed) | Commerce's incentive page says compliance and incentive applications must be submitted by July 1, 2027, so an extension may mean missing the incentive. Confirm with Commerce. |
| When it ends | Next report in five years | After two years: a compliance application, an exemption application or a one-time extension renewal |
Example (arithmetic only): on a 25,000 sq ft multifamily building the base incentive estimate is $0.30 × 25,000 = $7,500, if funds remain, the utility participates and Commerce approves. That's the amount at stake if an extension pushes the application past July 1, 2027.
Which is right?
If none of the qualifying reasons apply, an extension isn't an option and the work has to be done by the deadline. If one does apply, weigh two more years against the incentive you may give up, and keep working toward compliance during the extension, as Commerce requires.
Quick answers
Can any Tier 2 owner get an extension?
No. Commerce lists specific reasons (beyond-control events, recent change of ownership, financial restrictions, new construction, or benchmarking complete but more time needed for the EMP and O&M), and the application needs supporting documentation plus the Extension Reporting Tool.
When can I apply for a Tier 2 extension?
No sooner than six months before and up to six months after the compliance date, in the Clean Buildings Portal. For July 1, 2027 that window starts January 1, 2027.
Is an extension a way to comply?
No. Commerce says extensions are not a compliance pathway; they give more time to pursue compliance.
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.