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Setting up ENERGY STAR Portfolio Manager for a Tier 2 filing

Based on WAC 194-50-050 (Section 5.2), Commerce's Tier 2 compliance page and the Portfolio Manager workflow. Checked 31 Oct 2026.

Benchmarking is the step that most often holds up a Tier 2 filing, because it depends on getting data from utilities. Start it first. Washington requires benchmarking in ENERGY STAR Portfolio Manager, the free EPA tool, and your Form C comes straight from it.

What the rule requires

  • At least twelve consecutive months of net energy data for every fuel the building uses, measured within the two years before your compliance date (Section 5.2.1).
  • Portfolio Manager as the energy accounting system (Section 5.2.4).
  • For Tier 2, data at the connected-building level: the whole building, not individual tenant spaces (Section 5.2.1.2).

Step by step

  1. Create a Portfolio Manager account at energystar.gov. Use an account the organisation controls, not someone's personal login, because you will need it every year.
  2. Add the property. Enter the address, year built and gross floor area (excluding parking), then the property use: office, worship facility, multifamily housing and so on. For mixed-use buildings, add each use with its floor area and its operating details (hours, number of workers, number of units).
  3. Add a meter for each fuel. Electricity, natural gas, and anything else such as propane, fuel oil or district steam.
  4. Get the data in. Enter monthly readings from bills, upload a spreadsheet, or ask your utility whether it can send whole-building data to Portfolio Manager automatically. Many larger Washington utilities offer whole-building data for benchmarking; where tenants pay their own bills, this is how you get the total without collecting every tenant's statements.
  5. Check twelve consecutive months for every meter with no gaps or overlaps.
  6. Run the Data Quality Checker and fix anything it flags: missing months, unusually high or low use, estimated readings.
  7. Share the property read-only with Commerce, following Commerce's benchmarking guide (CBPS 027). This is what lets Commerce see your Form C data.

Common hold-ups. Tenant-metered buildings where the utility needs a signed request for aggregated data; buildings that changed hands with no history; propane or oil deliveries with no monthly meter (enter deliveries as they occurred); and floor area in Portfolio Manager that does not match the figure in your Commerce letter. Fix the last one before anything else, because the QEM's target on Form B uses the same floor area.

What you get out of it

Once the data is complete, Portfolio Manager calculates the building's site EUI and weather-normalised site EUI. Those go into your Energy Management Plan's baseline, Form A's summary and Form C, and your QEM compares them with the target on Form B. The plan must be updated with the new figures every year, so keep the account and the utility data feed running after you file.

The Tier 2 Filing Kit includes a benchmarking data sheet: your twelve months laid out the way Portfolio Manager asks for them, with the property details and the sharing steps. Next: Forms A, B and C explained.

Related guides

All Tier 2 guides