Tier 1 vs Tier 2: how Washington's Clean Buildings tiers differ
Washington's Clean Buildings Performance Standard has two tiers with very different requirements. Which one applies depends on how much of your building is commercial floor area.
Which tier are you?
- Tier 1: buildings where nonresidential, hotel, motel and dormitory floor area together exceed 50,000 sq ft, excluding parking.
- Tier 2: commercial buildings of 20,001 to 50,000 sq ft, and multifamily residential buildings over 20,000 sq ft.
A large apartment building is Tier 2 unless its commercial and hotel space alone exceeds 50,000 sq ft. Federal and tribal buildings are not covered. Check your building.
Side by side
| Tier 1 | Tier 2 | |
|---|---|---|
| Deadline | 1 June 2026 (over 220,000 sq ft), 1 June 2027 (90,001–220,000), 1 June 2028 (50,001–90,000) | 1 July 2027 for all |
| Benchmarking | Yes | Yes |
| Energy Management Plan and O&M Program | Yes | Yes |
| Energy performance | Must meet the EUI target or use an alternative: investment criteria (ASHRAE Level 2 audit and all cost-effective measures), a 15% weather-normalised reduction, or space-heating electrification | Target is set and reported but does not have to be met yet |
| Energy audit | Required on the investment-criteria pathway | Not required |
| Who signs | A Qualified Person; may need a Qualified Energy Auditor | A Qualified Energy Manager |
| Maximum penalty | $5,000 plus $1.50 per sq ft, with continuing daily penalties possible | $0.30 per sq ft per five-year cycle |
| Incentive | Tier 1 Early Adopter Incentive (check eligibility) | $0.30 per sq ft; up to $0.75 for multifamily with an Anti-Displacement Agreement |
What it means in practice
Tier 1 is an engineering project: meeting a performance target can mean audits and capital works, so owners usually hire specialists. Tier 2 is a paperwork-and-practice project: benchmark, write the plan and the maintenance program, and actually run the program. Many Tier 2 owners can do it themselves with their own staff as the QEM.
Tier 2 performance targets are coming: Commerce must adopt them by the end of 2030, effective no earlier than after the 2031 legislative session. How the Tier 2 target works.
The Tier 2 Filing Kit covers Tier 2 only; it does not cover Tier 1 targets or audits.