The Tier 2 Energy Management Plan for apartment buildings
Every multifamily building in Washington over 20,000 square feet is a Tier 2 building, however large it is, and must file an Energy Management Plan, an Operations and Maintenance Program and twelve months of benchmarking by 1 July 2027. This guide covers what the plan must contain and the two things that are different for apartments: the connected-building rule and the enhanced incentive.
What the plan must contain
Section 5 of the standard, as adopted in WAC 194-50-050, lists the contents. In plain terms, for an apartment building:
| Requirement | What it means for an apartment building |
|---|---|
| Energy accounting (5.1.2.1, 5.2) | Twelve consecutive months of whole-building electricity and gas, recorded in ENERGY STAR Portfolio Manager. Tenant meters count: ask your utility for aggregated whole-building data if units are individually metered. |
| Baseline EUI and weather-normalised EUI (5.1.2.2–5.1.2.3) | Portfolio Manager calculates these once the data is in. Record them in the plan and update yearly. |
| Comparison to target (5.1.2.4) | Your QEM sets the EUI target on Form B; the plan compares actual use to it each year. |
| Operating parameters (5.1.2.5) | Number of units, occupancy, common-area hours, laundry and amenity schedules, and any equipment changes since the baseline year. |
| Energy efficiency measures and actions | What has been done (LED common areas, boiler replacement, low-flow fixtures) and what is planned. |
| Occupant information (5.1.3) | Residents must be able to see the plan once a year: a notice in the lobby or on the tenant portal is enough. |
| O&M overview (5.1.2.14) | A summary of the O&M Program and its implementation plan (Annex L). |
| Planning (6.5, 6.6) | How unit turnovers and renovations are handled, and a capital plan that evaluates more-efficient options when boilers, water heaters and lighting are replaced. |
| Lighting schedule and survey (5.1.2.12–13) | Not required for Tier 2. |
The connected-building rule
Tier 2 buildings report at the connected-building level (5.2.1.2). If your complex is several structures joined by enclosed walkways or shared conditioned space, Commerce treats them as one building for benchmarking, and the 20,000 square foot threshold applies to the combined area. Detached buildings on one parcel are assessed separately. Your Commerce letter lists the buildings as Commerce sees them; the portal lets you confirm or correct that.
The O&M Program for apartments
Annex L asks for an inventory of the equipment, systems and controls to be inspected and maintained, with performance criteria; the inspection and maintenance tasks with frequencies and control settings; a list of systems beyond useful life; and records that show the programme is actually being carried out. For a typical mid-size apartment building that means the central boiler or furnaces, domestic hot water, ventilation and exhaust fans, common-area and exterior lighting and their controls, thermostats or building controls, and the envelope (doors, weather-stripping). In-unit equipment the owner maintains belongs in the inventory too.
The enhanced incentive: up to $0.75 per square foot
Every Tier 2 owner who files on time can claim $0.30 per eligible square foot from the $150 million early-adopter fund, first come, first served. Multifamily owners can claim up to $0.75 per square foot, or their actual cost of compliance if lower, by signing Commerce's Anti-Displacement Agreement, a commitment about rents and tenant protections. On a 30,000 square foot building that is $9,000 at the base rate and up to $22,500 with the agreement. The agreement is a legal document with real obligations; read it with your adviser before signing. We do not interpret it.
Full-service vendors often pitch apartment owners a "net zero cost" filing because the enhanced incentive can cover their fee. That can be a sensible choice. The question is whether you would rather pay a vendor $3,750 to $12,000 of that incentive, or $690 for drafts and keep the rest. If your maintenance lead can qualify as your QEM after Commerce's free course, the kit route usually wins.
Timeline that works
- Now: request twelve months of aggregated utility data; set up ENERGY STAR Portfolio Manager; book a staff member on the free Tier 2 training.
- Within a month: order the kit, complete the intake, receive the drafts, start the O&M implementation log.
- Over the following months: run the maintenance tasks and record them. Form A asks the QEM to confirm the programme is implemented, not just written.
- Before 1 June 2027: QEM reviews and signs, upload everything, apply for the incentive in the same session. Early filing closes 1 June; the hard deadline is 1 July 2027.