The Tier 2 energy-use intensity target, in plain English
Every Tier 2 filing reports two numbers that sound alike: the building's EUI and its EUI target, or EUIt. Owners often worry they have to hit the target to comply. For Tier 2, today, you do not. You do have to set it correctly, and it will matter in the future.
EUI: what the building actually uses
Energy use intensity is the building's total annual site energy divided by its gross floor area, expressed in thousand British thermal units per square foot per year (kBtu/sq ft/yr). Portfolio Manager calculates it from your twelve months of utility data, along with a weather-normalised version that adjusts for an unusually hot or cold year. Lower is better.
EUIt: what a building like yours is expected to use
The target comes from Washington's version of ASHRAE Standard 100. The Qualified Energy Manager sets it on Form B:
- Activity type. Choose the building activity from the standard's definitions (Table 7-4): office, worship, retail, warehouse, multifamily and so on.
- Base target. Look up the target for that activity in Table 7-2a.
- Hours adjustment. Where allowed, apply the shift normalisation factor from Table 7-3 for buildings used for more or fewer hours than typical.
- Mixed use. Where a building has several activities, combine the targets in proportion to floor area.
Commerce publishes a pre-calculator (CBPS 019) that does the arithmetic. If a building cannot develop a target this way, for example because no activity type fits, it reports the Portfolio Manager national median site EUI for its property type instead.
Do I have to meet it?
No. Commerce states that Tier 2 buildings are "not required to meet a performance target at this time." Tier 2 compliance today means benchmarking, an Energy Management Plan and an O&M Program. Your plan must compare actual EUI with the target each year, but being above it is not a violation.
Why it still matters
- Future performance rules. Commerce must adopt Tier 2 performance rules by 31 December 2030; they cannot take effect before the end of the 2031 legislative session. The gap between your EUI and EUIt today shows how much work you might face then.
- Your plan's priorities. A building well above target has the clearest case for the efficiency measures in its Energy Management Plan.
- Tier 1 comparison. Larger Tier 1 buildings already have to meet the target or use an alternative pathway. See how the tiers differ.
Getting it right
The two common mistakes are a floor area that does not match Portfolio Manager and the Commerce letter, and the wrong activity type for a mixed-use building. Agree both with your QEM before they complete Form B. More on Form B. The Tier 2 Filing Kit records your activity breakdown and floor areas so the QEM can complete Form B in minutes.