The Tier 2 Operations & Maintenance Program, explained
The Operations and Maintenance (O&M) Program is one of the two documents every Washington Clean Buildings Tier 2 owner must upload by 1 July 2027, alongside the Energy Management Plan. It is also the one your Qualified Energy Manager must confirm is implemented, not just written, when they sign Form A. This guide sets out what the rule actually requires and what a working program looks like.
Where the requirements come from
Section 6 of the standard, adopted in WAC 194-50-060, says the program must be implemented according to Normative Annex L, adopted in WAC 194-50-130. Commerce offers an optional Excel O&M Program Development Tool (CBPS 040) and requires a separate O&M Reporting Tool (CBPS 023) to be attached to every application. You can use Commerce's tool, your own format or a prepared kit, as long as the content meets Annex L.
What Annex L requires, in plain terms
| Annex L item | What it means in practice |
|---|---|
| L1 Responsibility | The owner is responsible for the program and may name an authorised representative, such as a property manager, to run it. |
| L2 Inventory | A list of the equipment, systems and controls to be inspected and maintained: heating, cooling, ventilation, hot water, controls and thermostats, lighting and lighting controls, envelope items, and anything else that uses energy. |
| L2.2.3 Tasks and control settings | For each item, what is inspected or maintained, including the control settings to verify: setpoints, schedules and sequences. |
| L2.2.4 Frequencies | How often each task happens. After two consecutive unacceptable inspections you investigate the cause; after three consecutive acceptable ones you may reduce the frequency. |
| L2.2.5 Documentation | At minimum: (1) the systems and components with their performance criteria, (2) the tasks and how they are tracked, (3) systems beyond their useful life, and (4) enough written or electronic records to demonstrate the program is being carried out. |
| Section 6.5 Tenant improvements | A process so that tenant fit-outs and renovations are reviewed before work starts. |
| Section 6.6 Replacement equipment | Replacement equipment and lighting must meet code efficiency, and more efficient options are evaluated in your capital planning. |
The part owners miss. Form A asks your QEM to confirm the O&M requirements of Section 6 have been met. A well-formatted plan with no inspection records is not an implemented program. Start the log the week the program is written and keep the evidence: work orders, contractor invoices, checklists, photos.
A template outline that meets Annex L
Whatever format you use, a Tier 2 O&M Program usually has two parts: a short document that explains the program, and a workbook that holds the detail.
The document
- Purpose and scope: the building, the systems covered, the owner and any authorised representative.
- Roles: who inspects and maintains (staff, contractors), who keeps records, who reviews.
- Inventory summary, pointing to the workbook.
- Inspection and maintenance approach, including the two-unacceptable and three-acceptable frequency rule.
- Record keeping: where the log lives and what counts as evidence.
- Systems beyond useful life and the intended action for each.
- Tenant improvements and equipment replacement process.
- Emergency information: shut-offs, utility emergency lines, after-hours contractor numbers.
- Annual program review and what triggers an earlier one (a change of use, new equipment, a system that cannot meet its criteria).
The workbook
| Sheet | Example row |
|---|---|
| Inventory | H-01 · Heating · Gas boiler, 1 unit, plant room, 18 years · Criteria: supply 180°F, no leaks, combustion test in range · Maintained by contractor |
| Tasks | H-01 · Combustion test and burner clean · Annual · Verify setpoint and outdoor reset curve · Acceptable: efficiency within manufacturer range |
| Implementation log | Date · H-01 · Combustion test · Acceptable · 82% · Acme Mechanical · Invoice 1043 |
| Beyond useful life | H-01 · Past 15-year typical life · Replace with high-efficiency unit · Target 2029 |
How it connects to the rest of the filing
The Energy Management Plan summarises the O&M Program in its O&M section, and the CBPS 023 Reporting Tool asks yes/no questions that map to each Annex L item, so answers must match what the program says. Your QEM reviews all three together before signing. See the full Tier 2 filing checklist for the order of steps.
The Tier 2 Filing Kit drafts the O&M document and a pre-filled workbook from your intake answers, with a 12-month implementation log ready to start. Check whether your building is Tier 2 first if you are unsure.