Building Performance Standards

Building performance standards (BPS) are energy or emissions targets that existing buildings must meet over time to improve energy efficiency and reduce climate impacts. Washington State's new energy performance standards are an important start, but will not be enough to move Seattle's buildings to a clean energy futureIn 2021, Mayor Durkan issued a Climate Executive Order directing OSE to create legislation for carbon-based BPS for existing buildings.  

Why Clean Buildings Matter

Burning fossil fuels like gas and oil for heating, hot water, appliances, and cooking in Seattle's existing commercial and multifamily buildings accounts for over 90 percent of all building related greenhouse gas emissions (see dashboard). These polluting emissions degrade outdoor air quality and accelerate climate change, which disproportionately harms Black, Indigenous, and people of color, people living in poverty as well as children and seniors. According to a recent study from the Harvard T.H. Chan School of Public Health, fossil fuel use in buildings is responsible for thousands of early deaths and hundreds of billions of dollars' worth of annual health impacts. Continuing to power our buildings with gas and other fossil fuels is an issue of climate justice as explained in this OSE infographic.

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Why Building Performance Standards

The 2018 Climate Action Strategy calls for Seattle-specific Building Performance Standards (BPS) to reduce emissions by transitioning commercial and multifamily buildings to use cleaner electricity instead of gas or oil. And in 2021, during the COP26 Climate Summit, Mayor Durkan issued a Climate Executive Order directing OSE to accelerate action toward net zero emission buildings, healthy and equitable transportation, and clean energy workforce development to advance climate justice. In the buildings sector, the Climate Action Executive Order will:

  • Direct OSE to create legislation for carbon-based BPS for existing commercial and multifamily buildings 20,000 sq ft or larger in 2022. 
  • Prohibit fossil fuels in City-owned buildings by 2035 to continue Seattle leading by example.
  • Provide options to lower upfront and operating costs for affordable housing to address the climate crisis and improve resilience as we build, operate, and maintain affordable housing.

A Seattle BPS approach will complement the Washington State energy performance standards and build on the City's existing Energy Benchmarking and Tune-Up programs. Although the State energy performance standards are an important start, OSE projects they will only result in about a 4% reduction by 2030 in meeting the City's 2050 carbon-neutral goal, whereas Seattle-specific GHG emissions standards for larger buildings could result in up to a 27% decrease (see image below).

Wedge diagram that shows the projected impact of various building energy policies on GHG emissions.

Performance standards, phased in over time, provide flexibility for building owners to choose the technologies or operational strategies that are most cost-effective for them to meet the targets. Upgrading existing commercial and multifamily buildings to be more energy efficient and to reduce climate pollution makes them healthier for people and the environment. And Seattle City Light's carbon-neutral electricity can provide the energy needed for heat pumps and other systems that replace fossil-fuel fired equipment. Building improvements also create local, well-paying jobs at all levels from building trades professionals like electricians and plumbers to building operations engineers. Other cities with building performance standards include New York City, St. Louis, Washington DC, Boston and Chula Vista, CA and many more jurisdictions currently have policies under development. 

Stakeholder Process

Developing a successful Seattle BPS policy that builds on the State energy standards and establishes climate pollution standards will require understanding and offering solutions to meet the challenges - technical, financial, operational, or otherwise - that building owners, managers, and tenants may face in making upgrades. In doing so, Seattle will join a growing cohort of other leading cities that have worked with local buildings stakeholders and community members to establish both energy and GHG emissions performance standards. Beginning in late 2021 and through 2022, the City of Seattle will be conducting an inclusive engagement process to help develop an equitable and effective policy. We are committed to a collaborative effort to maximize benefits to building owners and tenants and to ensure equitable pathways to high quality green jobs, especially for people of color and women.

Washington State Energy Performance Standards

The Clean Buildings for Washington law (HB 1257), being implemented by the Washington State Department of Commerce, applies to all commercial buildings larger than 50,000 SF. The law includes several requirements to improve energy efficiency including meeting a minimum average energy use intensity target (EUIt) for the space uses in building.1 All building owners and managers should start planning now to comply, and can use the law as a catalyst to join the emerging commercial real estate industry shift to all-electric assets.

OSE estimates that nearly 1,000 Seattle buildings will need to comply and at least 1/3 will need energy efficiency improvements to meet the State EUIt.

What Does the State Law Require?

Owners of commercial buildings 50,000 SF and greater need to comply with steps 1-4 (below) and show that their building meets the EUI target (EUIt). Buildings with EUIs that exceed the EUIt will also need energy saving upgrades to reduce the EUI to meet the target, per step 5. Some buildings, such as campus buildings without separate energy meters or unique mixes of uses, will not be able to calculate an EUIt, and must also complete step 5.

  1. Benchmark and have a qualified person2 calculate the building's EUIt.
  2. Designate an individual as energy manager for the building.
  3. Develop and adopt an energy management plan.
  4. Develop and implement an operation and maintenance (O&M) program.
    • Note: Please read the Building Tune-Ups FAQ for questions about how the O&M program aligns with the Seattle Building Tune-Up requirements.
  5. Meet EUIt (if not already meeting or cannot calculate EUIt) by following the Investment Criteria process outlined in WAC 194-50 to identify and implement cost-effective energy efficiency measures.

What is the Timeline for Compliance?

Building owners will need to demonstrate that: 1) the O&M program has been implemented in their building, 2) the energy management plan is complete, and 3) that their building's weather normalized EUI is less than or equal to the building's EUIt for a minimum of 12 months before the compliance dates listed below. This means that the largest buildings need to be ready by June 2025! 

Graphic summarizing number of buildings required to comply with state CBPS policy by size

  • June 1, 2026 - Buildings >220,000 SF
  • June 1, 2027 - Buildings between 90,000 and 220,000 SF
  • June 1, 2028 - Buildings between 50,000 and 90,000 SF  

In mid-October 2021, the State mailed notification letters to owners of buildings that likely need to comply, based on Assessor information. If your building is already required to meet Seattle's Building Tune-Ups requirement, it likely needs to meet this new State law as well. They have also created an online Clean Buildings Portal for compliance and buildings may begin reporting starting July 1, 2023. The notification letters have a unique code needed to access the Portal. If you do not receive a letter by November, have a building you don't think needs to comply, or have another question, please visit the State's Clean Buildings Portal webpage for instructions.

What Help is Available?

Early Adopter Incentives - Reserve Yours Now!

The State has launched an Early Adopter Incentive program of $0.85 per SF for early adopters whose buildings are currently 15 EUI points above the EUI targets, and who make improvements to achieve the target before the deadlines. The total pool of incentive dollars to support early compliance is $75 million state-wide. Multifamily buildings are voluntarily eligible for this incentive if they commit to meeting the state target. The State also has an Equitable and Inclusive Early Adopter Incentive Plan that reserves some of the incentives for buildings that meet at least one of the following criteria: highest energy user, located in rural community, multifamily affordable housing, or in an area with significant environmental health disparities. Visit the link below to learn more and to reserve a spot now.

OSE projects that about 150 Seattle buildings may be eligible for the incentive, based on their estimated EUIt, and most of those (about 85%) may meet the equity criteria.

More Resources

Seattle City Light and/or other utility incentives and rebates can assist you with certain upgrades. Furthermore, City Light's Lighting Design Lab offers trainings and recorded sessions on energy-efficient electric technologies, such heat pumps and lighting that will both meet the Seattle Energy Code and could support owners meeting the State standards.

OSE and City Light are seeking funding to offer an equity aligned Seattle Clean Buildings Accelerator starting in 2022 with a goal of supporting under-resourced building owners that have less capacity to comply with the state requirements and may need additional support for reducing building emissions. This may include coaching, resources, and support to meet the law, obtain incentives and get started on a path towards reducing emissions and building electrification. Updates will be posted here. If you have suggestions for what could help support you, please email

  • Owner/Manager Survey: Seattle City Light and OSE are collecting feedback on building owner/manager readiness to comply with the Washington State Clean Buildings Act and what kind of program or resources you think the City of Seattle should offer to help with compliance. Please take a quick anonymous survey here >

City of Seattle Resources

  • Seattle City Light FAQ - More about SCL's Early Adopter Incentive role and other conservation incentives.
  • List of OSE Projected EUI Targets by Building - Buildings that have submitted benchmarking data can look up their projected EUIt (for planning purposes only - not to be used for compliance).
  • EUIt Calculator (Coming soon!) - Facilities managers or service providers that understand Portfolio Manager and benchmarking data can estimate a building's EUIt using this spreadsheet tool (for planning purposes only - not to be used for compliance).
  • City Light Lighting Design Lab - Webinars and recordings on a host of energy-efficient and code-compliant electric technologies like heat pumps for commercial and large multifamily buildings.

WA State Resources

Case Studies & Fact Sheets 

Utility Incentives   

  • City Light Commercial Retrofit Incentives - From lighting and windows to existing building commissioning, energy efficiency programs can help owners meet the State targets and can be paired with the State early adopter program for eligible buildings.
  • PSE Commercial Retrofit Incentives - Puget Sound Energy (PSE) customers are eligible for a variety of commercial gas incentives, including strategic energy management.

Financing Highlights 


1 - Energy Use Intensity (EUI) is measured in annual energy use per square foot of building area (kBtu/SF/year). The EUIt will be based on the mix of building uses (e.g. office, retail, hospital, etc.) and the building's weather normalized EUI will be used to determine if the building meets or exceeds (is greater than) the EUI target (EUIt).
2 - Per WAC 194-50-30, Section 3 Definitions, a Qualified Person is: "a person having training, expertise, and three years professional experience in building energy use analysis, and being any of the following: 1. A licensed professional architect or engineer in the jurisdiction where the project is located;  2. A person with Building Operator Certification (BOC) Level II by the Northwest Energy Efficiency Council;  3. A certified commissioning professional; 4. A qualified energy auditor; 5. A certified energy manager (CEM) in current standing, certified by the Association of Energy Engineers (AEE); 6. An energy management professional (EMP) certified by the Energy Management Association." Review the complete standards for official compliance information.