This is the second article in our series covering the continuously developing and expanding Building Performance Standard compliance environment. We will be looking at the Pacific region, including jurisdictions within California, Nevada, Oregon, Utah, and Washington.
All jurisdictions require energy benchmarking, and many require water benchmarking as well. In addition to benchmarking, jurisdictions have chosen to require up to 10 different compliance mechanisms. While some are similar, no two jurisdictions are identical. We’ll be exploring each below.
California Building Performance Standards
Berkeley, CA – Building Energy Saving Ordinance (BESO)
This policy addresses commercial and multifamily buildings greater than 25,000 sqft. This standard is unique in that it also covers all residential buildings with one to four attached units. Within this, there are three major requirements: annual benchmarking, an energy assessment, and a resilience standard.
- Annual benchmarking is required for all buildings larger than 15,000 sqft
- ASHRAE Level I or II Building Audits are required at the time of listing for all residential, multifamily, and commercial buildings up to 25,000 sqft
- Buildings larger than 25,000 sqft must also complete a building assessment every 5 years.
The resilience standard requires building buyers and sellers to implement projects that sum up to 6 “credits”, or they may be able to install a heat pump and satisfy the requirements.
To help ensure compliance, the buyer and seller must put down a $2,500 deposit, for a total of $5,000, which is forfeited if the buyer does not upgrade systems within two years of purchase.
Residential buildings must disclose their current Home Energy Score. Commercial and multifamily buildings must disclose the most current energy assessment, energy score, fuel source, and compliance documents to existing tenants, prospective tenants, and all prospective buyers.
Chula Vista, CA – Building Energy Saving Ordinance (BESO)
This BPS has a focus on commercial, industrial, and multifamily real estate 20,000 sq. ft. and larger. Beginning in 2026, buildings must achieve a minimum Energy Star score, or Energy Use Intensity (EUI) improvement of between 10% and 30%, depending on their original base year consumption of 2022.
If the building does not meet the reduction requirement, it must undergo:
- ASHRAE Level II Energy audit
- Buildings with over 50,000 sqft must also complete a retrocommissioning study
By 2031, building owners must implement all energy-saving opportunities identified during their audit with a payback period of less than 13 years.
Los Angeles, CA – Existing Buildings Energy and Water Efficiency (EBEWE)
The first compliance cycle finished in December of 2025; however, the second has just begun. All commercial and multifamily buildings over 20,000 sqft must comply.
EBEWE Compliance Requirements:
- ASHRAE Level II Energy audit and retrocommissioning completed by a California Licensed Professional Engineer or Architect
- Water audit and retrocommissioning completed by a California Licensed Professional Engineer or Architect
Compliance Schedule:
- December 1, 2026: LADBS ID “0” or “1”
- December 1, 2027: LADBS ID “2” or “3”
- December 1, 2028: LADBS ID “4” or “5”
- December 1, 2029: LADBS ID “6” or “7”
- December 1, 2030: LADBS ID “8” or “9”
San Francisco, CA – The Existing Buildings Energy Ordinance
If you own or manage a commercial or public building over 10,000 square feet. Depending on the square footage of your building, you may need to comply between 2026 and 2028. The first compliance deadline is quickly approaching on April 1st, 2026, for non-residential buildings greater than 50,000 square feet.
There are three different pathways to comply:
- ASHRAE Level II Building Audit
- Retrocommissioning
- Strategic Decarbonization Plan
- Buildings over 50,000 sqft are also required to utilize 100% renewable energy on-site
San Jose, CA – Energy and Water Building Performance Ordinance (EWBPO)
San Jose has both energy and water use intensity standards. Failing to meet one will trigger an audit for both. The compliance deadlines are split into two tiers based on square footage: buildings larger than 50,000 square feet vs. those between 25,000 and 49,999 square feet. Similar to Los Angeles’s EBEWE, this standard’s compliance date is based on the last digit of the building’s assessor’s parcel number. This standard’s first compliance deadline was 2023. This year, APNs ending in 6 and 7 are required to comply by May 1st.
This cycle repeats every 5 years, so all buildings will need to either achieve their energy and water performance metrics, improve by 15% from the last cycle, or perform an ASHRAE Level II Building Audit or retrocommissioning study by 2030.
Reno, NV – Energy and Water Efficiency Program, under ReEnergize Reno
Commercial and multifamily buildings over 30,000 sqft in Reno must comply with this standard. Buildings that did not meet their performance target must conduct either an ASHRAE Level II Energy and Water Audit or a building retrofit. Compliance deadlines for commercial and multifamily buildings begin in 2028 and repeat every seven years.
Salt Lake City, UT – Commercial Building Benchmarking and Market Transparency Ordinance
Public facilities over 3,000 square feet and commercial and multifamily buildings over 25,000 square feet must benchmark their energy and water consumption. Low-performing buildings, with an Energy Star Score of 49 or less, must conduct a retrocommissioning study every five years. The study must be performed by a qualified energy professional, and any cost-effective measure must be implemented within two years of the study.
Seattle, Washington – Building Energy Performance Standard (BEPS)
In addition to having to comply with the State of Washington’s Clean Building Performance Standard, buildings in Seattle over 20,000 sqft must also comply with the city’s BEPS.
Adding to the complexity of compliance, Washington requires an energy reduction, while Seattle requires a carbon reduction. While these metrics can be correlated, they are not automatically aligned.
Depending on the size of your building, between 2027-2030, BEPS requires a Qualified Person to create and submit a Greenhouse Gas Report. In addition, utility benchmarking and third-party data verification will be required to ensure data and target reduction accuracy.
This plan must document the current state of emissions, the upcoming emissions targets for each specific building, and the plan for how the building will be brought into compliance.
While capital planning is crucial to all building performance standards, it is especially vital to comply with Seattle’s BEPS. Projects designed to comply with Washington’s standard may not be enough to meet Seattle’s. With the highest penalties in the country, a combined $3.5/sqft, getting the equipment type, timing, and fuel source right the first time will avoid costly fines and premature removal of newly placed equipment.
Oregon Statewide – Energy Performance Standards
There are five compliance dates spread across two tiers, based on square footage and building type. Tier 1 buildings are generally non-residential, or temporary residential, like hotels or motels, greater than 35,000 sqft. Tier 2 buildings include non-residential buildings between 20,000 and 34,999 sqft, as well as any multifamily and other longer-term residential-style buildings larger than 35,000 sqft.
Both tiers must complete an application for their building(s), determine the Energy Use Intensity Target (EUIt), and calculate the building(s) current EUI.
Tier 1 buildings must additionally implement and submit an operations and maintenance program (O&M) as well as an Energy Management Plan (EMP). Grouped buildings with district systems must also create a Decarbonization Plan.
Washington Statewide – Clean Building Performance Standard
The Clean Buildings Performance Standards (CBPS) policy covers commercial buildings over 20,000 sqft and multifamily buildings over 50,000 sqft statewide. The compliance timeline for the next three years has been broken down into a tiered system based on building size and between commercial and multifamily buildings.
Washington’s CBPS is one of, if not the most, comprehensive programs, requiring:
- Energy Management Plan
- Operations and Maintenance Program
- Energy Use Intensity (kbtu/sqft) Reduction
- Ongoing compliance, program and plan implementation, and registration of a Qualified Energy Manager or Qualified Person
These requirements may apply to your buildings starting at 20,000 square feet for commercial, and 50,000 sqft for multifamily buildings. The exact compliance date will depend on your building’s square footage; however, all buildings will complete their first compliance cycle before June 1st, 2028.
That date is a bit misleading, however, as the Energy Management Plan and Operations and Maintenance Program must be implemented for 12 months before the compliance date.
That means for buildings 220,000 square feet and larger, it isn’t possible to comply fully at this point. Luckily, you can file for conditional compliance and provide more time to implement these programs and later energy-saving measures.
Try Firefly to Navigate Evolving Building Performance Standards
These standards are complex, continuously expanding, and changing. If you are a building owner or property manager needing to comply with one or more of these standards, reach out for a complimentary risk assessment. At Firefly Building Performance, we understand that each building and jurisdiction requirement is unique. Each situation requires a customized approach to achieve compliance. Firefly stands ready to assist throughout the process, from data collection to project implementation.
