Washington Clean Buildings Tier 2: questions owners ask
Short answers about who is covered, the 1 July 2027 deadline, the penalty, the Early Adopter Incentive, the QEM, the extension and what Tier 2 Desk does.
Is my building covered by Tier 2?
Tier 2 covers buildings where the multifamily, non-residential, hotel, motel and dormitory floor area adds up to more than 20,000 and no more than 50,000 gross sq ft, excluding parking, plus multifamily buildings of 50,000 sq ft or more. Commerce mailed notification letters to owners on 1 July 2025; the letter carries your building's Commerce ID. Condominiums count, and for them the owners' association is the building owner.
What is the deadline and what happens if I miss it?
1 July 2027, one date for every Tier 2 building. If you miss it, Commerce issues a notice of violation with at least 30 days to cure. If you don't cure it, the penalty is up to $0.30 per sq ft of gross floor area per compliance period, and you may lose eligibility for the Early Adopter Incentive.
What does Tier 2 actually require?
Benchmarking in ENERGY STAR Portfolio Manager shared with Commerce, an EUI target (Form B), the Portfolio Manager EUI (Form C), an Energy Management Plan, an operations and maintenance program, and a summary form (Form A) signed by the owner, the Qualified Energy Manager and the energy manager. Tier 2 does not require meeting a performance target, an energy audit or a lighting survey.
How much is the incentive and is it guaranteed?
The Early Adopter Incentive is $0.30 per sq ft of gross floor area (a 30,000 sq ft building: $9,000). Multifamily buildings with an anti-displacement agreement can get $0.75 per sq ft or the estimated cost of compliance, whichever is lower. It is not guaranteed: your utility pays it from its public utility tax credit, first come first served, and Commerce says partial and zero payments are possible. Our fee never depends on it.
Who has to sign? Can my property manager be the QEM?
A Qualified Energy Manager (QEM) designated by the owner signs the summary form and submits the application in the Clean Buildings Portal. A property manager or chief engineer can qualify by completing the free Tier 2 training and having two years of experience with commercial building operations or energy management, or BOC Level I. Whether property management counts as building operations is Commerce's call; the owner attests to it.
Does the QEM have to be our employee?
No. WAC 194-50-030 says only that the QEM is an individual designated by the building owner. Since August 2026 a contractually obligated contractor can also act as the owner's authorized representative with Commerce.
Should I just file the two-year extension instead?
You can: an owner who benchmarks by the deadline can request two more years for the Energy Management Plan and O&M program. But the extension does not pay the Early Adopter Incentive, which needs the full package and closes on 1 July 2027. If the incentive is worth more to you than our fee, filing fully now is what captures it.
How long does it take?
The long pole is your utility: getting 12 months of whole-building data into Portfolio Manager takes from 2 days to about 4 weeks depending on the utility. We start those requests the day your deposit lands, and deliver the draft plan and program within 3 weeks of the data arriving. Commerce then reviews applications in the order received.
Do you visit the building?
Usually not. Tier 2 needs no audit or lighting survey, so we build the equipment inventory from nameplate photos and a short video walk-round by your maintenance person. If nobody on site can do that, we quote a local visit separately.
What do I have to do myself?
About two hours in total: fill in the questionnaire, sign the utility data authorizations, photograph equipment nameplates, create your Secure Access Washington account and give our portal user shared access, and sign Form A. We can't create or operate your state accounts for you.
Are you an engineering firm or part of the Department of Commerce?
Neither. Tier 2 Desk is a Jestr company (Duke Security, Inc., Delaware, USA). We prepare the documents and run the project; a Qualified Energy Manager, yours or our partner, reviews, signs and submits. We are not affiliated with or endorsed by the Washington State Department of Commerce.
Is there free help?
Yes, and you should know about it. Commerce publishes free templates and holds office hours, and several utilities run free accelerators or pilots (for example PSE and Seattle City Light, Snohomish PUD, Clark Public Utilities, and the Eastside program for Bellevue, Redmond and Issaquah). They mostly teach owners to do the work themselves or take a limited number of buildings. Commerce's free BEACON fellows have been on hold since 31 March 2026.
Something we didn't answer? matan@jestr.ai