The Tier 2 two-year extension: what it does and what it costs you
Since 21 August 2026, a Tier 2 owner who complies with the benchmarking requirements can get a two-year extension for the Energy Management Plan and O&M program (WAC 194-50-160, Y3.2). Requests run from 1 January 2027 to 1 January 2028. The extension does not pay the Early Adopter Incentive.
What it does and doesn't do
| Question | Extension (benchmarking only) | Full filing by 1 Jul 2027 |
|---|---|---|
| Avoids the penalty in 2027 | Yes, if granted | Yes |
| Early Adopter Incentive | No: it needs the full package, applications close 1 Jul 2027 | Yes, $0.30 per sq ft if approved and the utility's credit allows |
| Work now | Portfolio Manager benchmarking and the request | Benchmarking, EMP, O&M program, Forms A/B/C |
| Work later | The EMP and O&M program, by 2029 | Keep the plan maintained; report every five years |
| Cost with us | $750 starter | $3,900 or $2,400 |
The other extensions
Every extension under the 2026 rule is for two years and is requested between six months before and six months after the compliance date. Besides benchmarking, they cover: circumstances beyond the owner's control (a declared disaster, a shortage of goods or services); a change of ownership by arm's-length purchase within 12 months before the date; financial restrictions on the hardship list; and new construction affecting 10% or more of the floor area.
When the extension is the right call
- Your building's incentive is small, or your utility is likely to pay little or nothing.
- You plan to sell or substantially renovate within two years.
- Your equipment records are a mess and you'd rather fix them before writing the O&M program.
Otherwise filing fully now costs about the same work later, and only filing now captures the incentive. Benchmarking is half of either path, so our $750 starter is credited in full if you upgrade before the deadline.