Save Energy

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PLEASE READ ALL BPS-RELATED COMMUNICATIONS CAREFULLY

• For an overview of BPS, please see BPS 000 – BPS Basics.
• Track ongoing BPS rules development by accessing BPS Rulemaking. Participate in this development by checking BPS Stakeholder Engagement for key administrative rule dates, public meetings, and comment opportunities.
  
• ​Compliance dates for large commercial buildings are being phased in over time based on building type and size, as shown in the graphic below.
  

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Step 1. Check the Property Inventory List

ODOE gathered information about commercial buildings from county tax records to determine which buildings are covered by the standard. These records may be out of date, incorrect, or missing key pieces of information. Building owners are needed to help ODOE determine the accuracy of the information collected about their buildings.

ODOE sent letters to commercial building owners notifying them that their building may be subject to Oregon BPS, and asking them to verify key information, like their building's square footage. It's helpful if building owners check the Property Inventory List for all their buildings, even if they didn't receive a letter for a building. This helps ODOE confirm which buildings are covered by Oregon BPS.

To review building data in the Oregon BPS Property Inventory List, follow the steps below:

• Go to the Oregon BPS Property Inventory List (PIL) .

• If this is your first visit to the PIL, register to create an account.
• Log in to your PIL account.
• Look up your Oregon buildings one at a time. If you received letters in the mail for any buildings, enter the building address or UBID number from that letter. If not, simply enter addresses for your buildings.
• Confirm that building ownership details, square footage, property address, and property type are correct, and if not, request that corrections be made.
• If you own additional buildings in Oregon that you can't find in the PIL, especially any at least 20,000 square feet, contact Oregon BPS so we can add it.

For more help using the Property Inventory List, watch this PIL Tutorial Video .​


Step 2. Determine Oregon BPS Status

Buildings covered by Oregon BPS fall into two tiers, as shown here.


Tier 1 and Tier 2 Buildings 

Buildings covered by Oregon BPS fall into two tiers, as shown in the visual above. The table below lists the property type and gross floor area of the two building tiers, and gives their compliance dates. Note that the gross floor area does not include any parking garage area.

Property Type​	Gross Floor Area, ft2	Tier / Compliance Date
Nonresidential, Hotel, or Motel	35,000 ft2 to 90,000 ft2	Tier 1 / June 1, 2030
Nonresidential, Hotel, or Motel	90,000 ft2 to 200,000 ft2	Tier 1 / June 1, 2029
Nonresidential, Hotel, or Motel	200,000 ft2​​ and greater	Tier 1 / June 1, 2028​
Nonresidential, Hotel, or Motel	20,000 ft2 to 35,000 ft2	Tier 2 / July 1, 2028
Multifamily Residential, Hospital, School, University, Dormitory, Barracks, Prison, Residential/Senior Care Facility	35,000 ft2 and greater	Tier 2 / July 1, 2028

 

The table above lays out “regular" Tier 2 buildings (nonresidential, hotel or motel buildings from at least 20,000 to 35,000 square feet) and “special" Tier 2 buildings (multifamily, hospital, school, university, dormitory, barracks, prison or residential/senior care facility of at least 35,000 square feet). Note that there are also “extended" Tier 2 buildings. Buildings in the same complex as a “special" Tier 2 building, and that share the same primary function, may be eligible for “extended" Tier 2 status.

There are some mixed-use buildings whose tier isn’t so straightforward to determine. These buildings should use the OR BPS EUI Target Tool to find their tier, which applies a 50% threshold based on the tier definitions. ​


Tier 2 buildings must benchmark their energy use, so their total annual energy use intensity (energy use per square foot) is calculated and compared to an energy target for buildings with similar activity type.

Tier 1 buildings must benchmark their energy use by calculating energy use intensity and comparing it to an energy target, just like Tier 2 buildings. Tier 1 buildings must also document their operations and maintenance programs and energy management plans . In addition, Tier 1 buildings with energy use exceeding their energy target must undertake a process of reducing their energy use, including performing audits and implementing energy efficiency measures. The guidance document BPS 001 – Tier 1 and Tier 2 Compliance explains Tier 1 and Tier 2 distinctions and program requirements in more depth.

Compliance dates may seem a long way off, but work should start right away to comply with BPS, especially for Tier 1 buildings.  If Tier 1 buildings don't meet their energy target, they need to let BPS know at least 180 days before their compliance date. They also need to complete an energy audit before their compliance date.

There are some incentives available for early compliance, for buildings that complete tasks at least a year before their compliance date. See BPS 010- Incentives and Penalties, as well as Step 3. Incentives and Penalties below.  



Grouped Buildings 


Some Tier 1 and Tier 2 buildings share energy metering with one or more buildings, either through a common electrical or natural gas meter, or because they belong to the same district heating or cooling system. Tier 1 and Tier 2 buildings with shared metering still need to comply with BPS, but they must report as a set of grouped buildings.

Other sets of buildings may also apply as a group if they're part of the same complex, even if they don't share metering. This can be done for various reasons:

• If the complex includes a building with “special" Tier 2 status (a multifamily, hospital, school, university, dormitory, barracks, prison or residential/senior care facility of at least 35,000 square feet), applying as a group may allow extended Tier 2 status for other buildings in the group
• To reduce the amount of paperwork required for compliance

For specifics about BPS requirements for grouped buildings, see the guidance document BPS 009 – Grouped Buildings or Campuses.​



Exemptions and Historic Buildings 

Tier 1 and Tier 2 buildings may be eligible for exemptions for manufacturing/industrial and agricultural buildings, as well as for buildings without an occupancy certificate, with high vacancy rates, or for those under financial hardship. Applications for an exemption from BPS must be made at least 180 days before a building's compliance date. Exemption applications are reviewed by BPS staff, who will then let the building owner know whether that application has been approved or denied.  

Historic buildings are not exempt, but are not required to implement measures that would harm their historic integrity. However, buildings must file an application to qualify as historic. There is no deadline for submitting a historic building application.

In addition, many federally and tribally owned buildings are not subject to any provisions of BPS, although they may participate voluntarily.

Applications for exemptions and historic buildings will be available by early 2026.

For more details, see the guidance documents BPS 002 – Exemptions and Historic Buildings and BPS 011 – Federal and Tribal Buildings.​

Step 3. Incentives and Penalties

ODOE is now accepting incentive applications for the Early Compliance Action and Planning Program (ECAPP).​





Oregon House Bill 3409 directs the Oregon Department of Energy to establish an early compliance incentive program. $2 million in state funding has been allocated to this program to help building owners offset costs associated with compliance, such as energy benchmarking and reporting or performing an energy audit. 





Tier 1 and Tier 2 building owners may receive an incentive of up to $0.85 per square foot of gross floor area with caps of $10,000-$50,000 per building based on building type and size. 





Final rules were filed with the Secretary of State on August 5, 2025, establishing the Oregon Building Performance Standards Incentive Program. Please see the ODOE BPS Incentive Program rulemaking webpage​ for more information. 




$12 million in funds for BPS compliance has been obtained through a federal Climate Equity and Resilience Through Action (CERTA) grant. The Building Emissions/Energy Reduction Incentive (BERI) programs under development. Incentives are geared towards offsetting the implementation costs of energy efficiency measures. Funds are expected to be disbursed in stages with the application period for the first installment expected to open in early 2026. 

Please see BPS 010 – Incentives and Penalties for more information. 

Step 4. Gather Building Information

Tier 1 and Tier 2 buildings that are covered by Oregon BPS need to determine their energy use and compare it to buildings with similar activity types. This process starts by gathering all the information that's needed:

• Drawings or schematics showing the square footage of building areas with different tenants or activity types
• A summary of all the building's energy metering (electricity, natural gas, district heating or cooling) or energy deliveries (propane, other fuels), and which areas of the building each meter or delivery serves.
• All energy bills for at least 12 consecutive months within the 24 month period before reporting to Oregon BPS.

Getting billing data may be tricky for buildings with tenants who pay their own energy bills. Owners can ask tenants for their bills, or ask them to sign a utility release form that gives them access to tenant energy use information.

Owners may also be able to ask utilities to add together energy use data from multiple tenants. Large Oregon utilities (PGE, Pacific Power (PacifiCorp), EWEB, Avista, Cascade Natural Gas and/or NW Natural) are required to aggregate data for multifamily buildings with five or more tenants, and for non-residential buildings with three or more tenants. ​


More thoughts about gathering building information are included in the guidance documents BPS 003 - Finding Energy Use Intensity Target and BPS 004 – Calculating Energy Use Intensity. 


Step 5. Identify Energy Professionals

Required for Tier 1 and Tier 2 Buildings 

Different types of energy professionals are required to do certain tasks under Oregon BPS:

• Qualified Energy Manager (QEM) can benchmark Tier 2 buildings
• Qualified Person (QP) can benchmark Tier 1 or Tier 2 buildings, is responsible for reviewing Tier 1 O&M and EMP documents, and may need to oversee work to improve building energy efficiency in Tier 1 buildings
• Qualified Energy Auditor (QEA) can audit and perform life cycle cost assessments in Tier 1 buildings

These professionals need to meet different requirements for experience, licenses and certifications, and must submit their qualifications to Oregon BPS before performing tasks.

Please see the guidance document BPS 006 - Energy Professionals for information about requirements. Interested energy professionals can download, fill out, and submit Form Q: Energy Professional Qualifications. There are also listings of Oregon BPS Energy Professionals who have submitted their qualifications to perform Oregon BPS tasks. 


Step 6. Determine Energy Use Intensity Target (EUIt)

Required for Tier 1 and Tier 2 Buildings 


The Energy Use Intensity Target (EUIt), or energy target, represents the maximum amount of energy a building should consume, in units of kBtu per square foot per year.

A set of Oregon EUIt values was derived for different building types from local, regional, and national commercial buildings, adjusted to reflect Oregon weather.

A reference set of operating factors was also derived for each building activity type. The operating factor represents how differences in weekly operating hours affect building energy use.

The reference EUIt values and operating factors are used to find a specific energy target for each Oregon building. A building's energy target (EUIt) is compared to each building's weather-normalized energy use (WN-EUI) to see how efficient the building is. For Tier 2 buildings, this is useful information that gives building owners an idea about how well their building performs. For Tier 1 buildings, the energy target determines whether a building must undergo more work to reduce its energy use.

Please refer to the guidance document BPS 003 - Finding Energy Use Intensity Target for more detailed information about the derivation of EUIt . The QEM or QP should download and use the Oregon BPS EUI Target Tool, an Excel-based spreadsheet tool, to determine EUIt.


Step 7. Calculate Energy Use Intensity Target (EUI)

Required for Tier 1 and Tier 2 Buildings 


The Energy Use Intensity (EUI) is a measurement of a building's energy use relative to its size, given in units of kBtu per square foot per year.

EUI is calculated for Oregon BPS Tier 1 and Tier 2 buildings from 12 consecutive months of energy use data, taken from any of the 24 months before the reporting date. EUI is found from a total year of energy use divided by the building's Gross Floor Area. This value is then adjusted to from actual weather conditions to obtain a weather normalized value, WN-EUI, that is compared to the building's Energy Use Intensity Target (EUIt).

WN-EUI calculations are done in Energy Star Portfolio Manager (ESPM), a free online energy tracking tool developed and maintained by the US Environmental Protection Agency. This tool uses information about the building's location, square footage, energy metering, and energy use to automatically calculate WN-EUI. 


ESPM can also find the WN-EUI for a set of grouped buildings.

Please refer to BPS 004 - Calculating Energy Use Intensity​ for more specific information about EUI calculations for Oregon BPS, and to the ESP​M Website​ for information about how to set up and use Energy Star Portfolio Manager.


Step 8. Document O&M and EMP

​Required for Tier 1 Buildings 


Tier 1 buildings must report to Oregon BPS about their Operations and Maintenance program and Energy Management Plan.

An Operations and Maintenance program documents routine work done to run the building and look after it, including the envelope/windows, HVAC equipment, lighting, water heating equipment, and other energy-using systems of the building.

An Energy Management Plan records longer-term goals for reducing building energy use. It lists all building systems and equipment and their expected life, lays out a replacement schedule, and identifies more efficient equipment to install upon replacement.

The Qualified Person for each Tier 1 building must review the building's O&M and EMP records, fill out the Oregon BPS O&M and EMP Checklist (coming soon) confirming this work meets all requirements, and make sure these documents are available for review by Oregon BPS upon request.

Oregon BPS has also developed a spreadsheet tool, the Oregon BPS O&M and EMP Tool​, to help facilities carry out and track all their O&M and EMP responsibilities.

More information can be found in the guidance documents BPS 007 - Operations and Maintenance Programs and BPS​ 008 - Energy Management Plans.​


Step 9. Perform Energy Audit with Optional LCCA

​Required for Tier 1 Buildings with EUI > EUIt 

For Tier 1 buildings, it's important to compare EUI and EUIt as soon as possible.  If the building does not look like it will meet its Energy Use Intensity target (EUIt) before its compliance date, the following must be done:

• EUI and EUIt must be reported to BPS at least 180 days before the building's compliance date
• An energy audit and an optional Life Cycle Cost Assessment must be completed before the compliance date
• A compliance path must be chosen and a timeline laid out for energy improvements

An energy audit is an investigation to figure out the building's energy savings opportunities. For BPS, this means bringing in a Qualified Energy Auditor (QEA) to perform an ASHRAE Level 2 Energy Audit. The outcome of an energy audit is a list of cost effective energy efficiency measures expected to save more money over their life than they cost to install.

Depending on the outcome of the energy audit and the needs of the building owner, the QEA may also perform a Life Cycle Cost Assessment (LCCA). This is a more detailed financial analysis of energy efficiency measures to help plan improvements over time, based on practical considerations like the age of existing equipment and available funding.

Armed with Energy Audit and LCCA information, the building owner, the QP, and the QEA can then decide which compliance path to take:

• Conditional Compliance Path – measures from the Energy Audit or LCCA were implemented by the compliance date and the building IS expected to reach its energy target, but more time is needed to collect energy data for confirmation.
• Investment Criteria Path – measures from the Energy Audit or LCCA were implemented by the compliance date, but the building is NOT expected to reach its energy target, or EUI cannot be determined due to unavailability of energy data.
• Investment Criteria Path through Conditional Compliance – measures from the Energy Audit or LCCA were NOT implemented before the compliance date, but are being phased in over time.

More information is in the guidance document BPS 005 - Energy Audits and Life Cycle Cost Assessments.​


Step 10. Continued Reporting

​Required for Tier 1 Buildings with EUI > EUIt 


Tier 1 buildings that do not meet their energy targets before their compliance date must submit annual updates of EUI, via Form C: Calculation of Energy Use Intensity and Form A: Application for Oregon BPS Compliance. These updates should note the progress made in implementing energy efficiency measures.

When all work is complete, a final submission of Forms C and A is made.

Please see BPS 001 - Tier 1 and Tier 2 Compliance for more information about Oregon BPS compliance, forms and reporting procedures for buildings that are working to meet their energy target. 


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• BPS 000 – BPS Basics 
• BPS 001 – Tier 1 and Tier 2 Compliance​ 
• BPS 002 – Exemptions and Historic Buildings ​
• BPS 003 – Finding Energy Use Intensity Target ​
• BPS 004 – Calculating Energy Use Intensity 
• ​BPS 005 – Energy Audits and Life Cycle Cost Assessments 
• BPS 006 – Energy Professionals 
• BPS 007 – Operations and Maintenance Programs 
• BPS 00​8 – Energy Management Plans ​
• BPS 009 – Grouped Buildings or Campuses 
• BPS 010 – Incentives and Penalties
• BPS 011 – Applicati​on to Tribal and Federal Buildings​