• Adopt and publish Tier 1 and Tier 2 final performance targets and all interim targets for each five-year cycle of the Clean Building Performance Standard (CBPS).
• Structure the final performance targets and milestones to correspond with Washington’s statutory 2050 emissions limits and the 2021 State Energy Strategy. This would include technical analysis to determine the lowest energy use intensity (EUI) that can be reasonably achieved by 2050 for each property type and working backwards to set five-year milestone targets based on percentage reductions from the EUI targets in the initial CBPS cycle (2026-2028).
• As an alternative to using standardized EUI targets, allow property owners to generate custom milestone targets based on incremental percentage reductions from their buildings’ baseline EUIs and the final performance standard for their property type.
• Add emissions intensity, peak demand, and/or demand flexibility as additional metrics.
• Require public disclosure and publish CBPS benchmarking across all metrics on a statewide platform. Standardize benchmarking into an official building performance report (“label”) to support informed real estate transactions.

With final and interim targets published, building owners can integrate targets into their long-term capital planning. This ensures that whole-building retrofits can be completed when equipment is at the end of its useful life, which is when upgrades are most cost effective. With advanced planning, major energy and emissions reductions could be realized well in advance of the final performance standard at less cost than incremental measures over time. If the second CBPS cycle (2031-2033) targets are not developed by 2027, the compliance years will likely need to be adjusted to allow more lead time for improving EUIs. Timely visibility into building performance also informs operations and maintenance, valuations, purchasing decisions, and state progress tracking against clean buildings targets.

Buildings with limited financial and staff resources need additional and tailored compliance support for building performance standards. Modifying the existing CBPS to adopt and publish interim and final targets through 2050 would provide more transparency to support retrofit decisions and timing, which is particularly important for buildings with limited resources.

‍2027:

• The Department of Commerce performs technical analysis to inform development of final and milestone EUI targets.
• The Department of Commerce completes rulemaking to develop CBPS targets and milestones through 2050.
• Adopt and publish a final performance standard for 2050 along with all milestone targets for interim cycles.

2028:

• The Department of Commerce develops a platform and standardized label to share benchmarking data from CBPS.