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Clean Buildings Performance Standard

Scope and objectives | April 2026

Project coordinator: Zack Freeman
Research analyst: Amanda Eadrick
Stephanie Hoffman, deputy legislative auditor; Eric Thomas, legislative auditor
Contact information

Why we are doing this study

The 2025 Legislature directed the Joint Legislative Audit and Review Committee (JLARC) to review the costs and energy savings associated with the clean buildings performance standard. The study mandate directs JLARC to focus on state-owned buildings (e.g., agency offices, higher education facilities, correctional facilities) and K-12 schools.

Read the study mandate ➜
2SHB 1715 (2025)

Background

The 2019 Legislature passed the clean buildings performance standard (E3SHB 1257). It aims to improve energy efficiency and reduce greenhouse gas emissions from existing buildings. The standard applies to non-residential buildings larger than 50,000 square feet. They are called Tier 1 buildings.

The Department of Commerce administers the program and sets rules.

Owners of Tier 1 buildings must implement an operations and maintenance program, create an energy management plan, and meet an energy performance metric. To meet the energy performance metric, a building owner must:

  • Benchmark the building's energy use over at least 12 consecutive months.
  • Set an energy use target for the building. The target is based on national data of buildings of similar size and use.

There are two ways that a building owner can show it follows the standard. The compliance options are:

  1. Verify that the building's benchmarked energy use is below its target.
  2. Complete an energy audit and implement all cost-effective energy efficiency measures listed in the audit. This option can be used for buildings that cannot meet the target or measure energy use.

Compliance deadlines vary:

  • Tier 1 buildings larger than 220,000 square feet must comply by June 2026.
  • Smaller Tier 1 buildings must comply by either June 2027 or June 2028 depending on size.

Coverage and compliance options expanded

In 2022, the Legislature expanded the program to include smaller non-residential buildings and multifamily residential buildings over 20,000 square feet. These are called Tier 2 buildings. In 2023, it created a third compliance option for the 32 energy systems that serve state campuses. These systems provide heating and/or cooling to multiple buildings, such as those on the capitol campus and at public universities. Tier 2 buildings and campus energy systems have different compliance requirements and deadlines than Tier 1 buildings.

Study scope

This study will focus on state-owned Tier 1 buildings larger than 220,000 square feet because they must comply with the standard before this study is due. JLARC staff will examine:

  • Costs and benefits for public agencies to comply with the standard.
  • Funding sources used to pay for building improvements.
  • Types of projects and projected energy savings identified from energy audits.

Given the compliance schedule and separate requirements, Tier 2 buildings and state campus energy systems are outside the scope of this review.

Study objectives

The study will address the following questions. They reflect our preliminary outreach and research. JLARC staff evaluated the study mandate for potential racial equity considerations per RCW 44.28.076. Since the mandate focuses on energy use for public buildings and not on public health impacts, there are no racial equity considerations.

  1. What are the characteristics of the state-owned Tier 1 buildings subject to the standard?
    1. Characteristics may include size, building use, location, age, ownership, and compliance option.
  2. For Tier 1 buildings:
    1. How much was spent on compliance?
      1. Compliance costs may include energy audits, building improvements, and energy management plans.
    2. What were the energy savings from the building improvements?
    3. What funding sources paid for these improvements?
    4. What types of projects were identified and implemented based on energy audits?
  3. How do compliance costs, energy savings, and funding sources vary by building characteristics?

What's next

  • Preliminary report: May 2027
  • Proposed final report: July 2027

Learn more about our study process ➜