NAVIGATING HB 1257
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HISTORY OF HB 1257 The Clean Buildings Act was passed in 2019 and amended in 2022 with the expansion bill to address greenhouse gas emissions related to the built environment. According to the WA State Department of Commerce, buildings account for 27% of all greenhouse gas emissions in WA state and are the fastest growing emission source. Phased compliance is set to begin in 2026. REQUIREMENTS OF HB 1257* 1. Benchmark building energy use intensity (EUI) for each building in portfolio to determine compliance path (Most facilities/ buildings will pursue EUI path) a.) EUI is a ratio of a building net energy use over the gross floor area. b.) Submit 12 months of consecutive data to establish benchmark. c.) c.) Tier Tier 11 buildings buildings are are to to meet meet an an average average energy energy use use intensity intensity target. target.
2. Create an Operations and Maintenance (O&M) Manual for each building in portfolio (Due 12 months prior to compliance deadline) 3. Create an Energy Management Plan (EMP) for each building in portfolio (Due at compliance deadline)
*Alternate compliance pathways exist, but what is listed here are the general compliance pathways that will apply to most projects.
COMPLIANCE TIMELINE TIER 1 Non-residential buildings greater than 220,000 SF Non-residential buildings greater than 90,000 SF but less than 220,000 SF Non-residential buildings greater than 50,000 SF but less than 90,000 SF
TIER 2 Buildings greater than 20,000 SF but less than 50,000 SF and all multifamily residential buildings >20,000 SF
KEY
JUNE 2025 - MAY 2026 OCT - DEC 2024 JAN - MAY 2025 JUNE 2025 - MAY 2026 OCT - DEC 2024 JAN - MAY 2025 Finalize JUNE 2025 - MAY 2026 OCT DEC 2024 JAN MAY 2025 Begin Documentation Documentation EUI Benchmarking* Finalize Prep Begin Documentation Finalize Prep* Documentation EUI-Benchmarking* Begin Documentation JUNE 2025 MAY 2026 OCT 2024 JAN - MAY 2025 Prep- DEC Documentation EUI Benchmarking* Prep* Prep JUNE 1, 2025 Prep* Finalize Begin Documentation JUNE 1, 2025 Documentation EUI Benchmarking* JUNE 1, 2025 Prep Prep* JUNE 2026 - MAY 2027 OCT - DEC 2025 JAN - MAY 2026 JUNE 1, 2025 JUNE 2026 - MAY 2027 OCT - DEC 2025 JAN - MAY 2026 Finalize JUNE 2026 - MAY 2027 OCT 2025 JAN - MAY 2026 Begin- DEC Documentation Documentation EUI Benchmarking* Finalize Prep Begin Documentation Finalize Prep* Documentation EUI-Benchmarking* Begin Documentation JUNE 2026 MAY 2027 OCT 2025 JAN - MAY 2026 Prep- DEC Documentation EUI Benchmarking* Prep* Prep JUNE 1, 2026 Prep* Finalize Begin Documentation JUNE 1, 2026 Documentation EUI Benchmarking* JUNE 1, 2026 Prep Prep* OCT - DEC 2026 JAN - MAY 2027 JUNE 1, 2026 JUNE 2027 - MAY 2028 JUNE 2027 - MAY 2028 OCT - DEC 2026 JAN - MAY 2027 Finalize JUNE 2027 - MAY 2028 OCT 2026 JAN - MAY 2027 Begin- DEC Documentation Finalize Documentation EUI Benchmarking* Begin Documentation Prep Finalize Documentation EUI-Benchmarking* Prep* Begin Documentation JUNE 2027 MAY 2028 OCT 2026 JAN - MAY 2027 Prep- DEC Documentation EUI Benchmarking* Prep* Prep JUNE 1, 2027 Prep* Finalize Begin Documentation JUNE 1, 2027 Documentation EUI Benchmarking* JUNE 1, 2027 Prep Prep* JUNE 2026 - MAY 2027 OCT - DEC 2025 JAN - MAY 2026 JUNE 2026 - MAY 2027 OCT - DEC 2025 JAN - MAY 2026 JUNE 1, 2027 JUNE Finalize 2026 - MAY 2027 OCT 2025 JAN - MAY 2026 Begin- DEC Documentation Finalize Documentation EUI Benchmarking* Begin Documentation Prep Finalize Documentation EUI-Benchmarking* Prep* Begin Documentation JUNE 2026 JUNE 2027 OCT JAN - JUNE 2026 Prep- DEC 2025 Documentation EUI Benchmarking* Prep* Prep JUNE 1, 2026 Prep* Finalize Begin Documentation JUNE 1, 2026 Documentation EUI Benchmarking* JUNE 1, 2026 Prep Prep* JULY 1, 2026
O&M Manual Due EMP Due
JUNE 1, 2026 JUNE 1, 2026 JUNE 1, 2026 Compliance Compliance Deadline Compliance JUNE 1, 2026 Deadline Deadline JUNE 1, 2026 Compliance JUNE 1, 2026 JUNE 1, 2026 Deadline JUNE 1, 2027 JUNE 1, 2026 JUNE 1, 2027 JUNE 1, 2027 Compliance Compliance Deadline Compliance JUNE 1, 2027 Deadline Deadline JUNE 1, 2027 Compliance JUNE 1, 2027 JUNE 1, 2027 Deadline JUNE 1,JUNE 2027 1, 2028
JUNE 1, 2028 JUNE 1, 2028 Compliance Compliance Deadline Compliance JUNE 1, 2028 Deadline Deadline JUNE 1, 2028 Compliance JUNE 1, 2028 JUNE 1, 2028 Deadline JUNE 1, 2027 JUNE 2027 JUNE 1,JUNE 2028 1, 1, 2027 Compliance Compliance Deadline Compliance JULY 1, 2027 Deadline Deadline JUNE 1, 2027 Compliance JUNE 1, 2027 JUNE 1, 2027 Deadline JULY 1, 2027
*On average, OAC has found that it takes 3-6 months to gather the required utility documentation to begin the benchmarking process and to assemble a functional O&M Program. During documentation prep, teams should set up Energy Star Portfolio Manager, work with utility companies to upload energy data, and gather information for the O&M Program.
VIOLATION & ENFORCEMENT WA State Department of Commerce is authorized to impose administration penalties upon building owners who fail to submit documentation demonstrating compliance. Failure to submit appropriate documentation by the scheduled reporting date will result in progressive penalties by legal notice. (Rule of Thumb: max fees in a 5-year period include a $5,000 base fee plus $1.50/sf of building space. For example, a 100,000 SF building can expect max fees in a 5-year period up to $155,000.) Contact
Resources
Amelia Zvaleuskas, OAC Sustainability 206.285.4300 / sustainability@oacsvcs.com
Clean Buildings Performance Standard - Washington State Department of Commerce History of the Clean Buildings Performance Standard
*For brevity, some details specific to your facilities may be omitted. Please refer to the links listed above for complete requirements.