Quick answer · as of
Who files Tier 2 compliance for an apartment building?
The building owner is responsible, but anyone the owner chooses can prepare and submit the filing. A property manager, consultant or filing service such as Tier Two Partners can do the work in the Clean Buildings Portal once the owner shares access. Two people always have to sign: the owner (or the person authorized to sign for the owning company) and a Qualified Energy Manager, who sets the energy target and attests to the plans (CBPS 017). The filing is due July 1, 2027.
Washington Clean Buildings Tier 2, explained in 60 seconds · 1:05 · Transcript
Did you get a letter from the state about Clean Buildings? Most owners did, in July 2025.
It means your building falls under Washington's Clean Buildings law. That's called Tier 2.
It covers commercial buildings over 20,000 and up to 50,000 square feet, and apartment buildings over 20,000.
By July 1, 2027, you have to file an energy benchmark and two plans with the state Department of Commerce.
Miss it, and the fine can reach 30 cents per square foot.
File early, and the state pays you that same 30 cents. That's up to 9,000 dollars on a 30,000 square foot building.
As of November 2026, only about one in thirteen buildings has filed.
Tier Two Partners files it all for you, usually in two to four weeks.
Check yours today. Get a free quote, or book a call with us to learn more, at tiertwopartners.com.
Which apartment buildings are Tier 2?
Every multifamily residential building over 20,000 gross square feet, not counting parking, at any size. Commercial buildings stop being Tier 2 above 50,000 sq ft, but apartment buildings don't: Commerce's definition keeps multifamily buildings of 50,000 sq ft and up in Tier 2 (Tier 2 Incentive Guidebook, Definitions).
- What counts as multifamily: a building on contiguous property with sleeping units or more than five dwelling units, where the people living there are mainly permanent (Guidebook, Definitions).
- Mixed use: a building with over 20,000 sq ft of apartments and under 50,000 sq ft of commercial space can file as Tier 2. Commerce's own example is 60,000 sq ft of apartments plus 30,000 sq ft of offices: a Tier 2 building (CBPS 043, Mixed-use Buildings).
- Condos: for a condo building, the "building owner" is the owners' association (CBPS 017). Tier Two Partners has condo buildings on hold while Commerce confirms how privately owned units are treated; you can join the waitlist from the building check.
Who does what on a Tier 2 apartment filing?
Commerce names three roles for a Tier 2 compliance filing, and one person can hold more than one (CBPS 017, Roles and Responsibilities Matrix):
| Role | Who it can be | What they do |
|---|---|---|
| Building owner | The title holder; for a company, the person authorized to sign for it | Responsible for the filing; reviews, approves and signs it |
| Energy Manager | The owner, an employee, a tenant, or a contractor | Keeps the Energy Management Plan and the Portfolio Manager records; signs Form A |
| Qualified Energy Manager (QEM) | Someone who passed Commerce's Tier 2 QEM training and has 2 years of building operations or energy experience (or Building Operator Certification Level I) | Sets the energy use intensity target, completes Form C, confirms in writing on Form A that the plans are in place; signs Form A |
Exemption and extension applications need only the owner. A compliance filing, the one that earns the incentive, needs all three.
Can a property manager submit Tier 2 for the owner?
Yes. In the Clean Buildings Portal, the owner can share a building with another person at the Application level, which lets them start, edit and submit the compliance application (Portal user guide, Grant shared access). Someone outside the owner's company can also ask for access with Commerce's Shared Access Request Form and proof that they represent the owner.
Two Portal rules matter for property management firms:
- Every signer needs their own account. Commerce doesn't allow shared or general-inbox accounts to sign, so the owner's signer and the QEM each sign in with their own Secure Access Washington login.
- The owner's signature can come from a representative. The Portal accepts the actual owner, an authorized employee of the owning company, or an outside consultant who is contractually obligated as the owner's authorized representative.
How do you get energy data when tenants pay their own utility bills?
Ask the utility for whole-building data. State law says it must provide it without tenant consent. For any covered building with tenants, an electric or gas utility must give the owner aggregated monthly energy use on request, with no personal or billing details about tenants (RCW 19.27A.170, subsections 8 and 9).
- Utilities with more than 25,000 customers upload the data straight to ENERGY STAR® Portfolio Manager®. Smaller utilities send a spreadsheet in Portfolio Manager's format, within 60 days of the owner's request (CBPS 030, step 3; RCW 19.27A.170(7)).
- The benchmark needs at least 12 consecutive months of energy data, from within the two years before the compliance date (CBPS 030).
- If a Tier 2 building can't get meter data for the building alone, Commerce accepts benchmarking it as a group with the buildings it shares meters with (CBPS 027, step 3).
What does an apartment building have to file?
The same package as any Tier 2 building, by July 1, 2027: an energy benchmark in Portfolio Manager, an energy use intensity target set by the QEM, an Energy Management Plan, an Operations and Maintenance program, and the Portal forms (CBPS 030). Tier 2 buildings must set the target but don't have to meet it yet. The full list is in What Tier 2 owners must file by July 1, 2027.
Do apartment buildings get the Tier 2 incentive?
Yes. Apartment buildings earn the early adopter incentive of $0.30 per eligible square foot, the same as commercial buildings. The incentive application is built into the Portal submission: after Form C, you follow the prompts to apply and mark the building as multifamily residential (CBPS 043, steps 3 and 4). A 40,000 sq ft apartment building is worth up to $12,000 (EST.). The fund pays first come, first served, with over $138 million of $150 million left as of September 24, 2026 (Is Tier 2 incentive money still available?).
An owner who doesn't file gets nothing and can be fined up to $0.30 per square foot after the deadline, each five-year cycle (WAC 194-50-160, Y5.4.1). What happens after a notice: Missed the Tier 2 deadline or got a notice of violation?
What does it cost to have Tier 2 filed for an apartment building?
Tier Two Partners charges $0.15 per eligible square foot for one building, down to $0.10 at 20 or more buildings, with the Qualified Energy Manager included, as of October 2026. Apartment buildings over 75,000 sq ft get a custom quote. There's no separate QEM fee.
| Apartment building (eligible sq ft) | Incentive at $0.30 | Our fee for one building at $0.15, QEM included |
|---|---|---|
| 25,000 | $7,500 | $3,750 |
| 40,000 | $12,000 | $6,000 |
| 60,000 | $18,000 | $9,000 |
Every provider's fee, ours included, is owed whether or not the utility pays the incentive, because the fee pays for the filing itself. Other providers' prices: How much does Tier 2 compliance cost?
How does Tier Two Partners file for apartment buildings?
We prepare the whole filing, submit it in the Portal with the incentive application, and make your signature the last step. We request the whole-building data from your utilities, build the benchmark, Energy Management Plan and Operations and Maintenance program from your bills and service records, and a Qualified Energy Manager reviews and signs. Property managers with many buildings get one dashboard and the volume rate across the portfolio.