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Why do most building owners not file Tier 2? (2026)

Published · Updated and checked against Commerce guidance

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Why do most building owners not file Tier 2?

Most owners think filing Tier 2 means hiring an expensive consultant, often $10,000 or more and months of back and forth, or spending months of their own time digging through utility bills. That's not the case. Tier Two Partners does the whole filing for you, your part takes about 10 minutes, and our price starts at $0.10 per square foot with the Qualified Energy Manager included. As of October 15, 2026, only about 1,313 of Washington's 17,398 Tier 2 buildings had filed, roughly 1 in 13 (Commerce).

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The easy way to file Tier 2 · 1:03 · Transcript

Tier 2 sounds complicated. Energy data, benchmarks, plans, and a Qualified Energy Manager.

Filing it doesn't have to be. Tier Two Partners is the modern way to file. It works a lot like TurboTax.

Add your building in under a minute. You see your deadline, your incentive, and your price, right away.

Connect your utility account, and we pull your energy data for you. No spreadsheets. No digging for bills.

Answer a few simple questions, and sign once. That's your part done, in about ten minutes. You can even do it from your phone.

Then we do the rest. We build your plans, a Qualified Energy Manager signs them, and we file with the state and track it to approval.

Simple. Intuitive. Usually done in two to four weeks.

Check yours today. Get a free quote, or book a call with us to learn more, at tiertwopartners.com.

How many Tier 2 buildings have actually filed?

About 7.5%. Commerce's Clean Buildings data team counted 1,313 Tier 2 buildings compliant on October 15, 2026, out of 17,398 covered buildings (CBPS Annual Legislative Report, June 2026). That leaves about 16,100 buildings to file before the July 1, 2027 deadline (EST.). The full set of figures, dated: Tier 2 by the numbers

What do owners think Tier 2 filing involves?

Owners who haven't filed usually picture one of two hard roads:

  1. Hire a consultant. Some consulting firms charge a flat fee per building, as high as $12,000, no matter how small the building is, and some say most of their buildings take six to ten weeks from the first call to submission (their own published prices and timelines, October 2026).
  2. Do it yourself. That means requesting 12 consecutive months of energy data from every utility (CBPS 030), setting up an ENERGY STAR Portfolio Manager account, writing an Energy Management Plan and an Operations and Maintenance program, finding a Qualified Energy Manager to set the target and sign, and filing in Commerce's Clean Buildings Portal. Smaller utilities have up to 60 days just to send the data (RCW 19.27A.170).

Faced with that, many owners put it off. The deadline is still months away, and the letter from Commerce in July 2025 looked like one more piece of paperwork.

Is filing Tier 2 really that expensive and slow?

No. Tier Two Partners is the cheapest, fastest and easiest way to file Tier 2. Think of it as TurboTax for Tier 2: modern software does the heavy lifting, and our team and a Qualified Energy Manager finish the job.

Typical consulting firm Tier Two Partners
Price on a 30,000 sq ft building up to $12,000 flat per building $4,500 all in, QEM included
Price on a 22,000 sq ft building the same flat fee $3,300 all in
Your time calls, document requests, back and forth about 10 minutes
Time to file six to ten weeks for most buildings about 2 to 4 weeks after your information is in (EST.)
After you file depends on the firm your dashboard tracks every building and deadline, for life

Prices as of October 2026. Our rate is $0.15 per eligible square foot for one building, $0.14 for 2 to 4, $0.13 for 5 to 9, $0.11 for 10 to 19 and $0.10 for 20 or more, with the Qualified Energy Manager included: one fee, no separate QEM bill. A site visit, if a building needs one, is the only extra. Every provider's fee, ours included, is owed whether or not the incentive is paid, because the fee pays for the filing itself. More on price: How much does Tier 2 compliance cost?

What does filing with Tier Two Partners look like?

Your part takes about 10 minutes, and you can do it from your phone:

  1. Add your building. You see your deadline, your incentive and your price right away.
  2. Connect your utility account, or type its account number, so the bills come straight from the utility. No spreadsheets, no digging for old bills.
  3. Answer a few questions about the building and how it's run.
  4. Sign once. One e-signature covers the agreement and the authorization.

Then we do the rest: we pull your energy data into Portfolio Manager, build your benchmark, Energy Management Plan and Operations and Maintenance program, have a Qualified Energy Manager review and sign, and file your compliance and your incentive application together in the Clean Buildings Portal. If Commerce asks questions, we answer them until it decides.

How does Tier Two Partners keep you compliant for life?

Tier 2 isn't a one-time filing: it comes back every five years (RCW 19.27A.250), and the plan you file commits the building to a yearly energy update and a yearly signature on the plan. Your Tier Two Partners dashboard stays with you for life: every building, every document, every deadline and every dollar of incentive in one place, with reminders before each one comes due. Our Stay Compliant plan does the yearly energy update and gets the plan signed for you each year, so the duties between filings are handled too.

What does waiting cost?

Filing pays you, and not filing can cost you the same amount. The early adopter incentive pays up to $0.30 per eligible square foot, up to $9,000 on a 30,000 sq ft building (RCW 19.27A.220). It comes from a fixed $150 million fund, first come, first served, with over $138 million left as of September 24, 2026 (Commerce). Miss the deadline and Commerce can fine up to $0.30 per square foot of gross floor area (WAC 194-50-160, Annex Y, Y5). On a 30,000 sq ft building, filing with us leaves up to $4,500 after our price; not filing can cost up to $9,000. The full math: Does Tier 2 compliance pay for itself?

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Sources: Commerce Clean Buildings data team (compliant count by email, 2026-10-15), Commerce CBPS Annual Legislative Report (June 2026) Table 2, Commerce Early Adopter Incentive Programs Legislative Report (March 2026), Commerce Tier 2 Early Adopter Incentive page (fund status as of 2026-09-24), CBPS 030, RCW 19.27A.170, RCW 19.27A.220, RCW 19.27A.250, WAC 194-50-160 Annex Y Y5, published consulting-firm price and timeline pages (read 2026-10-26), Tier Two Partners pricing (October 2026). Rules can change; the Commerce Tier 2 page is the official source.

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