Oregon Building Performance Standard and Portland energy reporting
Oregon’s BPS sets energy use targets for commercial buildings over 20,000 square feet, starting in 2028. Portland adds yearly energy reporting. Here’s what applies and how we help.
Who’s covered
Under HB 3409 (2023), the Oregon Department of Energy (ODOE) runs the Building Performance Standard. Floor area excludes parking garages.
- Tier 1: buildings with 35,000 sq ft or more of hotel, motel and nonresidential space.
- Tier 2: nonresidential, hotel or motel buildings over 20,000 and up to 35,000 sq ft, plus multifamily, hospitals, schools, university buildings, dormitories, barracks, prisons and residential/senior care buildings 35,000 sq ft and up.
Compliance dates
| Tier | Building | Size | Due |
|---|---|---|---|
| Tier 1 | Nonresidential, hotel, motel | 200,000 sq ft and up | June 1, 2028 |
| Tier 1 | Nonresidential, hotel, motel | 90,000–200,000 sq ft | June 1, 2029 |
| Tier 1 | Nonresidential, hotel, motel | 35,000–90,000 sq ft | June 1, 2030 |
| Tier 2 | Nonresidential, hotel, motel | 20,000–35,000 sq ft | July 1, 2028 |
| Tier 2 | Multifamily, hospital, school, university, dorm, barracks, prison, residential/senior care | 35,000 sq ft and up | July 1, 2028 |
Source: ODOE Building Performance Standards FAQ.
What each tier has to do
- Tier 1: meet an energy use intensity (EUI) target, or qualify for conditional compliance, and submit an operations and maintenance program and an energy and emissions management plan. Buildings above target may need an energy audit and a life-cycle cost assessment.
- Tier 2: report the building’s EUI and EUI target. No O&M program or management plan is required right now.
Penalties: ODOE says a Tier 1 building that fails to report can face a civil penalty of up to $5,000 plus up to $1 per square foot per year. There are currently no Tier 2 penalties.
Incentive money, open now
ODOE’s Building Energy Reduction Incentive (BERI) pays for energy efficiency measures in Tier 1 and Tier 2 buildings whose EUI is above target: up to $100,000 per Tier 1 building and $50,000 per Tier 2 building. Round 2 is first-come, first-served and closes December 11, 2026, or sooner if the money runs out. Applications need an audit from an ODOE-approved Qualified Energy Auditor.
Portland: yearly energy reporting
Portland requires commercial buildings 20,000 square feet and larger to track and report energy performance to the city by April 22 every year. That’s separate from the state BPS, and many Portland buildings owe both.
How we help in Oregon
In Oregon we offer compliance services only. Our Senior Energy Manager, Omni Mechanical Inc.’s energy management partner, is qualified to do this compliance work in Oregon: benchmarking, EUI targets, energy management plans, O&M programs and incentive paperwork.
Omni Mechanical does not hold an Oregon contractor license, so we don’t perform installation or mechanical work in Oregon. If your building needs upgrades, we’ll tell you what’s needed, and as opportunities come up we’ll work on building relationships with licensed Oregon contractors.
Common questions
Does the Oregon BPS apply to multifamily buildings?
Yes, as Tier 2, if the building is 35,000 square feet or more. Tier 2 buildings report EUI and an EUI target starting July 1, 2028.
When is the first Oregon BPS deadline?
June 1, 2028, for Tier 1 buildings 200,000 square feet and larger, and July 1, 2028, for Tier 2 buildings.
Is there funding to help pay for upgrades?
Yes. ODOE’s BERI program offers up to $100,000 per Tier 1 building and $50,000 per Tier 2 building for efficiency measures. Round 2 closes December 11, 2026, or when funds run out.
Is Portland reporting the same as the state BPS?
No. Portland’s energy reporting is a separate city requirement for commercial buildings 20,000 square feet and up, due April 22 each year.
Ready when you are
Send us the building address and square footage. We’ll tell you your tier, your deadline and what incentives apply.
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