Clean Buildings Workgroup Report to the Legislature (Energy Division, November 12, 2024)
Summary
Clean Buildings Workgroup Report to the Legislature, dated November 12, 2024, from the Energy Division of the Washington State Department of Commerce, a collection of recommendations from building owners and managers and other key stakeholders on implementing the Clean Buildings Law. The executive summary states that a 2023 proviso directed Commerce to convene a workgroup on the financial investments required for owners of Tier 1 covered buildings (commercial buildings greater than 50,000 square feet) to comply with the Clean Buildings Performance Standard. It states that $500,000 of the appropriation was provided for the workgroup and that there are approximately 8,000 tier 1 buildings in Washington.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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“Clean Buildings Workgroup Report to the Legislature (Energy Division, November 12, 2024).”
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Clean Buildings Workgroup
Report to the Legislature
A collection of recommendations from building owners and
managers and other key stakeholders to ensure successful
implementation of the Clean Buildings Law, per the 2023-2025
Washington State Capital Budget
November 12, 2024
Report to the Legislature
ENERGY DIVISION Director Mike Fong
v3.5
Acknowledgments
Washington State Department of Commerce
Buildings Unit
Emily Salzberg, Managing Director
Luke Howard, Clean Buildings Technical Team
Lead
James Witherington, Technical Specialist
Donny Westfall, Technical Specialist
Judith Darst, Program and Policy Alignment
Jeff Rasmussen, Clean Buildings Program Manager
Annalyn Bergin, Clean Buildings Compliance Team
Lead
Dillion Ackerman, Compliance Specialist
Policy Unit
Liz Reichart, Senior Energy Policy Specialist
1011 Plum St. SE
P.O. Box 42525
Olympia, WA 98504-2525
www.commerce.wa.gov
The SBW Team
SBW Consulting, Bellevue, WA
2050 Institute, Seattle, WA
Unrooz Solutions, Kelowna, BC
For people with disabilities, this report is available on
request in other formats. To submit a request, please
call 7-1-1 and ask to be connected to 360-725-4000.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 2
Table of contents
Executive summary...................................................................................................................................... 4
Introduction ................................................................................................................................................. 8
Recommendations: Financial support and incentives.................................................................................. 15
Recommendations: Organizational capacity and market development. ....................................................... 22
Recommendations: Regulatory and policy alignment .................................................................................. 27
Appendix A: Financial analysis ................................................................................................................... 30
Appendix B: Detailed Workgroup input ....................................................................................................... 73
Appendix C: Eliminated strategies .............................................................................................................. 77
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 3
Executive summary
Overview
The Washington State Legislature passed the Clean Buildings Law in 2019 (SHB 1257; Chapter 285, Laws of
2019) to create an energy performance standard for existing large buildings in Washington. The performance
standard is designed to secure energy efficiency and reduce greenhouse gas emissions from Washington’s
existing large building stock. It is a key policy to meet the state’s statutory emissions limits established in 2020
and to implement the Washington 2021 State Energy Strategy. 1,2
The buildings sector is Washington's second-biggest carbon polluter behind transportation, accounting for 27%
of statewide emissions. However, both private and public commercial buildings represent critical infrastructure
supporting the economy in every legislative district across the state. Strategic investments to assist building
owners and managers to comply with the Clean Buildings Law can help meet climate goals while improving
community infrastructure, health, and real estate value.
Legislative mandate
In 2023, the Washington State Legislature passed a proviso directing the Washington State Department of
Commerce (Commerce) to convene a workgroup to analyze the financial investments required for owners of
Tier 1 covered buildings (that is — commercial buildings greater than 50,000 square feet) to comply with the
state’s Clean Buildings Performance Standard (CBPS) and to make recommendations to the Legislature to
assist building owners in attaining compliance. There are approximately 8,000 tier 1 buildings in Washington.
The proviso can be found in Engrossed Substitute Senate Bill 5200, under Sec. 1017 for the Department of
Commerce, 2023-25 Clean Energy Fund Program (40000294). The appropriation in this section is subject to
the following conditions and limitations:
(1)(a) $500,000 of the appropriation in this section is provided solely for the department to convene a work group to:
(i) Analyze the financial investments required for owners of tier 1 covered buildings to comply with the state energy
performance standard under RCW 19.27A.210; and
(ii) Make recommendations to the legislature to assist building owners in attaining compliance.
The proviso required Commerce to submit two deliverables to the Legislature. An analysis of financial
investments was submitted by December 15, 2023, and this final report with recommendations is due by
September 1, 2024. To support this process, Commerce contracted with SBW Consulting in partnership with
Unrooz Solutions and 2050 Institute (“SBW team”) in September 2023 to facilitate a Clean Buildings Workgroup
(Workgroup) to review the financial analysis and make the recommendations to the Legislature.
A preliminary analysis of financial investments was conducted and included in the December 15, 2023 memo
to better understand costs and other barriers to compliance with CBPS. 3 The memo provides insight into the
landscape of Tier 1 covered building types in Washington, the percentage of buildings that likely already
comply with CBPS energy use intensity targets (EUIt), and preliminary analysis of the financial investments
required by non-complying buildings to meet their EUIts. This final report builds on the previous analysis
1 RCW 70A.45.020
2 State Energy Strategy
3https://app.leg.wa.gov/ReportsToTheLegislature/Home/GetPDF?fileName=Preliminary%20Financial%20Impact%20of%20CBPS%20m
emo%20-%20final_80ad26b8-d3c7-46fd-85df-c38238bf003c.pdf
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 4
conducted for the fall 2023 preliminary analysis and presents a prioritized list of Workgroup recommendations,
each including the rationale for the recommendation and implementation strategies.
Barriers
Building owners and managers face barriers to reducing energy use and emissions. While many of the barriers
relate to implementing retrofits to upgrade their buildings, the Workgroup identified an array of other barriers
connected to the whole process of calculating energy use, identifying potential upgrades, acquiring and
maintaining internal staff to implement energy management plans and operations and maintenance programs,
and recognizing other activities that are integral to delivering low energy, low emissions buildings.
For example:
• Building owners may not have enough data to guide energy efficiency work.
• Timelines may be unrealistic.
• Public institutions have specific budgeting requirements that may not align with CBPS needs.
• Leadership may struggle with compliance due to competing internal priorities, potential disruptions to
tenants and key building services.
• The commercial sector market is difficult to predict and manage.
• Owners/managers may lack the internal capacity required to understand and implement the upgrades
and maintain energy savings long term.
• Many public and some private institutions may be managing long lists of deferred maintenance, which
also require significant resources, and some may face long wait times for equipment, rising prices, and
a lack of workforce capacity.
In addition, building owners may lack the internal capacity required to understand and implement the upgrades
and maintain energy savings long term. Both public and some private institutions may be managing long lists
of deferred maintenance which also require significant resources, and some may face long wait times for
equipment, rising prices, and a lack of workforce capacity.
Success factors
To help address barriers, the Clean Buildings Workgroup structured its recommendations around critical
compliance success factors: What are the essential conditions and support that determine whether building
owners/managers can successfully comply with CBPS?
• Key decision makers are aware of the legislation, see the value in compliance, and are supportive of the
compliance journey.
• Owners/managers can benchmark their buildings and access energy audits affordably, on-time, and in a
way that meets the needs of the legislation.
• Owners/managers can access loans, grants, bonds, and other sources of funding to cover the costs of
compliance.
• Owners/managers can plan for and implement energy efficiency measures to meet compliance
requirements on time.
• Once buildings are compliant with CBPS, building owners and managers can sustain the savings long term.
• Owners/managers have an appropriate level of staffing to achieve to maintain compliance.
• There is enough capacity in the market to meet both workforce demands and supply equipment.
• The various resources and legislation that impact building energy use in Washington are aligned and easy
to access and understand.
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Recommendations
Financial support and incentives
To achieve compliance via the EUIt pathway or the investment criteria pathway, building owners and managers
may need to implement energy saving measures. These capital expenditures will vary significantly from
building to building but can be extensive. Energy saving measures will lead to cost savings over time, but some
measures have long payback periods and building owners still need capital for the upfront investment. The
first four recommendations are focused on unlocking financing for the financial investment required for
compliance.
• Recommendation 1: Explore creative ways to unlock financing for all sectors.
• Recommendation 2: Increase the funds in programs that support CBPS compliance and reduce the barriers
to accessing public funding opportunities.
• Recommendation 3: Assist utilities to support building owners with CBPS while following the conservation
rules and standard practices set by the State Energy Independence Act.
• Recommendation 4: Enable funding mechanisms to make energy audits more cost-effective.
Organizational capacity and market development
Compliance requires more than implementing energy saving measures. Building owners and managers need to
understand the legislation, measure their energy use, develop EMPs and O&M programs, and maintain savings
over time. The following three recommendations aim to ease the challenges of compliance by focusing on
building capacity within institutions and in the market, as well as reducing the complexity of navigating the
legislation.
• Recommendation 5: Ensure public institutions have the human resources necessary for ongoing
compliance.
• Recommendation 6: Develop a comprehensive CBPS program to holistically support all aspects of
compliance.
• 6a. Develop comprehensive and interactive support tools.
• 6b. Invest in commercial sector market development.
• 6c. Expand outreach about CBPS and explore new outreach strategies.
• Recommendation 7: Develop the workforce capacity needed to deliver a low energy, decarbonized, grid
integrated commercial building stock.
Regulatory and policy alignment
The final recommendations propose strategies to align Washington's existing goals, resources, and programs.
These include adjusting CBPS to introduce new compliance pathways and enhance flexibility while maintaining
alignment with the state's energy objectives. Additionally, a review of current legislation is recommended to
ensure coherence across the regulatory landscape. Finally, the recommendations offer strategies to
strengthen long-term grid resilience and create new opportunities for building owners.
• Recommendation 8: Adjust CBPS to better match the needs of building owners and managers.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 6
• 8a: Align and create more clarity on energy efficiency and greenhouse gas (GHG) emission reduction
goals.
• 8b: Develop additional new compliance pathways and tools.
• Recommendation 9: Ensure alignment between various pieces of existing legislation and CBPS.
• Recommendation 10: Incentivize building owners to transition their buildings and campuses into grid
interactive assets.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 7
Introduction
In 2023, the Washington State Legislature passed a proviso directing the Washington State Department of
Commerce (Commerce) to convene a workgroup to analyze the financial investments required for owners of
Tier 1 covered buildings — that is, commercial buildings greater than 50,000 square feet—to comply with the
state’s Clean Buildings Performance Standard (CBPS) and to make recommendations to the Legislature to
assist building owners in attaining compliance. 4 There are approximately 8,000 tier 1 buildings in Washington
state.
CBPS is designed to secure energy efficiency and reduce greenhouse gas (GHG) emissions from Washington’s
existing large building stock. It is a key policy to meet the state’s statutory emissions limits established in 2020
and to implement the Washington 2021 State Energy Strategy. 5,6
The 2023 proviso required Commerce to submit two deliverables to the Legislature. An analysis of financial
investments was submitted by December 15, 2023, and this final report with recommendations is due by
September 1, 2024. To support this process, Commerce contracted with SBW Consulting in partnership with
Unrooz Solutions and 2050 Institute (“SBW team”) in September 2023 to facilitate a Clean Buildings Workgroup
to review the financial analysis and make the recommendations to the Legislature.
Preliminary analysis of financial investments was conducted and included in the December 15, 2023 memo to
better understand costs and other barriers to compliance with CBPS. The memo provides insight into the
landscape of Tier 1 building types in Washington, the percentage of buildings that likely already comply with
CBPS energy use intensity targets (EUIt), and preliminary analysis of the financial investments required by non-
complying buildings to meet their EUIts.
This final report builds on the previous analysis conducted for the preliminary analysis in December 2023. It
describes the Workgroup facilitation process and the financial analysis methodology, which included
additional compliance cost analysis, a cost survey of Workgroup members, and case studies of six buildings to
improve cost estimates. The report also presents an overview of key barriers to CBPS compliance as well as a
list of compliance success factors identified by the Workgroup. The report concludes with a prioritized list of
Workgroup recommendations, each including the rationale for the recommendation and implementation
strategies. The appendix includes more detailed information on the methodology, results, and Workgroup
input.
Background
Buildings are the most rapidly growing source of greenhouse gas emissions in Washington. The buildings
sector is the state’s second-biggest carbon polluter behind transportation, accounting for 27% of statewide
emissions.
The Washington State Legislature passed the Clean Buildings Law in 2019 (SHB 1257; Chapter 285, Laws of
2019) to create an energy performance standard for existing large buildings in Washington. The purpose of the
law is to improve energy efficiency in new and existing buildings and to maximize reductions of greenhouse
gas emissions from the building sector.
4 Chapter 474, Laws of 2023
5 RCW 70A.45.020
6 State Energy Strategy
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Commerce was charged with establishing the standard through rulemaking and developing the administrative
framework for building owners to document compliance with the law. Commerce established the Clean
Building Performance Standard (CBPS) energy use intensity targets (EUIt) in 2020 through a robust public
process. The initial CBPS applied to commercial buildings greater than 50,000 square feet. These buildings are
now referred to as Tier 1 buildings. Subsequent expansions to the Clean Buildings Law extended it to include
Tier 2 buildings, which includes smaller commercial buildings greater than 20,000 to 50,000 square feet and all
multifamily buildings greater than 20,000 square feet.
Tier 1 compliance dates are based on Tier 1 building size cohorts and begin in 2026, continuing through 2028.
Energy use intensity (EUI) used for compliance must be measured in a 12-month period not to exceed two
years prior to the compliance deadline. Compliance is a building owner’s responsibility and must be
documented on a five-year compliance cycle. Commerce is required to update CBPS targets every five years.
According to this schedule, the second cycle of CBPS targets will be updated in 2029 with compliance dates
between 2031 and 2033.
Recommendation and strategy development methodology
The SBW Team, including SBW Consulting Inc., Unrooz Solutions, and the 2050 Institute, facilitated the
Workgroup from November 2023 to July 2024. Workgroup members participated in one-on-one interviews,
Workgroup meetings, and online and offline feedback tools in order to develop 10 recommendations and 57
strategies to support building owners and managers with CBPS compliance.
Workgroup limitations
Representatives of the public sector composed more than half of the Workgroup, and there was limited private
sector representation as directed by the proviso language. 7 To address this, private sector representatives
were given additional opportunities to highlight key challenges and add context to the recommendations.
Phase 1: Understanding the barriers to compliance
The process began with one-on-one interviews to build trust and identify perceived barriers to compliance.
These barriers were compiled, discussed, and refined through meetings, feedback, and surveys. The perceived
barriers to compliance are presented briefly here, but each barrier has additional complexity which will be
presented in the rationale for each recommendation.
Perceived barrier Explanation
Data Buildings may not have enough data to guide their energy efficiency work.
Timelines Completing all the work necessary for compliance in the existing timeline may be unrealistic.
Awareness Many building owners could still be unaware that the legislation exists.
Budgeting process Public institutions have specific budgeting requirements that may not align with CBPS needs.
Costs The costs of compliance may be unreasonable for building owners and managers, particularly
amidst the commercial building market downturn.
Legislative overlap Multiple pieces of legislation regulate building energy use and emissions.
7 The original composition of the workgroup included 13 public sector representatives, 5 private sector representatives, 2 utility
representatives, and 2 non-profit representatives.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 9
Perceived barrier Explanation
Unreliable savings Buildings may not reach the required EUIt, even after a retrofit. Energy savings may be negated
by the additional costs of compliance or may not appear to leadership due to rising utility costs.
Value proposition Leadership may struggle with compliance due to competing internal priorities and potential
disruptions to tenants and key services, and rising utility costs may make it difficult to account
for savings.
Internal capacity Institutions may lack the internal capacity required to understand and implement the upgrades
and maintain energy savings long term.
Deferred maintenance Many public institutions are managing long lists of deferred maintenance which also require
significant resources.
Grant challenges It may be difficult to access grants and incentives.
Supply chains / There are concerns about long wait times for equipment, rising prices, and a lack of workforce
inflation capacity.
Grid concerns If electrification is required, there are concerns about grid capacity, energy costs, and resilience.
Old/unique buildings These types of buildings can be very difficult to bring into compliance.
Phase 2: Identifying compliance success factors
In the second phase, the Workgroup reflected on key compliance challenges and explored existing resources
to determine what was still needed to support Tier 1 building owners and managers. The key challenges from
the barriers were reorganized into seven key compliance success factors, presented here. Each success factor
was the focus of strategy brainstorming workshops.
Compliance success
Explanation
factor
Awareness & Key decision-makers in buildings are aware of the legislation, see the value in compliance, and
leadership buy-in are supportive of the compliance journey.
Benchmarking & Building owners and managers can benchmark their buildings and access audits affordably, on-
audits time, and in a way that meets the needs of the legislation.
Financing Building owners/managers can access loans, grants, bonds, and other sources of funding to
cover the costs of compliance.
Retrofits & capital Building owners/managers can plan for and implement energy efficiency measures to meet
planning compliance requirements on time.
Sustained savings Once buildings are compliant with CBPS, building owners and managers can sustain the savings
long term.
Staff & market Building owners/managers have an appropriate level of staffing to achieve and maintain
capacity compliance; there is enough capacity in the market to meet both workforce demands and supply
equipment.
Overall resource & The various resources and legislation that affect building energy use in Washington are aligned
legislative alignment and easy to access and understand.
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Phase 3: Developing recommendations and strategies for each success factor
In the final phase of the Workgroup process, several workshops led to the development of 57 potential
compliance strategies, which were distilled into ten high-level recommendations. These recommendations
were refined through engagement with Workgroup members and external stakeholders and informed by the
results of the financial analysis. Workgroup members were invited to score the recommendations and
strategies; the results of this scoring process are presented in Appendix B: Detailed Workgroup input. The final
recommendations offer a stakeholder-informed roadmap for supporting building owners and managers in both
the public and private sector in compliance with the Clean Buildings Performance Standard.
All strategies and recommendations are intended to be actionable by the Washington State Legislature unless
otherwise named within the strategy.
Financial analysis methodology and limitations
Regional
The financial analysis conducted for this work assessed the costs and benefits of energy efficiency measures
throughout the lifetime of the measure for Tier 1 buildings. The scope of the analysis was limited to the energy
use intensity target (EUIt) compliance pathway and only included buildings meeting CBPS targets in their
current condition or meeting CBPS targets through implementation of cost-effective measures. Assumed
savings were amortized over a 20-year measure life for all measures. 8 Building level data from the City of
Seattle was used to estimate typical EUI compliance deficits and costs of compliance, since statewide data
will not be available until after the first compliance cycle. Costs assessed included first-cost, operations and
maintenance, and interest expenses. The outputs of the analysis provide a list of measures that a building
owner could install to comply with CBPS EUIts.
Data sources included 2019 City of Seattle Energy Benchmarking data, 2021 Northwest Power Plan, Puget
Sound Energy's 2023 Gas Integrated Resource Plan, United States Energy Information Administration (EIA)
statewide commercial energy costs, and the Wall Street Journal's trailing 12-month average financing rate. The
costs and benefits of measures in the council plan were estimated using the Power Council's ProCost
software. All measures used in the analysis are "retrofits" to reflect higher incremental costs of equipment
replacement. Retrofit measures do not include baseline costs of a "code equivalent" replacement. This
approach does result in reduced savings potential from not including "major renovations/new construction"
measures. The 2021 Power plan baseline model includes other regional planning benefits which were removed
from this analysis to better reflect a consumer level cost test. Energy benefits were combined into kBtu to
allow for both gas and electric measures.
Supply curves were created for buildings that would need to implement measures to comply with CBPS. Supply
curves containing all applicable electric measures were created based on building activity types in
combination (e.g., a building with a restaurant and an office would receive all measures for both use types).
Lifetime costs included a discount of 3.75% based on ProCost Estimates, which includes a 2% inflation rate
over the 20 year measure life. Energy costs also inflated at a rate of approximately 2% over the span of a
8 Note that the EUIt compliance pathway is not limited to cost-effective measures while the investment criteria pathway only requires
implementation of cost-effective measures. For more detailed information on the compliance pathways, see the materials in the CBPS
Document Library, https://www.commerce.wa.gov/growing-the-economy/energy/buildings-archive-page/clean-buildings-performance-
standard-document-library/
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measure life. Measures were applied to each building as needed to meet the EUIt for the building starting with
the most cost-effective.
Cost survey
Based on Workgroup feedback following the presentation of the regional financial analysis, we developed a
questionnaire for building managers and operators about non-retrofit costs, or operational costs. For the
purposes of this work, we define “operational costs” to be expenses such as staff time for compliance
planning including navigating resources for financial and technical assistance, soliciting and hiring third party
service providers, benchmarking, conducting energy audits and measurement and verification (M&V),
developing the O&M program and Energy Management Plan, and ongoing efforts to sustain compliance. These
costs do not include expenses directly related to the planning, materials, and labor associated with capital
retrofit projects being implemented for the purposes reducing energy use to comply via meeting the target or
the investment criteria path. The cost survey questionnaire is provided in Appendix A: Financial analysis under
Cost Survey Protocol.
We assembled a list of approximately 50 benchmarked Tier 1 buildings from the state catalog, exports from
Commerce’s Energy Star Portfolio Manager (ESPM) account, and Clean Buildings Accelerator program
participants. We sent the cost survey to each of the unique organizations in the list primarily via the Property
Data Manager (PDA) provided in Energy Star Portfolio Manager or the Workgroup member. We also sent the
cost survey to Workgroup members.
From these responses, we recruited buildings into our case studies and analyzed the operational costs,
particularly compared to the retrofit costs and penalties for non-compliance. Anonymized, detailed responses
are provided in the Appendix A: Financial analysis. It is important to keep in mind the following characteristics
of the survey responses:
• The building data available for compiling the list of organizations that the cost survey was sent to is not
representative of Tier 1 buildings, and further limiting the representativeness is the disposition of the
survey respondents, which were heavily skewed to public sector, particularly community colleges.
• The starting list came primarily from benchmarked buildings, which is likely a small percentage of Tier 1
buildings in the state outside of Seattle. Benchmarked buildings are more likely professionally managed.
Buildings that have not been benchmarked and/or are not professionally managed are likely to be farther
behind in understanding the costs and resources associated with compliance and may face higher costs
than reported through the survey.
• Even among Seattle's benchmarked buildings, the organizations are often not far along in the process of
compliance planning and provided ballpark estimates of costs in most cases. 9 In many cases these
organizations did not provide a response to a question if they had not estimated that cost yet.
• Organizations made different assumptions about what to include in the costs they provided, e.g., whether
to include the costs of recruiting or training staff or outsourcing to contractors, ongoing costs in addition to
first year costs, etc. Furthermore, we were not able to verify the provided costs, i.e., they are self-reported.
Case studies
The purpose of the case study analyses was to refine our preliminary financial analysis and improve
estimates of compliance costs. We identified six buildings across Washington for in-depth analysis, aiming
to represent a diverse range of Tier 1 buildings. For this task, the SBW team consisted of SBW engineers and
9 An exception is that some of the community colleges are much farther along and were able to provide more realistic cost estimates.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 12
engineers subcontracted for their expertise in conducting energy audits, estimating costs, and aiding
customers in CBPS compliance.
We chose buildings from our cost survey responses, considering geographic region, floor area, percentage EUI
over target, and building type. Despite efforts to ensure diversity, this small sample is not comprehensive and
is not representative of all Tier 1 buildings.
Of the six buildings, four were recruited from survey responses. With the given budget, we were able to analyze
the top three energy-saving measures per site. It is important to note that the three measures may not be
sufficient for the sites to meet EUI targets. Due to low survey response rates, an additional two buildings were
recruited from Workgroup participants. For the two buildings recruited from the Workgroup, we used existing
measure analyses for these sites. For those two sites, one implemented two measures in their building, and
the other implemented a single whole-building measure.
For each of the six buildings, we:
• Held initial calls with site staff.
• Conducted on-site data collection visits.
• Identified the top three measures for analysis.
• Estimated energy savings and costs for each measure.
• Estimated non-measure compliance costs.
• Determined the cost-effectiveness of each measure.
We provided regular updates to the Workgroup, culminating in a presentation of findings on June 26, 2024.
Limitations
The limitations of this study should be carefully considered when interpreting the results. Here are some key
limitations to highlight:
Sample size and representativeness
The case study sample of six buildings is extremely small and not statistically representative of the broader
population of Tier 1 buildings. While efforts were made to select diverse buildings, the results cannot be
generalized to all Tier 1 buildings. Each building is unique in terms of its characteristics, energy usage patterns,
and potential for improvements. The City of Seattle benchmarking data used for the supply curve retrofit cost
analysis also may not be an adequate representation of statewide buildings. Additionally, the number of
operational survey respondents was also not a representative sample. Several Workgroup members explained
that they were not far enough in their compliance efforts to provide reliable responses to the operational cost
survey.
Measure selection and analysis
Only the top three energy-saving measures were identified and analyzed for each case study site due to budget
constraints. This limited scope means that the analyzed measures may not be sufficient to bring buildings into
compliance with their EUI targets. Additionally, other potentially cost-effective measures were not evaluated.
Data collection challenges
Four buildings were recruited from survey responses, and two were recruited from Workgroup participants due
to low customer response. For the two Workgroup participant buildings, existing measure analyses were used,
with only one or two measures implemented, further limiting the data.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 13
Cost estimation limitations
Operational costs are one-time costs, not amortized over time. There are inconsistencies in how costs were
estimated across sites — some provided full costs while others provided estimated incremental costs.
Public sector bias
The data collected for the financial analysis may have an overrepresentation of public sector buildings, similar
to the Workgroup itself, which potentially skews the findings.
Scope of analysis
This study provides indicators and examples of costs and savings, rather than a comprehensive measurement.
The results should be viewed as illustrative case studies rather than definitive cost data for compliance.
Inflation rates
Workgroup members expressed concerns about electricity costs rising at a faster rate than 2% inflation. A
higher inflation rate for electricity costs would increase the cost saving benefits of energy saving measures.
These increased benefits would be somewhat offset by rising costs of materials and labor. Rising electric
energy costs could also discourage electrification and mean that building owners and managers see rising
overall utility bills even after implementing energy saving measures.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 14
Recommendations: Financial support and incentives
To achieve compliance via the EUIt pathway or the investment criteria pathway, building owners and managers
need to implement energy saving measures. These capital expenditures will vary significantly from building to
building but can be extensive. Energy saving measures will lead to cost savings over time, but some measures
have long payback periods and building owners still need capital for the upfront investment. The first four
recommendations are focused on unlocking financing for the financial investment required for compliance.
• Recommendation 1: Explore creative ways to unlock financing for all sectors.
• Recommendation 2: Increase the funds in programs that support CBPS compliance and reduce the barriers
to accessing public funding opportunities.
• Recommendation 3: Assist utilities to support building owners with CBPS while following the conservation
rules and standard practices set by the State Energy Independence Act.
• Recommendation 4: Enable funding mechanisms to make energy audits more cost-effective.
All strategies and recommendations are intended to be actionable by the Washington State Legislature unless
otherwise identified.
Financial analysis results - Capital costs
Total costs and energy use from the proposed case study projects were analyzed in a modified 2021 NWPCC
Power Plan model and Commerce's LCCA tool (version 3.25.24).
The following summarizes key differences between the two approaches:
2021 Power Plan Model
• Uses a Total Resource Cost Test (TRC).
• Calculates the ratio of lifetime cost benefits to be lifetime incurred costs.
• Considers measures with a cost-benefit ratio of 1.00 or higher as cost-effective.
• Provides a comprehensive view of long-term project value.
Commerce LCCA Tool
• Uses Savings-to-Investment Ratio for cost-effectiveness (both for individual measures developed from
audits and for the optimized measure bundle entered into form F).
• Deems an optimized bundle of measures cost-effective if their saving-to-investment ratio is greater than or
equal to 1.00.
• Study period is based on longest measure life.
Key findings
Our analysis found the cost-effectiveness metrics between the tools used yielded mostly similar outcomes,10
namely, that it may be challenging to find cost-effective bundles of measures to achieve adequate EUI
reduction. Some measures in both analysis methods were cost effective even if the bundle for the building was
not. Even though the EUIt pathway does not require cost-effective measures, building owners will likely only
implement cost-effective measures or seek financial assistance such as grants, incentives, or tax credits to
that will reduce lifetime costs to be in line with lifetime benefits.
10 Both tools found two projects cost-effective, one they disagreed on, and both tools found three projects not cost-effective.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 15
Figure 1 and Figure 2 show the output of the project cost effectiveness tools. Energy savings and total project
upfront costs are on the primary y-axis (blue and red respectively), and cost testing results are on the
secondary y-axis (green dots). The horizontal red line on each graph represents cost-effective measures, either
above 1.00 for TRC in the first graph or below 12 years payback time in the second graph.
Measure Package Cost Effectiveness
90.0 6.00
Savings (kBTU/Sqft) & Costs ($/sqft)
80.0
Cost Effectiveness (TRC B/C)
5.00
70.0
60.0 4.00
50.0
3.00
40.0
30.0 2.00
20.0
1.00
10.0
0.0 0.00
Case Study ID
EUI Savings (kBTU/sqft) Total Project Cost ($/sqft) TRC B/C Ratio
Figure 1: Case study results analyzed with 2021 NWPCC Power Plan
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 16
Measure Package Cost Effectiveness
90.0 250
Savings (kBTU/Sqft) & Costs ($/sqft)
80.0
70.0 200
Payback (Years)
60.0
150
50.0
40.0
100
30.0
20.0 50
10.0
0.0 0
Case Study ID
EUI Savings (kBTU/sqft) Total Project Cost ($/sqft) LCCA Payback
Figure 2: Case study results analyzed with Commerce LCCA tool
Recommendation 1: Explore creative ways to unlock financing for all
sectors.
Rationale
Complying with CBPS creates new costs for building owners and managers. Some are one-time costs like
developing the O&M plan, or may be required once per compliance cycle, such as energy audits and retrofits.
Other costs will be ongoing, such as implementing and maintaining the O&M Program and EMP. The
Workgroup proposed several strategies to facilitate both the public and private sector access to new financing
tools such as market development, green revolving funds, and clarity on public budgeting processes.
The commercial real estate market is facing a uniquely challenging downturn due to COVID-19 and the ongoing
shift to remote work. King County Assessor John Wilson expects commercial building values in downtown
Seattle to drop by 35-40% in 2025. 11 Nationwide, $1.5 trillion in commercial loans are due for refinancing
before the end of 2025, 12 and in a high-interest rate environment. Long lasting and higher vacancies, lower
building values based on lower long-term leases at reduced rates, and the timing of refinancing are all leading
11 https://www.kuow.org/stories/downtown-seattle-office-values-are-dropping-like-overripe-plums-that-s-not-all-bad
12 https://www.bloomberg.com/news/articles/2023-04-08/a-1-5-trillion-wall-of-debt-is-looming-for-us-commercial-
properties?embedded-checkout=true
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 17
to loan defaults and bankruptcies which exacerbate banking turmoil. CBPS is an additional capital expense on
top of many competing priorities, and so additional funding sources are needed to support private building
owners.
Commercial Property-Assessed Clean Energy and Resilience (C-PACER) and Energy Efficiency as a Service
(EEaS) models are examples of innovative financing options, but Workgroup members were clear that there is
no one-size-fits-all solution. A combination of strategies should be employed to reach different building types.
While there are cost-saving benefits to energy efficiency, rising utility costs can make it harder to account for
savings year over year as utility bills may remain the same or even increase despite reduced energy usage.
Additional efforts to increase the value proposition of energy efficiency projects through grant funding,
creative financing options, and public sector budgeting guidance can encourage compliance and increase buy-
in to CBPS.
In the public sector, public budgeting processes are not well aligned with the pace and scale of funding
required for compliance. Budgets are created every two years, along with 10-year capital plans. These
timelines provide little flexibility for responding quickly to CBPS requirements, specifically in the first cycle of
compliance. The capital management plan included in the EMP lays out the groundwork necessary to manage
future budgeting considerations related to CPBS compliance. Retrofit costs are funded from capital budgets,
while savings appear in the O&M budget. Auxiliary service buildings will need public funding to cover the costs
of compliance. Bond limits can reduce the public sector’s ability to use debt-based financing opportunities.
Additional guidance, and direction to the Office of Financial Management (OFM) for approving CBPS related
costs, can support public sector compliance.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
OFM should clarify that green revolving funds are permitted in public institutions, and how Budgeting
1.1 Public sector
they can be structured. process
Grant
OFM should clarify payback mechanisms for rebates/grants, and tax incentives such as the
challenges,
1.2 179-D tax deduction, so public institutions know how exactly a grant will impact their budget Public sector
budgeting
and know whether funds go to the institution or the state.
process
Share successful models of C-PACER to demonstrate the value of this kind of financing for
1.3 All sectors Costs
CBPS compliance.
Educational materials should be developed by the Washington Green Bank and promoted by Budgeting
All sectors
1.4 Commerce to educate building owners about green revolving funds. process
Investigate the potential benefits and barriers of energy as a service for privately owned
Private
buildings and recommend pathways to develop the market for energy service agreements to Costs
1.5 sector
support CBPS compliance.
Allow non-profits to access the same state-led CBPS funding opportunities as the public
Non-profits Costs
1.6 sector.
Costs, grant
1.7 Lower the bond approval for schools to 50%. Public sector
challenges
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 18
Potential Barrier(s)
Strategy
beneficiary addressed
Accelerate the C-PACER market by promoting market awareness, consistency, economies of
1.8 scale and interconnectivity with policies and programs such as the energy code, utility All sectors Costs
programs, and market transformation programs.
Recommendation 2: Increase the funds in programs that support
CBPS compliance and reduce the barriers to accessing public
funding opportunities.
Rationale
Compliance with CBPS may involve significant spending by building owners and managers. Costs include
energy saving measures, but there are also additional compliance costs which are not immediately reflected in
energy savings such as measuring energy use, completing paperwork, and undertaking energy audits. While
building owners and managers will enjoy the benefits of improved energy efficiency, they must first contend
with upfront costs. To maximize compliance, unlock the individual and societal benefits or energy efficiency,
and avoid undue burden on individual building owners and managers, existing state funding opportunities
should be increased. Public funding opportunities should also be made available to the private sector. Existing
resources can be better promoted and made easier to access to reduce the administrative burden for
accessing grants and support.
If the costs of compliance are entirely passed on to building owners and managers, there are potential
consequences in both the public and private sectors. In the public sector, service delivery may be impacted, or
service fees (such as tuition) may rise to cover the costs.
In the private sector, the impacts will vary based on the leasing structure. In buildings with long term triple net
leases, 13 costs will be borne by the tenants who are typically obligated to make repairs to meet government
mandates. These costs will affect businesses big and small. For buildings with short-term triple net leases,
costs will be borne by in-place tenants, by building owners for vacant spaces, and may be negotiated for new
leases. Property value will decline to the extent that the owner is responsible for paying for improvements and
to the extent that tenants reduce the rents they will pay for the building because of the required improvements.
For buildings with other lease types, the building owner will typically bear the costs. Values may decline
commensurate with the investment required. Reduced building values can then affect public sector budgets
through reduced property tax revenues.
13 "Triple net rent model: The tenants pay all operating expenses, including property taxes, insurance and repairs and maintenance,
either directly or by pass-through reimbursement to the landlord" (NAIOP).
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 19
Strategies
Potential
Strategy Barrier(s) addressed
beneficiary
Value proposition,
Direct OFM to approve funding requests from public agencies that couple additional
Public sector deferred
2.1 upgrades with compliance work in public institutions (ex. simultaneously address
maintenance
deferred maintenance and/or whole building upgrades along with CBPS compliance).
Guarantee that public institutions will receive the funding they need to implement Costs, budgeting
2.2 Public sector
required upgrades through the investment criteria pathway. process
Costs, grant
Appropriate public funding directly to agencies rather than being awarded as grants by
2.3 All sectors challenges,
Commerce. Grants for privately-owned buildings should be administered by Commerce.
budgeting process
Should the public vote to maintain the Climate Commitment Act, revenues should be Costs, value
2.4 All sectors
allocated to support CBPS compliance for both public and private buildings. proposition
Increase the funding in all Commerce programs that support compliance, especially the
Costs, value
2.5 'Energy Efficiency Retrofits for Public Buildings" program and the "Energy Audit for All sectors
proposition
Publicly-Owned Buildings" program.
Adjust the EUI requirement for the early adopter incentive to encourage applications Costs, grant
2.6 All sectors
and set reasonable EUI requirements across different building types. challenges
Increase the amount of funding in OSPI Small District Energy Assessment Grant
2.7 Public sector Costs
program.
Recommendation 3: Assist utilities to support building owners with
CBPS while following the conservation rules and standard practices
set by the State Energy Independence Act.
Rationale
Utilities have existing expertise in delivering energy efficiency programming, and connections with their
customers across the state. They have access to customer data (though there can be challenges in
transferring data from the customer level to the building level) and are familiar with state legislation and
resources. Overall, utilities are well positioned to offer CBPS support programs. The state can provide
additional resources and guidance to expand both the number of utilities which are offering support, and the
depth of offerings from each utility, while following the conservation rules and standard practices set by the
State Energy Independence Act.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Engage with qualifying utilities that are required to provide building owners utility data via
3.1 ESPM to identify barriers, case studies of successful approaches to providing ESPM data, and All sectors Data
to explore methods to provide support to assist utilities in converting their systems.
RCW 19.27A.170 – In section (8) change “For any covered commercial building with three or
3.2 more tenants” to include “or for any covered buildings required to comply with state or local All sectors Data
laws or mandates”.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 20
Potential Barrier(s)
Strategy
beneficiary addressed
Collaborate with Bonneville Power Administration to help public utilities develop and
3.3 implement compliance support programs, leveraging economies of scale for greater All sectors Various
efficiency and cost-effectiveness.
Study the resources required for utilities to provide ESPM automated upload and the
resources available to non-qualifying utilities under RCW 19.27A.170 – Sections (2) and (7), to
3.4 All sectors Data
determine if and how this requirement should be modified. The state should then implement
the findings of this study.
Explore methods to reduce the technical and cost barriers of entry to these programs by
enabling data sharing between utilities and between utilities and state; encouraging regional
3.5 organizations like BPA and NEEA to provide services to a wide range of utilities thus reducing All sectors Various
cost and risk; and exploring a state-level contract whereby utilities can opt into programs like
accelerators, thus reducing cost and risk.
Provide funding to utilities to provide CBPS support, such as accelerator programs and
3.6 All sectors Various
rebates.
3.7 Establish a utility grant to establish revolving door loan/financing options. All sectors Costs
Recommendation 4: Enable funding mechanisms to make energy
audits more cost-effective.
Rationale
An energy audit can be the first step to making smart investment decisions that ensure building owners
maximize the benefits of compliance and are able to reach compliance in time. An energy audit is required if
building owners and managers choose the investment criteria pathway for compliance; however, a full
ASHRAE Level 2 energy audit can be cost prohibitive. Making energy audits more accessible would support not
only CBPS compliance in the Tier 1 commercial building sector, but the entire built environment in Washington.
The Workgroup suggested some strategies to make audits easier and more cost effective, but additional
strategies for market development should be considered.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
4.1 Fund audits for non-profits. All sectors Data, costs
4.2 Make the cost of energy audits tax deductible. All sectors Data, costs
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 21
Recommendations: Organizational capacity and market
development.
Compliance requires more than implementing energy saving measures. Building owners and managers need to
understand the legislation, measure their energy use, develop O&M and EMP, and maintain savings over time.
These aspects of compliance can be expensive and require ongoing human resources, whether from the
existing building staff or external hires. The following recommendations are focused on building capacity
within institutions and in the market, as well as reducing the complexity of navigating the legislation.
• Recommendation 5: Ensure public institutions have the human resources necessary for ongoing
compliance.
• Recommendation 6: Develop a comprehensive CBPS program to holistically support all aspects of
compliance.
• 6a. Develop comprehensive and interactive support tools.
• 6b. Invest in commercial sector market development.
• 6c. Expand outreach about CBPS and explore new outreach strategies.
• Recommendation 7: Develop the workforce capacity needed to deliver a low energy, decarbonized, grid
integrated commercial building stock.
All strategies and recommendations are intended to be actionable by the Washington State Legislature unless
otherwise identified.
Financial analysis results - Operational costs
Figure 3 shows average results from the operational costs of compliance survey. The regional supply curve
estimated costs for a year of a commercial EMP are shown in the same chart for comparison to the EMP
development cost collected in the survey. The intent of the survey was to estimate annualized compliance
costs. When considered over a full compliance cycle, building owners may experience operational costs
equivalent in magnitude to capital costs to the building retrofits, such as those observed in our cases studies
and BOMA's study as shown in Appendix A: Financial analysis under BOMA study comparison. For example,
challenges with benchmarking that lead to high costs for that requirement include staff or contractor time to
survey the building(s) and identify space types and associated floor area, potential submetering costs, tenant
space data collection, data quality review and cleaning, and ongoing maintenance to keep benchmarking data
updated.
The full set of survey results can be seen in Appendix A: Financial analysis, under Tabulated Results.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 22
Operations Costs
$6.00
$5.00
Normalized Operations Cost ($/SF)
$4.00 Commercial EMP
Other
$3.00 Audit
OMP Development
$2.00 Benchmarking
EMP Development
$1.00
$-
Cost Survey Supply Curve
Figure 3: Operational cost data
Recommendation 5: Ensure public institutions have the human
resources necessary for ongoing compliance.
Rationale
Compliance and maintaining compliance with CBPS requires more than capital. Obtaining and maintaining a
high-performing building long-term requires ongoing capacity and knowledge. Human resources are needed to
understand the law, measure, and monitor energy use, develop, and manage energy efficiency projects, submit
compliance paperwork, and more. Retrocommissioning 14 was identified as an energy savings opportunity for
several buildings in the case study's financial analysis. This reflects the propensity of a building's efficiency to
drift over time if not properly managed. However, many organizations lack the capacity to maintain buildings in
their intended working order long term. Well-staffed teams to manage building operations and maintenance
can lead to greater occupant comfort, improved indoor air quality, energy savings, and more. This can be
achieved by both increasing staffing levels, and by reducing unnecessary demands on existing staff.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Increase pay scales in public institutions to be competitive with private sector Public Internal
5.1
compensation, including pay rates for contractors. sector capacity
14 Retrocommissioning is a process that seeks to improve how building equipment and systems function together. Depending on the
age of the building, retrocommissioning can often resolve problems that occurred during design or construction, or address problems
that have developed throughout the building's life. Building Commissioning: Definition (lbl.gov)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 23
Potential Barrier(s)
Strategy
beneficiary addressed
Internal
Require that public institutions have an energy manager or resource conservation Public capacity,
5.2
manager and provide ongoing state funding for the position. sector sustained
savings
Provide guidance to public institutions how to budget for CBPS: O&M vs capital budgets,
Public Budgeting
5.3 accounting for savings, prioritizing energy efficiency in budgets, grant payback
sector processes
mechanisms, etc.
Internal
Create dedicated energy teams within each state agency to support energy efficiency Public capacity,
5.4
work generally and CBPS compliance. sector sustained
savings
Review RCW 28A.150.260 to determine if minimum staffing allocations need to be Public Internal
5.5
adjusted due to increased staffing needs from CBPS. sector capacity
Recommendation 6: Develop a comprehensive CBPS program to
holistically support all aspects of compliance.
Sub-recommendations:
A. Develop comprehensive and interactive support tools.
B. Invest in commercial sector market development.
C. Expand outreach about CBPS and explore new outreach strategies.
Rationale
The Clean Buildings Performance Standard presents a significant regulatory change for Washington's built
environment. The level of knowledge and capacity that each building owner and manager has regarding energy
efficiency varies. Commerce should provide a comprehensive and well-resourced support program that
addresses all aspects of compliance, such as benchmarking, submetering, data measurement, and developing
an EMP and an O&M program.
The first barrier to compliance is becoming aware of the legislation. While Commerce has used several
strategies to reach building owners and managers, including physical letters, webinars, and outreach through
partners, the Workgroup is concerned that many building owners and managers may still be unaware of their
obligations under CBPS. Some building owners and managers may be aware of the requirements but
underestimate the importance of compliance and the possible consequences of non-compliance. The
Workgroup proposed several new strategies to support outreach to those who may have missed previous
communications.
Once they are aware of the legislation, building owners and managers need to understand the law, explore their
pathways to compliance, and identify resources available to support them. Commerce has developed guides, a
document library, workshops, and more, which already exist to support building owners and managers with
compliance. Members of the Workgroup expressed that having even more comprehensive and responsive
tools to navigate compliance could ease the compliance burden.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 24
The private market can deliver much of the expertise and demand needed to drive widespread compliance.
Making technologies more affordable and accessible, aligning state strategies around CBPS, and creating
market demand for energy efficient real estate can all drive resources into energy efficiency. These benefits
can also have impacts beyond Tier 1 buildings, and even beyond the commercial sector, by driving widespread
investment into energy efficient solutions.
Data access can also be a challenge, particularly in buildings without adequate metering, or buildings where
lease arrangements limit the building owners’ access to energy use data. Some strategies for supporting
submetering are presented. However, submetering is not always the best choice as it requires ongoing
maintenance and can be expensive. Other strategies include reducing barriers to accessing energy audits and
examining the investment criteria pathway to make it a more appealing option for building owners and
managers who do not have the data needed to follow the EUIt pathway.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Increase funding available to support building owners and managers with metering, including utility
6.1 meters to measure energy use at the individual building level and submeters to measure separate All sectors Data
end uses within buildings.
Internal
If support for sub-metering is provided to public institutions, it should be coupled with longer-term Public
6.2 capacity,
funding to maintain the meters and ensure data collection is continuous and accurate. sector
data
Internal
6.3 Create a more robust and comprehensively staffed Help Desk. All sectors
capacity
Create a dedicated online tool to help decision-makers navigate CBPS requirements. The tool
should cover: specific regional needs, comparison with other requirements such as Seattle's BEPS,
Internal
6.4 and should match the user with any available resources that apply to their building. The tool should All sectors
capacity
also present how resources can be combined, such as with conservation programs, renewable
programs or EV supports.
Value
Target outreach and training about CBPS to tenants and key financial and leadership decision
6.5 All sectors proposition,
makers.
awareness
Provide leadership and coordination at all levels to align everyone around CBPS: equipment
6.6 All sectors Various
manufacturers, colleges and apprenticeships, utilities, OFM, etc.
Costs,
Fund large-scale market transformation and cost compression efforts to remove barriers and
value
accelerate adoption of the highest impact commercial retrofit solutions, such as rooftop unit heat
6.7 All sectors proposition,
pumps, dedicated outside air systems, ERVs, retrocommissioning, onsite solar, strategic
supply
sequencing, etc.
chains
6.8 Develop a cost sharing model for third party benchmarking service. All sectors Data, costs
6.9 Expand physical presence for outreach about CBPS. All sectors Awareness
6.10 Offer grant funding for cities to hire dedicated staff to promote and educate on CBPS. All sectors Awareness
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 25
Recommendation 7: Develop the workforce capacity needed to
deliver an energy efficient commercial building stock.
Rationale
To achieve widespread compliance, it is essential to have a well-trained workforce capable of implementing
energy efficiency measures and maintaining savings. CBPS compliance may require both capital projects to
reduce energy use and the development, implementation, and ongoing maintenance of an EMP and an O&M
program. Capital projects will require cyclical increases in staffing demands, while the ongoing requirements
may increase staffing needs long term. Workgroup members have reported challenges in finding and retaining
qualified staff, as well as difficulties in hiring external contractors at reasonable rates across the state.
Workforce development efforts must keep pace with the growing demand for energy-efficient buildings.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Explore creative strategies to increase the number of BOC 2 certified individuals, such as a Internal
7.1 All sectors
scholarship program. capacity
Internal
7.2 Fund energy fellows across Washington. All sectors capacity,
costs
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 26
Recommendations: Regulatory and policy alignment
The final recommendations propose strategies to align Washington's existing goals, resources, and programs.
These include adjusting CBPS to introduce new compliance pathways and enhance flexibility while maintaining
alignment with the state's energy objectives. Additionally, a review of current legislation is recommended to
ensure coherence across the regulatory landscape. Finally, the recommendations offer strategies to
strengthen long-term grid resilience and create new opportunities for building owners.
• Recommendation 8: Adjust CBPS to better match the needs of building owners and managers.
• 8a: Align and create more clarity on energy efficiency and GHG reduction goals.
• 8b: Develop additional new compliance pathways and tools.
• Recommendation 9: Ensure alignment between various pieces of existing legislation and CBPS.
• Recommendation 10: Incentivize building owners to transition their buildings and campus into grid
interactive assets.
All strategies and recommendations are intended to be actionable by the Washington State Legislature unless
otherwise indicated.
Recommendation 8: Adjust CBPS to better match the needs of
building owners and managers.
Subrecommendations
A. Align and create more clarity on energy efficiency and GHG reduction goals.
B. Develop additional new compliance pathways.
Rationale
There have been ongoing and comprehensive efforts to update CBPS through rulemaking and engagement,
resulting in important additions and changes. The Workgroup has expressed that there are still opportunities to
better align the needs of building owners and managers with the details and intent of the law. Small
adjustments, particularly in the early compliance cycles, can provide options for building owners and managers
who intend to comply with the law but need additional time or flexibility.
Additional compliance pathways can offer building owners and managers much-needed flexibility, particularly
in early cycles as building owners and managers are learning about the legislation and developing O&M and
EMP programs for the first time. For example, building owners and managers in the commercial real estate
market may need additional flexibility as they navigate a difficult real estate market due to COVID-19 and high
office vacancy rates. Building owners and managers may also need flexibility to ensure that key service
delivery is not disrupted, such as housing prisoners securely, students attending classes, and life science and
medical research.
The CBPS offers three pathways to compliance, including compliance through exemption, meeting the EUIt,
and the investment criteria pathway. The Workgroup proposed several new pathways to compliance which
could ease administrative burdens, extend deadlines, and recognize unique extenuating circumstances. These
changes could bring more buildings into compliance while still maintaining the intent of the law.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 27
Workgroup members also recognize the longer-term state trajectory towards decarbonization which is not
currently reflected in CBPS. Building owners and managers would like to have greenhouse gas emissions
reductions recognized and supported within their buildings. At the same time, they have concerns about grid
capacity and grid resilience which should be addressed to ensure building owners can make thoughtful long-
term investments, even in early compliance cycles. In some parts of the state, electricity is currently more
expensive than natural gas, so fuel switching may increase ongoing operating costs.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Establish future EUIts to provide a clear investment pathway, allow buildings owners and
8.1 All sectors Various
managers to undertake long term planning, and to help drive market innovation.
Allow a building owners to request an extension if they are waiting for equipment with long Supply chains/
8.2 All sectors
lead times. inflation
Allow building owners to request an extension if they have begun but not completed their
8.3 All sectors Timelines
upgrade work or their measurement and verification.
8.4 Streamline and add flexibility to the conditional compliance pathway. All sectors Various
Create specific long-term energy efficiency, GHG reduction, and other performance related
goals for CBPS and establish flexible compliance paths that allow buildings to integrate Legislative
8.5 All sectors
multiple behind-the-meter strategies, not only energy efficiency, to demonstrate CBPS overlap
compliance.
Allow building owners to set an EUIt based on a percentage reduction in their current EUI as
8.6 All sectors Various
an alternative to prescribed EUI targets.
8.7 Accept compliance with equivalent legislation. All sectors Various
Allow building owners to request an extension if they can implement the EMP and O&M but
8.8 All sectors Timelines
need additional time to meet the performance metric.
Study the investment criteria pathway to determine how the pathway can be streamlined or
8.9 All sectors Various
improved.
Recommendation 9: Ensure alignment between various pieces of
existing legislation and CBPS.
Rationale
Workgroup members said that a growing number of policies, laws, and standards are determining how to
manage the built environment, but they do not necessarily align and are increasingly difficult to navigate.
Building owners are aware of the policies and plans such as the State Energy Strategy, Seattle’s Building
Emissions Performance Standard, the Washington Sustainable Schools Protocol, and the Climate Commitment
Act. CBPS upgrade work can also trigger compliance with the State Energy Code if the work is considered a
substantial alteration. Working towards better alignment between these pieces of legislation can reduce
administrative burdens and ensure resources are focused on achieving energy savings.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 28
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
The Department of Ecology should study refrigerant phase-outs to determine whether the Overlapping
9.1 All sectors
pace of phase-outs is impacting CBPS compliance. legislation
Overlapping
9.2 Get rid of LEED standard requirement for state buildings (RCW 35.39D). Public sector
legislation
Fund the Department of Commerce to increase its participation in the energy code
Overlapping
9.3 development process in order to identify and encourage alignment across the state energy All sectors
legislation
code, CBPS, and utility programs.
Recommendation 10: Incentivize building owners to transition their
buildings and campuses into grid interactive assets.
Rationale
Treating buildings like grid assets opens opportunities for building owners and managers, utilities, and the
future of state energy planning. When buildings can store, share, and generate energy, while also responding in
real time to grid demands to reduce energy loads, the grid becomes more resilient and building owners can
unlock new revenue streams. Planning projects like this across multiple buildings will increase the load-
management potential, making projects more appealing for utilities. However, state leadership is needed to
undertake demonstration projects and coordinate the stakeholders needed to unlock these opportunities.
Strategies
Potential Barrier(s)
Strategy
beneficiary addressed
Costs, value
10.1 Use the newly developing green bank to offer loans for large-scale projects which support All sectors proposition,
buildings as grid assets (local power generation, energy storage and load flexibility). grid concerns
Costs, value
10.2 Recognize and reward building owners who engage in grid-interactive energy planning (local All sectors proposition,
power generation, energy storage and load flexibility) in CBPS compliance process. grid concerns
Launch a workgroup between the Department of Commerce, the Utilities and Transportation
Commission, and other key stakeholders to develop a strategy for grid resilience through
10.3 All sectors Grid concerns
interactive and inter-building energy planning (through local power generation, energy storage
and load flexibility).
Work with utilities to undertake demonstration projects to show how buildings can act as grid
Costs, value
assets at scale (local power generation, energy storage and load flexibility), to better
10.4 All sectors proposition,
understand the potential benefits to both building owners and utilities, especially within the
grid concerns
context of CBPS compliance.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 29
Appendix A: Financial analysis
Case studies
The following table summarizes the sites recruited for the case studies.
Case Study Building Activity Type Region EUI EUIt Bin Floor Area Compliance Year
Central Puget
Case Study 1 Office Building 72 kBtu/sqft >50% >220k sqft 2026
Sound Area
Western
Case Study 2 Entertainment Facility 140 kBtu/sqft >50% 90k-220k sqft 2027
Washington
Hospital (Site is Eastern
Case Study 3 272 kBtu/sqft >50% >220k sqft 2026
review) Washington
Medical Office Western
Case Study 4 113 kBtu/sqft 15%-50% 50k-90k sqft 2028
Building Washington
College Science Western
Case Study 5 148 kBtu/sqft 15%->50% 50k-90k sqft 2028
Building Washington
Eastern
Case Study 6 Primary School 60 kBtu/sqft <15% 50k-90k sqft 2028
Washington
The next table summarizes the top measures identified for the case study buildings.
Building Type Proposed Energy Efficiency Measure Measure Category End Use kBtu/sqft Savings Measure Cost
1. VAV night setback RCx HVAC 8.0 $153,404
Medical Office
Building 2. High-performance VAV system RCx/Retrofit HVAC 8.8 $574,869
3. Boiler to ASHP Retrofit HVAC 20.7 $3,583,444
1. EMS Upgrade RCx HVAC 1.7 $2,700,000
High Rise Office 2. HVAC System VFDs RCx/Retrofit HVAC 9.1 $575,005
3. Heat Recovery Ventilation Retrofit HVAC 5.8 $8,410,424
1. Controls Retrocommissioning RCx HVAC 17.1 $27,878
University
(Lab Bldg) 2. Lab Fume Hood VFDs RCx/Retrofit HVAC 8.5 $83,225
3. Lab Demand Controlled Ventilation Retrofit HVAC 14.8 $270, 540
1. VAV Conversion/Optimization RCx/Retrofit HVAC 63.2 $1,714,933
Hospital
2. LED Lighting and Controls Retrofit Retrofit Lighting 5.5 $841,362
1. Kitchen Hood Controls RCx HVAC 10.4 $72,900
Entertainment
2. Kitchen Hood Night Setback RCx HVAC 16.1 $40,500
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 30
Building Type Proposed Energy Efficiency Measure Measure Category End Use kBtu/sqft Savings Measure Cost
3. Controls Retrocommissioning RCx HVAC 54.5 $64,048
K-12 School 1. Boiler Upgrade / Building Controls Upgrade RCx/Retrofit Whole Building 13.7 $495,846
Comparison with penalties
In addition to the results summarized above and described in detail in the case study memos below, the team
also considered the penalties each building would face for non-compliance. We observed that the costs of
compliance could be multiples of the fines. When the measure costs are combined with estimated operational
costs, the total annualized net lifecycle costs are in the range of 2 to 20 times the fines for potential non-
compliance penalties.
Also, note that the limited budget and time constraints on conducting the case studies prevented the team
from considering financial assistance to offset the measure costs. The measure costs could be offset some if
the sites participated in the state Early Adopter Incentive Program and/or utility programs or sought other
financial assistance through grants or federal tax credits.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 31
Medical Office Building - 102
To: Building Owner
From: Clean Buildings Team (SBW, Ecotope, UMC)
Subject: Medical Office Building Summary
Date: July 30, 2024
Site description
This Medical Office Building (MOB) is an 85,000 SF medical office building located in Vancouver, Washington.
This building is heated year-round, with the baseload for natural gas around 32 kbtu/sf/yr. This is likely a
combination of reheating the overcooled zones and domestic hot water (DHW) loads related to hot water
usage and temperature maintenance. The electrical baseload is around 68 kbtu/sf/yr, comprised of lighting,
plugs, fans, and miscellaneous loads.
The building is simultaneously heated and cooled when outdoor temps are between 54°F and 64°F.
Temperatures below 54°F are dominated by reheat which is typical with variable air volume (VAV) systems.
The temperatures above 64°F are dominated by cooling.
The controls and heat/cool setpoints in zones are likely causing a lot of simultaneous heating and cooling
associated with how the zoning is arranged. The VAV system critical zones are driving the VAV operation to
longer hours and reheating of the overcooled zones. There is upgrade work happening at this project, including
replacing the aging boiler with a new variable capacity gas boiler.
This building’s clean buildings target of 67 kbtu/sf/yr is going to take a lot of measures to get below this
target. There is some uncertainty regarding the classification of this building as a medical office building
(MOB). To better align the energy targets with actual usage, a weighted average is appropriate. A method for
weighting is outlined in Washington State Clean Buildings Performance Standard integrated document section
7.2.3. For this case study, it is an appropriate strategy for building owners to account for spaces with
Outpatient Surgery or Lab-like functions such as MRI and light surgery areas.
Current Stats
• Current EUI: 112 kbtu/sf/yr
• Current EUIt: 67 kbtu/sf/yr
• Heated Floor Area: 85,856 SF
Billing analysis
Medical Office Building
Gas energy use intensity had an inversely proportional relationship with outside air temperature until outside
air temperature reached 67 degrees Fahrenheit at which point its relationship with outside air temperature
became constant. Electric energy use intensity was constant until outside air temperature reached 54 degrees
Fahrenheit at which point its relationship with outside air temperature became proportional. See Figure 4 for
billing analysis.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 32
Annual Medical Office Building Energy Use by End Use
250,000
200,000
Estimated Energy Use (kWh)
150,000
100,000
50,000
0
1 2 3 4 5 6 7 8 9 10 11 12
Month
Space Heating DHW Lighting Cooling Fans Plugs and Misc
Figure 4: Annual energy use by equipment type for medical office.
Energy reduction measures
MEASURE 1: SETUP VAV MACHINES TO POWER OFF FOR OVERNIGHT SETBACK
• Investigate critical cooling zones for each of the air handling units (AHU’s). Decouple VAV from critical
cooling zones and install dedicated equipment for those zones. (Removing critical 24/7 cooling zones from
central VAV is required in current energy code (WSEC C403.7, requirement 14)). Assume each AHU’s
critical zone will be reassigned, any zone that is driving cooling usage should add a ductless heat pump to
handle cooling dominated zones and reduce primary air to those zones for ventilation.
• Assume four (4) ductless heat pumps are installed in all of the critical zones.
• Set up new critical zone for the AHU cooling system that has similar load profiles.
• Implement VAV temperature reset so that critical zone is not driving overcooling in the other zones and
forcing reheating year-round.
• Swap out gas range standing pilots for electronic ignition starters that allows the gas pilots to be turned off
overnight. This measure will allow the Type 1 grease fans to powered off during unoccupied hours. This
measure shall include adding both CO2, CO and natural gas detection measurement sensors and alarms to
the control system dashboard.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 33
MEASURE 2: IMPLEMENT HIGH PERFORMANCE VAV PER WSEC SECTION C403.7
This measure would implement the current WSEC section on high performance VAV systems. This measure is
focused on energy efficiency with supply temperature reset and demand-controlled ventilation, primary air
reset, primary ventilation air reset. This measure will require:
• VAV AHU’s:
• Calibrate outside air measurement stations and set up programming logic to control the outside air
dampers on 4 AHU’s as a sum of all of the ventilation demands in the zones.
• Implement supply air temperature reset for current AHU’s.
• Implement supply air flow reduction monitoring the zone level calls for heating and cooling.
• Reduce building pressure. The building is positively pressurized, which suggests over supply of ventilation
air and one or more return fans not turning on in the sequence.
• VAV Terminals:
• Replace ~50 VAV boxes with ECM fans and reheat coils sized for 120°F hot water.
• Install CO2 level monitoring of each VAV zone with feedback control directly to DDC and OSA damper.
MEASURE 3: REPLACE HOT WATER BOILERS WITH AIR SOURCE HEAT PUMPS
(ASHP)
This building has a gas EUI of 44 kbtu/sf/yr. This measure will implement energy efficient ASHP on the primary
heat plants at COP’s of 2.5. The current hot water reheat system will need to upsize current coils.
• Install new variable capacity ASHP hydronic plant to replace existing gas boilers.
• Assume two, 150 Ton ASHP’s to replace current hot water boilers.
• Assume 2,400 gallons of hot water storage between the heat pump and the building distribution loop. This
is required to accommodate heat pump defrost downtime.
• Install a variable frequency drive (VFD) on current hot water circulation pumps.
Measure savings
Base Measure 1 Measure 2 Measure 3
Electricity 3,800,525 3,610,499 3,074,749 38,836
Gas 5,908,455 5,416,685 5,195,803 6,460,779
Total (kbtu) 9,708,980 9,027,183 8,270,553 6,499,615
EUI 113 106 97 76
Measure costs
Measure EEM Low High Notes
includes mark-up, taxes, bonding,
Setup VAV machines to power
1 $138,063.73 $168,744.56 construction management, controls
off for overnight setback.
(estimate)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 34
Measure EEM Low High Notes
includes mark-up, taxes, bonding,
Implement high performance
2 $517,382.29 $632,356.13 construction management, controls
VAV per WSEC section C403.7.
(estimate)
includes mark-up, taxes, bonding,
Replace Hot Water Boilers with
3 $3,225,099.48 $3,941,788.25 construction management, controls
Air Source Heat Pumps (ASHP).
(estimate)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 35
Form-F Lifecycle Cost Assessment Summary
Project Information
Field Value
Project Building 102 Retrofit
Lifecycle Cost Analysis Results
Analysis Baseline Alternative
Net Present Savings 0 -$3,243,949
Savings-to-Investment Ratio (SIR) 0 0.08
Internal Rate of Return NA NA
First Construction Costs (minus Grants) $314,905 $4,311,717
Present Value of Capital Costs $297,442 $4,279,788
Present Value of Maintenance Costs $0 $0
Present Value of Utility Costs $1,472,138 $1,148,665
Total Life Cycle Cost (LCC) $1,769,580 $5,428,453
CO2 Emissions Reductions over Building Life by Energy Source
Energy Source Baseline (tons CO2e) Alternative (tons CO2e)
Electricity 3,565 3,898
Natural Gas 3,028 31
Diesel/#2 0 0
Fuel Oil/#5, #6 0 0
Gasoline 0 0
LPG 0 0
District Heat 0 0
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 36
Energy Source Baseline (tons CO2e) Alternative (tons CO2e)
Coal 0 0
Biomass 0 0
Total CO2 Emissions 6,593 3,929
CO2 Emissions Reductions 0 2,664
Percent Reductions 0 40%
Cost Summary in 2024 Dollars
Cost Item Baseline Alternative
Capital Expenditures $314,905 $4,618,526
Financing Expenses $141,053 $1,931,307
Residual Value at End of Study Period 0 0
CapEx Minus Avoided Costs & Grants $6,093,875 $6,093,875
Annual Costs and Benefits
Description Baseline Alternative
Annual Maintenance Expenses 0 0
Annualized Major Maintenance Expenses 0 0
Incremental Total Maintenance Expenses 0 0
Annual Utility Savings 0 $37,978
Annual Incentives 0 0
Annual Benefits minus Costs ($/year) 0 $37,978
Simple Payback (years) 0 160.5
Return on Investment (%) 0 1
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 37
Annual Savings Summary
Description Baseline Alternative
Water (CCF/year) 0 0
Electricity (kWh/year) 0 -161,829
Natural Gas (therms/year) 0 37,617
Diesel/#2 (gallons/year) 0 0
Fuel Oil/#5, #6 (gallons/year) 0 0
Gasoline (gallons/year) 0 0
LPG (gallons/year) 0 0
District Heat (MMBtu/year) 0 0
Coal (MMBtu/year) 0 0
Biomass (MMBtu/year) 0 0
CO2 Reductions through 2029 (tons/year) 0 133
CO2 Reductions 2030 and later
0 200
(tons/year)
* Electricity is assumed to be carbon neutral 2030 and later.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 38
Cumulative Cash Flow Report
$9,000,000
$8,000,000
$7,000,000
$6,000,000
$5,000,000
$4,000,000
$3,000,000
$2,000,000
$1,000,000
$-
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044
Baseline Alternative
Figure 5: Cumulative cash flow report: baseline vs. alternative (2024-2044)
$700,000
$600,000
$500,000
$400,000
$300,000
$200,000
$100,000
$-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Baseline Alternative
Annual Cash Flow Report
Figure 6: Annual cash flow report: baseline vs. alternative scenarios (2024-2044)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 39
High-Rise Office Building - 104
To: Building Owner
From: Clean Buildings Team (SBW, Ecotope, UMC)
Subject: High-Rise Office Building Summary
Date: July 30, 2024
Site description
High-Rise Office Building is a high-rise large office building in downtown Seattle. This building is served with a
dual duct HVAC system and zoned as 4 cardinal directions and a core zone. This building isn’t really set up for
partial occupancy so the system has to be turned on to full speed levels to operate. The building is fairly well
occupied currently. The building uses gas to heat the hot deck airstream and uses outside air for economizer
and chilled water fan coils for the cold side. Ventilation air is ducted in the return side of each of the air
handling units (AHU’s) and is set at constant volume.
The current building’s baseload electrical EUI is operating at around 40 kbtu/sf/yr, which are mostly lights,
plugs, fans and domestic hot water (DHW). The rest of the building’s EUI are temperature dependent loads,
heating, and cooling energy. The heating energy usage is roughly 15x the cooling energy, and economizer
cooling provides a lot of the cooling energy.
Energy measures should focus on reducing the heating energy with heat recovery ventilation and demand-
controlled ventilation (DCV) on the outside air. Further reductions can be had swapping out boilers for air
source heat pumps.
Current stats
• Current EUI: 68 kbtu/sf/yr
• Current EUIt: 43 kbtu/sf/yr
• Heated Floor Area: 269,000 SF; 17 stories
Billing analysis
High Rise Building
Gas energy use intensity had a steady inversely proportional relationship with outside air temperature. Electric
energy use intensity was constant until outside air temperature reached 54 degrees Fahrenheit at which point
its relationship with outside air temperature became proportional. See Figure 7 for billing analysis.
Annual High-Rise Office Building Energy Use by End Use
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 40
600,000
500,000
Estimated Energy Use (kWh)
400,000
300,000
200,000
100,000
0
1 2 3 4 5 6 7 8 9 10 11 12
Month
Heating Cooling Lighting Plugs Fans DHW Other
Figure 7: Annual energy use by equipment for a high-rise office building
Energy reduction measures
MEASURE 1: UPDATE CURRENT BMS TO FULL DDC CONTROL AND PROVIDE END
USE MONITORING FOR HEATING, COOLING AND VENTILATION ENERGY USAGE.
This update modernizes the current control systems to allow for full system monitoring. Assume the following
scope:
• Assume half of the building’s HVAC controls require upgrade.
• Demo current pneumatic system and replace it with modern direct digital control (DDC) systems.
• Add energy monitoring to all motors (fan and pumps) as well as speed feedback.
• Add temperature monitoring to all variable air volume (VAV) boxes and dual duct mixing fans.
• Reprogram current BMS and add in new control points.
• MEASURE 2: ADD VFD’S TO PRIMARY PERIMETER DUAL DUCT FANS AND PUMPS.
• Add VFD’s to current fans and pumps serving office heating and cooling. Set the hot water distribution and
primary AHU’s on temperature and pressure reset.
• Replace 6 primary AHU fan motors with new motors and VFD’s; assume 20 HP fans each.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 41
• Replace 2 primary heating pumps used for perimeter heating loop control with VFD’s (10 HP each).
• Implement pressure reset for the primary VFD AHU’s and VFD pumps.
• Implement outdoor reset supply air and supply water temperatures for the building.
• Reprogram BMS to monitor and display new VFD monitoring.
MEASURE 3: ADD HEAT RECOVERY VENTILATION TO ALL OF THESE AHU ZONES.
USE DOAS VAV WITH HEAT RECOVERY WHEEL TO SUPPLY ALL EXISTING AHU
ZONES.
Assume this system is sized at peak ventilation flow for the building, roughly 100,000 CFM. Economizer
dampers in this dedicated outdoor air system (DOAS) supply shall be added to allow the AHU’s that feed the
tower to use economizers.
• Add energy recovery ventilation (ERV) DOAS unit with VAV zoning and setup to feed each of the 5 primary
zones.
• 100,000 CFM DOAS unit with heat wheel (75%).
• Re-program controls to setup pressure control for the DOAS unit as well as existing economizer control.
Measure savings
Base (2023 bills) Measure 1 Measure 2 Measure 3
Electricity 10,904,023 10,685,942 9,806,065 10,023,560
Gas 7,889,423 7,652,742 6,074,872 4,299,768
Total (kbtu) 18,793,445 18,338,684 15,880,937 14,323,328
EUI 72.3 70.5 61.1 55.1
Base Measure 1 Measure 2 Measure 3
Gas (therms) 78,894 76,527 60,749 42,998
Electricity (kwh) 3,194,850 3,130,953 2,873,151 2,936,877
Measure costs
Measure EEM Low High Notes
Update current BMS to full DDC
includes mark-up, taxes, bonding,
control and provide end use
1 $2,430,000.00 $2,970,000.00 construction management, controls
monitoring for heating, cooling,
(estimate)
and ventilation energy usage.
includes mark-up, taxes, bonding,
Add VFD’s to primary perimeter
2 $517,504.94 $632,506.04 construction management, controls
dual duct fans and pumps.
(estimate)
includes mark-up, taxes, bonding,
Add heat recovery ventilation
3 $7,569,381.97 $9,251,466.85 construction management, controls
(HRV) to all of these AHU zones.
(estimate)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 42
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 43
Form-F Lifecycle Cost Assessment Summary
Project Information
Field Details
Project Building 104 Retrofit
Life Cycle Cost Analysis Results
Alternative (HVAC boiler upgrades and
Category Baseline
RCx)
Net Present Savings 0 -$7,883,818
Savings-to-Investment Ratio (SIR) 0.06
Internal Rate of Return NA
First Construction Costs (minus Grants) $2,295,000 $11,685,429
Present Value of Capital Costs $5,267,304 $14,683,956
Present Value of Maintenance Costs $0 $0
Present Value of Utility Costs $2,814,885 $2,256,908
Total Life Cycle Cost (LCC) $8,082,189 $16,940,864
CO2 Emissions Reductions over Building Life by Energy Source
Energy Source Baseline (tons CO2e) Alternative (tons CO2e)
Electricity 6,579 6,048
Natural Gas 6,286 3,426
Diesel #2 0 0
Fuel Oil/#5, #6 0 0
Gasoline 0 0
LPG 0 0
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 44
Energy Source Baseline (tons CO2e) Alternative (tons CO2e)
District Heat 0 0
Coal 0 0
Biomass 0 0
Total CO2e Emissions (tons) 12,865 9,473
CO2e Emissions Reductions (tons) 3,391
Error! Not a valid link.Error! Not a valid link.Cost Summary in 2024 Dollars
Alternative (HVAC boiler upgrades and
Category Baseline
RCx)
Capital Expenditures Over Study Period $6,885,000 $17,085,429
Financing Expenses $1,027,978 $5,234,145
Residual Value at End of Study Period $0 $0
CapEx minus Baseline Avoided Costs $14,406,596
Grants $0 $0
CapEx Minus Avoided Costs & Grants $14,406,596
Annual Costs & Benefits ($ per year)
Alternative (HVAC boiler upgrades and
Category Baseline
RCx)
Annual Maintenance Expenses $0 $0
Annualized Major Maintenance Expenses $0 $0
Incremental Total Maintenance Expenses $0 $0
Annual Utility Savings $67,914
Annual Incentives $0
Annual Benefits minus Costs ($/year) $67,914
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 45
Alternative (HVAC boiler upgrades and
Category Baseline
RCx)
Simple Payback (years) 212.1
Return on Investment 0%
Annual Savings Summary
Description Alternative (HVAC boiler upgrades and RCx)
Water (CCF/year) 0
Electricity (kWh/year) 257,973
Natural Gas (therms/year) 35,897
Diesel/#2 (gallons/year) 0
Fuel Oil/#5, #6 (gallons/year) 0
Gasoline (gallons/year) 0
LPG (gallons/year) 0
District Heat (MMBtu/year) 0
Coal (MMBtu/year) 0
Biomass (MMBtu/year) 0
CO2e Reductions through 2029 (tons/year) 297
CO2e Reductions, 2030 and later (tons/year) 191
Note: Electricity is assumed to be carbon neutral 2030 and later.
Cumulative Cash Flow Report
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 46
$30,000,000
$25,000,000
$20,000,000
$15,000,000
$10,000,000
$5,000,000
$-
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044
Baseline Alternative
Figure 8: Cumulative cash flow report for a high-rise office building (2024-2044) comparing baseline and
alternative scenarios
Annual Cash Flow Report
$4,500,000
$4,000,000
$3,500,000
$3,000,000
$2,500,000
$2,000,000
$1,500,000
$1,000,000
$500,000
$-
2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044
Baseline Alternative
Figure 9: Annual cash flow report for a high-rise office building (2024-2044) comparing baseline and
alternative scenarios
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 47
Indoor Recreation Building - 108
To: Building Owner
From: Clean Buildings Team (SBW, Ecotope, UMC)
Subject: Indoor Recreation Building Summary
Date: July 30, 2024
Site description
This Indoor Recreation building includes bowling, an arcade, and dining. The building’s HVAC design is a
ground coupled heat recovery chiller (HRC). The ground loop has trimming with gas boilers. The internal piping
is a 4 pipe, all waste heat from cooling is used for heating by way of the HRC. There are also three Type 1
hoods in the commercial kitchen as well as several other rooftop exhaust fans running 24/7. The building
appears to be over-ventilating (likely still using COVID-19 protocol), exhaust fans are running full speed, zone
CO2 level control is set very aggressively.
It appears that the ground loop is not operating optimally. The ground loop should be a much lower
temperature for this time of year. Ventilation systems appear to be over-ventilating. The 4 pipe-HVAC is also
not working optimally. The heating and cooling loads may be feeding each other, deadband temps across
zones should be optimized. This building should be in heating during the winter and cooling in the summer if
setup optimally for this climate.
This building needs a thorough retro-commissioning update to get all of the systems operating together as
intended and to turn off systems where possible.
Current stats
• Current EUI: 140 kbtu/sf/yr
• Current EUIt: 78 kbtu/sf/yr
• Heated Floor Area: 58,000 SF
See Figure 10 for billing analysis.
Billing analysis
This project’s energy usage bills for 2022 are shown in the following graph. The baseloads for electricity and
for gas are both quite high for this type of space. The building is heating and cooling year-round.
Indoor Recreation Building
Gas energy use intensity had an inversely proportional relationship with outside air temperature until outside
air temperature reached 55 degrees Fahrenheit at which point its relationship with outside air temperature
became constant. Electric energy use intensity had an inversely proportional relationship with outside air
temperature until outside air temperature reached 50 degrees Fahrenheit at which point its relationship with
outside air temperature became constant.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 48
Indoor Recreation Building Energy Use by Month
900,000
800,000
Estimated Energy Use (kBtu)
700,000
600,000
500,000
400,000
300,000
200,000
100,000
0
1 2 3 4 5 6 7 8 9 10 11 12
Month
Electricity Gas
Figure 10: Annual energy use by fuel type for indoor recreation building.
Energy reduction measures
MEASURE 1: ACTIVITY SENSING CONTROLS INSTALLED ON TYPE 1 HOODS.
Install MeLink or equal, activity sensing (smoke and heat) controls on existing Type 1 hood exhaust fans and
make-up air system. This measure will install a retrofit controller and sensor array to monitor both heat and
smoke presence under the three Type 1 hoods in the cooking space and ramp up and down fan speeds for the
exhaust and make-up air systems. This activity sensing system should be tied into the control system so that
building engineers can monitor the fan speeds and overall system operation. Alarms shall also be tied into the
main BMS controller. This system will need to be coordained with the other exhaust systems and make-up air
systems to optimize the pressure relationships.
MEASURE 2: ELECTRONIC IGNITION STARTERS.
Swap out gas range standing pilots for electronic ignition starters that allows the gas pilots to be turned off
overnight. This measure will allow the Type 1 grease fans to powered off during unoccupied hours. This
measure shall include adding both CO2, CO and natural gas detection measurement sensors and alarms to the
control system dashboard.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 49
MEASURE 3: RETRO COMMISSIONING OF EXISTING SYSTEMS AND EXISTING
CONTROLS.
This measure will aim to understand the current sequence of operations and set a new sequence that is
focused on reducing energy usage and run time of equipment. The retro-commissioning scope would include:
• Exhaust Systems: Current building is exhausting more air than it is making up air back into the space. This
is causing excessive negative pressure inside the building. Rebalance airflows so that most spaces are
neutral to slightly positive pressure while the kitchen area remains slightly negative to keep smells and
smoke flowing out through the grease hoods. Setup fan systems so that they power off during unoccupied
hours.
• Current demand controlled ventilation (DCV) controls are not optimized. Currently, each zone’s CO2 levels
are nearly the same as outside air(~450ppm). This control setpoint could be moved up to 1000 ppm to
reduce outside air to be conditioned. Each zone shall be set up to deliver Ra ventilation component min
ventilation air during occupied hours and off during unoccupied hours. DCV- Once CO2 levels hit 1000ppm,
open the damper to full Ra+Rp position and reduce damper position back to Ra levels. Setup damper
position stops at Ra, Ra+600pppm, Ra+700ppm, Ra+800ppm, Ra+900 ppm, Ra+1000ppm, Ra+Rp,
Economizer.
• Economizer mode should be optimized for the dedicated outdoor air systems (DOAS). When any zone
enters cooling mode, economizer, via the DOAS, should be moved to Stage 1 with temperature band
widened, cool with up to 64°F air. Ventilation zone damper for each room will then revert to DCV sequence
above.
• The commercial kitchen variable speed exhaust rates will need to be integrated with the building exhaust
and supply rates. Set the variable speed exhaust fans operating as the primary exhaust and make-up air
system. The rest of the building air exchange will need to keep pressure in the slightly positive side and
respond to hood fluctuations. The goal is to maintain positive flow of air in the adjacent spaces towards
the kitchen.
• Disable outdoor radiant heating loop.
• Add timer controls to the gas fireplace. Control on a crank timer switch, (2-hour countdown).Even more
efficient would be to replace with an electric fireplace (OptiMyst or other).
• Experiment with disabling indoor radiant heating system. This system could be causing a false cooling
load. Re-program radiant floor operation when the outside temperature is < 45°F. Further, experiment with
turning this off.
• Optimize supply air setback for all AHU’s.
• Scheduling update: All AHU’s should be powered off overnight. Plugs turned off. Process loads turned off,
and fans turned off where possible.
• This building appears to be simultaneously heating and cooling itself based on the observation during our
interview. Cooling and heating hydronic pumps were running 75% full speed and there was very little
activity in the building and the outside temps were 55°F.
• Fan coil 21 needs to be checked, the controller seems a little off.
• Ground coupled heat pump: This building location is a heating climate, heat/cool energy should be 8:1. The
current controls for the loop are reporting a warmer ground loop going into the ground and coming back
cooler, this would mean the building is heating the ground, this should be investigated. The ground loop
should be supplying all of the heat for this building. The gas boiler could be doing most of the building’s
heating, currently installed to trim the ground loop prior to entering the HRC. High performance buildings
connected to ground loops in the Pacific Northwest operate at temperatures in the 30°F-40°F range year-
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 50
round. Investigate HRC and see what the minimum entering water temperature is. Recalibrate the ground
loop controls and sensors; this loop should be running as cold as is possible without freezing it.
Measure savings
Base Measure 1 Measure 2 Measure 3
Electricity 4,466,000 4,407,325 4,289,976 2,230,788
Gas 3,654,000 3,111,132 2,296,829 1,194,351
Total (kbtu) 8,120,000 7,518,457 6,586,805 3,425,139
EUI 140 130 114 59
Measure costs
Measure EEM Low High Notes
includes mark-up, taxes, bonding,
Activity sensing controls
1 $ 72,900.00 $89,100.00 construction management, controls
installed on Type 1 Hoods.
(estimate)
Swap out gas range standing includes mark-up, taxes, bonding,
2 pilots for electronic ignition $36,450.00 $44,550.00 construction management, controls
starters. (estimate)
includes mark-up, taxes, bonding,
RetroCx of existing systems
3 $57,643.49 $70,453.15 construction management, controls
and existing controls.
(estimate)
Form-F Lifecycle Cost Assessment Summary
Project Information
Field Details
Project Building 108 Retrofit
Life Cycle Cost Analysis Results
Metric Baseline Alternative
Net Present Savings $274,971 $274,971
Savings-to-Investment Ratio (SIR) 1.84 -
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 51
Metric Baseline Alternative
Internal Rate of Return 304% -
First Construction Costs (minus Grants) $0 $177,448
Present Value of Capital Costs $0 $272,392
Present Value of Maintenance Costs $0 $0
Present Value of Utility Costs $897,271 $395,980
Total Life Cycle Cost (LCC) $897,271 $668,372
CO2 Emissions Reductions over Building Life by Energy Source
Energy Source Baseline (tons CO2e) Alternative (tons CO2e)
Electricity 2,695 1,346
Natural Gas 1,941 634
Total CO2e Emissions (tons) 4,635 1,980
CO2e Reductions (tons) - 2,655
Percent Reductions - 57%
Cost Summary in 2024 Dollars
Metric Baseline Alternative
Capital Expenditures Over Study Period $0 $314,397
Financing Expenses $0 $79,483
Residual Value at End of Study Period $0 $0
CapEx Minus Baseline Avoided Costs $0 $393,879
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 52
Annual Costs & Benefits
Description Amount
Annual Maintenance Expenses $0
Annualized Major Maintenance Expenses $0
Incremental Total Maintenance Expenses $0
Annual Utility Savings $83,256
Annual Incentives $0
Annual Benefits minus Costs $83,256
Simple Payback (years) 4.7
Return on Investment (%) 21
Annual Savings Summary
Description Alternative
Electricity (kWh/year) 654,911
Natural Gas (therms/year) 24,596
CO2e Reductions through 2029 (tons/year) 400
CO2e Reductions, 2030 and later (tons/year) 131
Note: Electricity is assumed to be carbon neutral 2030 and later.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 53
Cumulative Cash Flow Report
$1,400,000
$1,200,000
$1,000,000
$800,000
$600,000
$400,000
$200,000
$-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Baseline Alternative
Figure 11: Cumulative cash flow report for an indoor recreation building (2024-2044) comparing baseline and
alternative scenarios.
$250,000
$200,000
$150,000
$100,000
$50,000
$-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Baseline Alternative
Annual
Cash Flow Report
Figure 12: Annual cash flow report for an indoor recreation building (2024-2044) comparing baseline and
alternative scenarios
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 54
Community College Science Building - 105
To: Building Owner
From: Clean Buildings Team (SBW, Ecotope, UMC)
Subject: Community College Science Building Summary
Date: July 30, 2024
Site description - pending live graphics
The science building in the Community College Science Building contains classrooms, staff offices and
science labs, including 17 fume hoods. The fume hood system running 12,000 CFM 24/7 is driving a lot of the
gas usage. The fans are also running extensively. The radiant cooling system is not working, which is causing
overheating in the classrooms. The variable frequency drives (VFD’)s are installed on the make-up air system
but not being used.
This building’s gas usage is high and is the primary target for reductions. Implementing systems to allow
demand controlled ventilation (DCV) of the primary fume exhaust and make-up air systems using air sampling
controls is a cost effective measure for this building.
Current stats
• Current EUI: 140 kbtu/sf/yr
• Current EUIt: 107 kbtu/sf/yr
• Heated Floor Area: 51,884 SF
See Figure 13 for billing analysis.
Billing analysis
Community College Science Building
Gas energy use intensity had an inversely proportional relationship with outside air temperature until outside
air temperature reached 62 degrees Fahrenheit at which point its relationship with outside air temperature
became constant. Electric energy use intensity was constant until outside air temperature reached 54 degrees
Fahrenheit at which point its relationship with outside air temperature became proportional. Electric solar
energy use intensity remained constant across all outside air temperatures.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 55
CC Science Building End Use Energy Estimates
1,200,000
1,000,000
Estimated Energy Use (kBtu)
800,000
600,000
400,000
200,000
0
1 2 3 4 5 6 7 8 9 10 11 12
Month
Electricity Gas
Figure 13: Annual energy use by equipment for community college science building
Energy reduction measures
MEASURE 1: RETRO-COMMISSIONING OF EXISTING SYSTEMS AND EXISTING
CONTROLS.
This scope will aim to retro-commission the current building controls and schedules for the lab spaces and
office/education spaces.
• Outside air requirements shall be recalculated and rebalanced.
• Schedules shall be tightened up to current usage. The goal is turning equipment off.
• Radiant cooling system shall be activated and/or diagnosed.
• Fume hood flow alarms setpoints shall be made adjustable to prepare for demand-controlled lab air
exchange.
• Fix hot water loop setpoints, install outdoor reset controls. Turn pumps off when not needed.
• Turn boilers off in the summer months, turn both boilers and pumps off when outside air is above 65°F.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 56
MEASURE 2: INSTALL VFD’S ON LAB FUME HOOD EXHAUST FANS.
Install VFD’s on lab fume hood exhaust fans.
• Install VFD on current exhaust hoods, 6000 CFM per fan. Assume 10 HP motors.
• Make changes to BMS controls to add this monitoring to the primary controls interface.
MEASURE 3: IMPLEMENT DEMAND-BASED FRESH AIR EXCHANGE SYSTEM.
Install Aircuity sensing and control system to enable variable speed fume hood exhaust flow rates.
• The lab is currently exchanging 12,000 CFM of fresh air exchange, (10 ACH, 104 CFM/Hood). The goal is to
reduce the reheating costs and fan energy of this system.
• Implement supply air temperature and pressure reset controls on make-up air unit, AHU-301.
• Implement demand-based zone air sampling system (Aircuity) and take control of both the exhaust and
make-up air flows.
• Added BMS programming to install the Aircuity BACnet control interface.
Measure savings
Base Measure 1 Measure 2 Measure 3
Electricity 4,844,824 4,300,876 4,300,876 3,811,324
Gas 2,818,545 2,474,301 2,034,084 1,753,770
Total (kbtu) 7,663,369 6,775,177 6,334,961 5,565,093
EUI 148 131 122 107
Base Measure 1 Measure 2 Measure 3
Gas (therms) - 5,439 - 4,896
Electricity (kwh) - 100,863 128,982 82,131
Measure costs
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 57
Measure EEM Low High Notes
includes mark-up, taxes, bonding,
Retro-Cx of existing systems
1 $25,090.37 $30,666.01 construction management, controls
and existing controls.
(estimate)
includes mark-up, taxes, bonding,
Install VFD’s on lab fume hood
2 $74,902.67 $91,547.71 construction management, controls
exhaust fans.
(estimate)
includes mark-up, taxes, bonding,
Implement demand based fresh
3 $243,486.00 $297,594.00 construction management, controls
air exchange system.
(estimate)
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 58
Form-F Lifecycle Cost Assessment Summary
Project Information
Field Details
Project Building 105 Retrofit
Life Cycle Cost Analysis Results
Alternative (HVAC boiler upgrades and
Description Baseline
RCx)
Net Present Savings $0 $250,263
Savings-to-Investment Ratio (SIR) 0 2.11
Internal Rate of Return 0 195%
First Construction Costs (minus Grants) $0 $111,103
Present Value of Capital Costs $0 $202,199
Present Value of Maintenance Costs $0 $0
Present Value of Utility Costs $1,461,423 $1,034,926
Total Life Cycle Cost (LCC) $1,461,423 $1,237,124
CO2 Emissions Reductions
Energy Source Baseline CO2e (tons) Alternative CO2e (tons)
Electricity 1,701 1,058
Natural Gas 3,860 3,037
Diesel/#2 0 0
Fuel Oil/#5, #6 0 0
Gasoline 0 0
LPG 0 0
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 59
Energy Source Baseline CO2e (tons) Alternative CO2e (tons)
District Heat 0 0
Coal 0 0
Biomass 0 0
Total CO2e Emissions 5,561 4,095
Percent Reductions 26%
Cost Summary in 2024 Dollars
Capital Expenditures
Alternative (HVAC boiler upgrades and
Description Baseline
RCx)
Capital Expenditures Over Study Period $0 $166,859
Financing Expenses $0 $49,765
Residual Value at End of Study Period $0 $0
Grants $0 $0
CapEx Minus Baseline Avoided Costs & Grants $0 $216,624
Annual Costs & Benefits
Alternative (HVAC boiler upgrades and
Description Baseline
RCx)
Annual Maintenance Expenses $0 $0
Annualized Major Maintenance Expenses $0 $0
Incremental Total Maintenance Expenses $0 $0
Annual Utility Savings $0 $37,809
Annual Incentives $0 $0
Annual Benefits minus Costs ($/year) $0 $37,809
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 60
Alternative (HVAC boiler upgrades and
Description Baseline
RCx)
Simple Payback (years) - 5.7
Return on Investment - 17%
Annual Savings Summary
Description Alternative HVAC boiler upgrades and RCx
Water (CCF/year) 0
Electricity (kWh/year) 311,976
Natural Gas (therms/year) 10,335
Diesel/#2 (gallons/year) 0
Fuel Oil/#5, #6 (gallons/year) 0
Gasoline (gallons/year) 0
LPG (gallons/year) 0
District Heat (MMBtu/year) 0
Coal (MMBtu/year) 0
Biomass (MMBtu/year) 0
CO2e Reductions through 2029 (tons/year) 183
CO2e Reductions, 2030 and later (tons/year) 55
Note: Electricity is assumed to be carbon neutral by 2030 and later.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 61
Cumulative Cash Flow Report
$1,800,000
$1,600,000
$1,400,000
$1,200,000
$1,000,000
$800,000
$600,000
$400,000
$200,000
$-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Baseline Alternative
Figure 14: Cumulative cash flow report for an indoor recreation building (2024-2044) comparing baseline and
alternative scenarios.
$120,000
$100,000
$80,000
$60,000
$40,000
$20,000
$-
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
Baseline Alternative
Annual Cash Flow Report
Figure 15: Annual cash flow report for an indoor recreation building (2024-2044) comparing baseline and
alternative scenarios.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 62
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 63
BOMA study comparison
The Building Owners and Managers Association (BOMA) conducted a study of 16 buildings to assess the
costs of complying with Building Performance Standards policies in Washington state and Seattle. BOMA
provided the study report to the SBW team so the results could be compared with results from our studies. The
figures below present the results of the financial analysis conducted for Commerce ("Commerce Case Studies"
and "Supply Curve Study") along with the BOMA case studies. Figure 16 shows the full context of all three sets
of analyses. Each point represents a building, the vertical axis is the measure cost per square foot 15 and the
horizontal axis is the measure savings per square foot. The supply curve data aggregates the energy savings
and costs for all energy efficiency measures in the portfolio across building types for all buildings in WA. This
is regardless of whether their EUI being greater than EUIt since it represents the potential for all buildings.
When measures are examined individually, they tend to cluster around the chart axis since their potential is
divided by statewide floor areas. Commerce and BOMA case studies likely contain higher costs per measure
than the supply curve buildings because these cost studies analyze costs closer to full costs rather than the
incremental nature built into the supply curve. The supply curve analysis assumes that any equipment past its
full typical life would be replaced as part of its normal lifecycle.
Figure 17 shows average cost per unit of energy saved for each study. Buildings with higher than average cost
per unit of energy must implement more expensive measures to meet their EUI goals. Figure 18 shows average
cost per square foot of building. Buildings with higher than average costs per square foot likely have more
fixed costs needed to implement a package of energy efficiency measures. A key takeaway from these
comparisons is that there is a broad range of results within each set of analyses and across all three analyses,
i.e., it is difficult and unadvisable to pin down a single average measure cost to extrapolate for estimating total
cost of retrofitting all Tier 1 buildings.
15 As noted above, the measure costs and savings from the supply curve are based on averages of across all buildings in Washington
state, regardless of their starting level of energy efficiency, and only include retrofit measures thus incremental cost and savings above
standard equipment replacement.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 64
Capital costs and Savings (normalized by sqft)
50
45
40
35
Retrofit Costs ($/SF)
30
25
20
15
10
5
0
0 10 20 30 40 50 60 70 80 90
Retrofit savings (kBtu/sqft)
BOMA WDOC Supply Curve
Figure 16: First year measure costs and savings normalized by floor area
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 65
Average Retrofit Costs by Study
$2.50
$2.00
Average cost of savings $/kBtu
$1.50
BOMA
Commerce
Supply Curve
$1.00
$0.50
$-
Study
Figure 17: Average first year measure cost per unit energy saved
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 66
Operations Costs Survey & Case Study Retrofit Costs
30
25
Normalized Costs ($/SF)
20
BOMA Case Studies
15 Commerce Case Studies
Cost Survey Retrofit
10
Costs
5
0
Study
Figure 18: Average first year measure cost per sf of building
Tabulated Results
Table of standardized results from supply curve analysis, case studies including from BOMA's report, and cost
survey
EUI Reduction
Source Building ID Building Type Cost ($/kBtu) Cost ($/SF)
(kBtu/SF)
Commerce 102 Healthcare 37.5 $ 1.34 $ 50.39
Commerce 104 Office 16.6 $ 2.61 $ 43.44
Commerce 105 University/College 40.4 $ 0.18 $ 7.36
Commerce 107 Healthcare 68.7 $ 0.13 $ 8.60
Commerce 108 Entertainment 80.9 $ 0.04 $ 3.06
Commerce 109 School 13.7 $ 0.68 $ 9.26
BOMA Bldg 1 Office 33.5 $ 0.65 $ 21.78
BOMA Bldg 2 Office 6.1 $ 0.73 $ 4.45
BOMA Bldg 3 Office 32.7 $ 0.51 $ 16.68
BOMA Bldg 4 Office 55.2 $ 0.52 $ 28.70
BOMA Bldg 5 Office 18.2 $ 0.69 $ 12.56
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 67
EUI Reduction
Source Building ID Building Type Cost ($/kBtu) Cost ($/SF)
(kBtu/SF)
BOMA Bldg 6 Office 18.9 $ 0.94 $ 17.77
BOMA Bldg 7 Office 18.0 $ 0.88 $ 15.84
BOMA Bldg 8 Hotel 29.9 $ 0.53 $ 15.85
BOMA Bldg 9 Health Club 33.3 $ 0.41 $ 13.65
BOMA Bldg 10 Hotel 31.8 $ 0.58 $ 18.44
BOMA Bldg 11 Hotel 32.6 $ 0.48 $ 15.65
BOMA Bldg 12 Convention Center 39.2 $ 3.98 $ 156.02
BOMA Bldg 13 Industrial Office 29.1 $ 3.01 $ 87.59
BOMA Bldg 14 Industrial Office 2.6 $ 1.43 $ 3.72
BOMA Bldg 15 Industrial Office 25.6 $ 0.65 $ 16.64
BOMA Bldg 16 Industrial Office 6.9 $ 1.01 $ 6.97
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 68
Total Savings Potential
Segment Cost ($/KBTU) Total First Cost ($/SF)
(kBTU/SF)
Other 7.14 9.77 0.73
Large Off 8.43 1.85 4.56
All 1.74 2.55 0.68
Residential Care 2.12 3.90 0.54
University 21.86 5.78 3.78
Small Ret 2.87 2.46 1.17
School K-12 5.88 6.45 0.91
Small Off 3.95 2.98 1.33
Medium Ret 4.03 5.23 0.77
Lodging 2.46 2.77 0.89
Large Ret 0.59 7.41 0.08
Warehouse 0.49 3.66 0.13
Hospital 8.38 13.46 0.62
MiniMart 7.63 5.35 1.43
Medium Off 20.88 1.00 20.90
Assembly 1.03 6.09 0.17
Restaurant 53.25 15.30 3.48
XLarge Ret 0.82 6.07 0.14
Supermarket 70.42 4.60 15.32
WA Total 223.95 3.89 57.63
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 69
Square
EMP O&M
Building Footage Benchmarking Audit Other Total
Building Development Development Total Cost
Count (million $/SF $/SF $/SF Cost $/SF
$/SF $/SF
sqft)
Healthcare_1 20 10.98 0.01 0.01 0.01 0.00 0.92 0.96 $524,442
ComCol_1 1 0.23 0.35 0.03 0.03 0.21 0.63 $343,431
ComCol_2 7 0.46 0.77 0.77 1.53 $840,117
School_1 16 1.45 0.02 0.01 0.01 0.01 0.28 0.34 $187,791
ComCol_3 18 1.39 0.52 0.01 0.02 0.51 10.00 11.06 $6,073,003
ComCol_4 1 0.83 0.05 0.05 0.25 0.17 6.50 7.02 $3,854,655
ComCol_5 8 0.65 1.00 0.25 0.25 0.25 7.00 8.75 $4,804,591
University_1 74 9.80 2.00 0.50 0.50 0.50 3.50 $1,921,836
ComCol_6 5 0.50 0.84 0.20 0.20 0.05 0.20 1.49 $818,153
ComCol_7 5 0.73 0.11 0.02 0.02 0.01 0.16 $87,855
ComCol_8 6 0.67 0.38 0.20 0.20 0.22 1.00 $549,096
ComCol_9 3 0.21 1.00 0.02 0.02 0.24 1.28 $702,843
Assembly_1 1 0.08 1.20 1.20 $658,915
ComCol_10 5 0.32 0.20 0.02 0.02 1.00 1.23 $675,388
Warehouse_1 1 0.14 1.00 1.00 $549,096
Warehouse_2 1 0.19 1.30 0.10 0.05 0.03 1.48 2.96 $1,625,324
School_2 15 1.61 0.02 0.02 0.03 0.25 0.32 $175,711
Assembly_2 2 0.14 0.04 0.04 0.07 0.55 0.14 0.83 $455,750
Assembly_3 1 0.06 0.07 0.02 0.02 0.02 0.12 $65,892
School_3 54 5.05 10.90 2.30 2.30 2.30 2.00 19.80 $10,872,103
Office_1 56 7.62 0.03 0.04 0.11 1.50 0.37 2.05 $1,128,322
Office_2 1 0.10 0.02 0.11 0.04 0.32 0.49 $268,179
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 70
Square
EMP O&M
Building Footage Benchmarking Audit Other Total
Building Development Development Total Cost
Count (million $/SF $/SF $/SF Cost $/SF
$/SF $/SF
sqft)
Total
Average O&M Average
Square Average Average EMP Average Average Average
Total Program Total
Footage Benchmarking Development Audit Other Total Cost
Buildings Development Cost
(million $/SF $/SF $/SF $/SF per Building
$/SF $/SF
sqft)
301 43.22 1.83 0.42 0.43 0.74 1.56 4.45 $123,530
Cost Survey Protocol
The table below presents the questions in the cost survey.
Question Survey question
1
Enter name of person completing this questionnaire.
2
Enter employer of the person completing this questionnaire.
3
Enter the name of the organization that owns the Tier 1 properties represented in this response.
4
Select this organization's property ownership type.
5
Select the top 3 most common nonresidential property types of this organization.
6
Enter the count of Tier 1 properties in this organization.
7
Enter total estimated floor area of the organization's Tier 1 properties.
8
Enter the total estimated annual energy use in kBtu of the organization's Tier 1 properties.
9 Enter your estimate of total cost per square foot ($/sq ft) to benchmark the organization's Tier 1 properties,
including costs for submetering, hiring, and training staff or outsourcing to third parties.
10 Enter your estimate of total cost per square foot ($/sq ft) to develop the Energy Management plan for the
organization's Tier 1 properties, including costs for hiring and training staff or outsourcing.
11 Enter your estimate of total cost per square foot ($/sq ft) to develop the O&M program for the
organization's Tier 1 properties, including costs for hiring and training staff or outsourcing to third parties.
12 Enter your estimate of total cost per square foot ($/sq ft) to conduct audits on the organization's
properties to determine which measures must be implemented to comply with CBPS.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 71
Question Survey question
13 Enter your estimate of total cost per square foot ($/sq ft) to retrofit the organization's properties to bring
them into compliance with CBPS regardless of path (Meet EUIt or Investment criteria).
14
Describe other costs the organization faces to comply with CBPS that are not captured above.
15 Enter your estimate of total cost per square foot ($/sq ft) of other costs associated with achieving CPBS
compliance for the organization's properties.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 72
Appendix B: Detailed Workgroup input
The Workgroup was asked to rate each recommendation and strategy on a scale of 1 through 5. The overall
scores from members in the public sector are presented in the second column. Overall scores from the private
sector, utility, and non-profit sector representatives are presented in the third column. Some strategies were
added after the ranking survey was complete, and so have a score of NA. Note that the strategies are designed
for implementation by the Legislature unless otherwise specified.
Private Sector,
Public Sector
Strategy Utility, Non-profit
Score / 5.00
Score / 5.00
Explore creative ways to unlock financing for all sectors.
The Office of Financial Management (OFM) should clarify that green revolving funds are
4.11 4.00
permitted in public institutions, and how they can be structured.
The OFM should clarify payback mechanisms for rebates/grants, and tax incentives such as
the 179-D tax deduction, so public institutions know how exactly a grant will impact their 4.22 3.67
budget and know whether funds go to the institution or the state.
Share successful models of C-PACER to demonstrate the value of this kind of financing for
3.86 4.00
CBPS compliance.
Educational materials should be developed by the Washington Green Bank and promoted by
3.70 3.71
Commerce to educate building owners about green revolving funds.
Investigate the potential benefits and barriers of energy as a service for privately owned
buildings and recommend pathways to develop the market for energy service agreements to 3.00 4.00
support CBPS compliance.
Allow non-profits to access the same state-led CBPS funding opportunities as the public
3.22 4.14
sector.
Lower the bond approval for schools to 50%. 3.60 4.00
Accelerate the C-PACER market by promoting market awareness, consistency, economies of
scale and interconnectivity with policies and programs such as the energy code, utility 3.43 4.00
programs, and market transformation programs.
Increase the funds in programs that support CBPS compliance and reduce the barriers to accessing public funding opportunities.
Direct the Office of Financial Management to approve funding requests from public agencies
which couple additional upgrades with compliance work in public institutions (ex.
4.44 4.67
simultaneously address deferred maintenance and/or whole building upgrades along with
CBPS compliance).
Guarantee that public institutions will receive the funding they need to implement upgrades
4.44 3.67
which are required through the investment criteria pathway.
Public funding should be appropriated directly to agencies rather than being awarded as
grants by Commerce. Grants for privately-owned buildings should be administered by 4.40 3.71
Commerce.
Should the public vote to maintain the Climate Commitment Act, revenues should be allocated
4.00 4.29
to support CBPS compliance for both public and private buildings.
Increase the funding in all Commerce programs which support compliance, especially the
'Energy Efficiency Retrofits for Public Buildings" program and the "Energy Audit for Publicly- 4.30 3.67
Owned Buildings" program.
Adjust the EUI requirement for the early adopter incentive to encourage applications and
3.90 3.71
increase equity across different building types.
Increase the amount of funding in OSPI Small District Energy Assessment Grant program. 3.67 4.00
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 73
Private Sector,
Public Sector
Strategy Utility, Non-profit
Score / 5.00
Score / 5.00
Assist utilities to support building owners with CBPS while following the conservation rules and standard practices set by the State
Energy Independence Act.
Engage with qualifying utilities which are required to provide building owners utility data via
ESPM to identify barriers, case studies of successful approaches to providing ESPM data, and 4.20 4.67
to explore methods to provide support to assist utilities in converting their systems.
RCW 19.27A.170 - In section (8) change “For any covered commercial building with three or
more tenants” to include “or for any covered buildings required to comply with state or local 3.67 4.83
laws or mandates”.
Collaborate with Bonneville Power Administration to help public utilities develop and
implement compliance support programs, leveraging economies of scale for greater 4.10 3.71
efficiency and cost-effectiveness.
Study the resources required for utilities to provide ESPM automated upload and the
resources available to non-qualifying utilities under RCW 19.27A.170 – Sections (2) and (7), to
3.78 4.17
determine if and how this requirement should be modified. The state should then implement
the findings of this study.
Explore methods to reduce the technical and cost barriers of entry to these programs by
enabling data sharing between utilities and between utilities and state; encourage regional
organizations like BPA and NEEA to provide services to a wide range of utilities thus reducing 3.80 3.86
cost and risk; and explore a state-level contract whereby utilities can opt into programs like
accelerators thus reducing cost and risk.
Provide funding to utilities to provide CBPS support, such as accelerator programs and
3.80 3.71
rebates.
Establish a utility grant to establish revolving door loan/financing options. 3.67 3.67
Enable funding mechanisms to make energy audits more cost-effective.
Fund audits for non-profits. 3.63 4.00
Make the cost of energy audits tax deductible. 3.33 4.00
Ensure public institutions have the human resources necessary for ongoing compliance.
Increase pay scales in public institutions to be competitive with private sector compensation,
4.89 4.33
including pay rates for contractors.
Require public institutions to have an energy manager or resource conservation manager and
4.33 4.00
provide ongoing state funding for the position.
Provide guidance to public institutions how to budget for CBPS: O&M vs capital budgets,
accounting for savings, prioritizing energy efficiency in budgets, grant payback mechanisms, 4.00 4.00
etc.
Create dedicated energy teams within each state department to support energy efficiency
4.00 4.00
work generally and CBPS compliance.
Review RCW 28A.150.260 to determine if minimum staffing allocations need to be adjusted
N/A N/A
due to increased staffing needs from CBPS.
Develop a comprehensive CBPS program to holistically support all aspects of compliance.
Increase funding available to support building owners and managers with metering, including
utility meters to measure energy use at the individual building level and submeters to measure 4.30 3.86
separate end uses within buildings.
If support for sub-metering is provided to public institutions, it should be coupled with longer-
4.78 4.25
term funding to maintain the meters and ensure data collection is continuous and accurate.
Create a more robust and comprehensively staffed Help Desk. 3.80 4.29
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 74
Private Sector,
Public Sector
Strategy Utility, Non-profit
Score / 5.00
Score / 5.00
Create a dedicated online tool to help decision-makers navigate CBPS requirements. The tool
should cover: specific regional needs, comparison with other requirements such as Seattle's
BEPS, and should match the user with any available resources that apply to their building. The 3.90 4.00
tool should also present how resources can be combined, such as with conservation
programs, renewable programs or EV supports.
Target outreach and training about CBPS not just to operation and facilities, but also to the
3.90 4.14
key financial and leadership decision-makers, and tenants.
Provide leadership and coordination at all levels to align everyone around CBPS: equipment
3.80 4.00
manufacturers, colleges and apprenticeships, utilities, OFM, etc.
Fund large-scale market transformation and cost compression efforts to remove barriers and
accelerate adoption of the highest impact commercial retrofit solutions, such as rooftop unit
3.44 3.83
heat pumps, dedicated outside air systems, ERVs, retrocommissioning, onsite solar, strategic
sequencing, etc. Implement to ensure access across WA.
Develop a cost sharing model for third party benchmarking service. 3.40 3.83
Expand physical presence for outreach about CBPS. 3.30 3.67
Offer grant funding for cities to hire dedicated staff to promote and educate on CBPS. 3.00 3.57
Develop the workforce capacity needed to deliver an energy efficient commercial building stock.
Explore creative strategies to increase the number of BOC 2 certified individuals, such as a
3.60 4.57
scholarship program.
Fund energy fellows across Washington. 3.50 3.83
Adjust CBPS to better match the needs of building owners and managers.
Establish future EUIts to provide a clear investment pathway, allow buildings owners and
4.30 4.71
managers to undertake long term planning, and to help drive market innovation.
Allow a building owners to request an extension if they are waiting for equipment with long
4.60 4.14
lead times.
Allow building owners to request an extension if they have begun but have not completed their
4.40 4.14
upgrade work or their measurement and verification.
Streamline and add flexibility to the conditional compliance pathway. 4.20 4.33
Create specific long-term energy efficiency, GHG reduction, and other performance related
goals for CBPS and establish flexible compliance paths that allow buildings to integrate
4.10 4.29
multiple behind-the-meter strategies, not just energy efficiency, to demonstrate CBPS
compliance.
Allow building owners to set an EUIt based on a percentage reduction in their current EUI as
4.20 3.86
an alternative to prescribed EUI targets.
Accept compliance with equivalent legislation. 3.80 3.83
Allow building owners to request an extension if they can implement the EMP and O&M but
3.90 3.43
need additional time to meet the performance metric.
Study the investment criteria pathway to determine how the pathway can be streamlined or
N/A N/A
improved.
Ensure alignment between various pieces of existing legislation and CBPS.
The Department of Ecology should study refrigerant phase-outs to determine whether the
4.00 3.67
pace of phase-outs is impacting CBPS compliance.
Get rid of LEED standard requirement for state buildings (RCW 35.39D). 3.78 4.00
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 75
Private Sector,
Public Sector
Strategy Utility, Non-profit
Score / 5.00
Score / 5.00
Fund the Department of Commerce to increase their participation in the energy code
development process in order to identify and encourage alignment across the state energy 4.00 3.29
code, CBPS, and utility programs.
Incentivize building owners to transition their buildings and campuses into grid interactive assets.
Use the newly developing green bank to offer loans for large-scale projects which support
3.67 4.29
buildings as grid assets (local power generation, energy storage and load flexibility).
Recognize and reward building owners who engage in grid-interactive energy planning (local
3.50 4.17
power generation, energy storage and load flexibility) in CBPS compliance process.
Launch a workgroup between the Department of Commerce, the Utilities and Transportation
Commission, and other key stakeholders to develop a strategy for grid resilience through
3.60 3.86
interactive and inter-building energy planning (through local power generation, energy storage
and load flexibility).
Work with utilities to undertake demonstration projects to show how buildings can act as grid
assets at scale (local power generation, energy storage and load flexibility), to better
3.80 3.57
understand the potential benefits to both building owners and utilities, especially within the
context of CBPS compliance.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 76
Appendix C: Eliminated strategies
Throughout the process, the Workgroup considered several strategies that were not included in the final report.
They are included below along with the reason for removal.
Strategy Reason for Removal
Allow buildings that came into compliance after 2019 but before the EAI program began to Low scoring strategy with Workgroup
apply for EAI funds, only if the money will be used for additional EE upgrades. objections
Allow for a longer window for building use planning, so that buildings which will be very Buildings scheduled for demolition
difficult to bring into compliance can instead be scheduled to be decommissioned. have an exemption pathway
Low scoring strategy with Workgroup
Allow identical buildings to submit once for all buildings.
objections
Not specific enough about how this
Allow more flexibility in determining which buildings comply first.
would work in practice
Cap measure life at 10 years for cost-effectiveness calculations for investment criteria Low score in survey and vetoed by
pathway. Workgroup members
Commerce should provide free models and templates for O&M and energy management, and
Already underway
create case studies of good examples of compliance paperwork.
Develop an energy manager training program. Already underway
Develop models and clarify whether Energy as a Service is permitted for public institutions. Already underway
Extension would extend the
Extend the application period for the Early Adopter Incentive. application period beyond the first
compliance cycle
Fund market development in the finance and real estate sectors to standardize and integrate Low score in survey and vetoed by
performance reporting into real estate valuations, transactions, and leasing agreement. Workgroup members
Increase the one-time base incentive payment in the Early Adopter Incentive Program. Already underway
Invest in apprenticeships for energy efficiency professionals. Already underway
Offer pre-performance incentives as loans, which are converted to grants once work is
Would create too much risk for state
complete.
Offer a yearly workshop to update all stakeholders on any changes to CBPS in the previous
Already underway
year.
Promote the 50001 ready program as a free tool for developing leadership alignment around
Already underway
energy efficiency.
EUIts will be updated in 2029 as new
Recalibrate EUIts that building owners flag as inaccurate as new data comes in.
building data becomes available
Remove the O&M and EMP requirement for buildings pursuing the investment criteria pathway Low score in survey and vetoed by
or buildings that have met their EUI. Workgroup members
Share examples of RFPs which ensure companies who are doing energy audits are not also Low score in survey and vetoed by
able to bid on the required EEMs (avoiding a false incentive to require additional work). Workgroup members
Subsidize paid internships for students in the energy efficiency sector, especially linked to
Already underway
CBPS work.
Train the consultant community to be champions for energy efficiency. Already underway
Utilities should increase grid capacity and resilience to support
Already underway
electrification.
REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP 77
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