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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.

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“Clean Buildings Workgroup Report to the Legislature (Energy Division, November 12, 2024).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2024-commercereports-2024-energy-clean-buildings-workgroup-final-3ae60-2145cfc8db/, SHA-256 141cb77970f3e2fa8ae0f10178b1c1a8d2da4ee8883eed4486e6d561ddc7d267.

Full text

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.



REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP                                                   5
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




REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP                                                      8
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.




REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP                                                                 10
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/


REPORT TO THE LEGISLATURE FROM THE CLEAN BUILDINGS WORKGROUP                                                                       11
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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