Oregon BPS for Office Buildings: Complete 2028 Guide

Office buildings represent the largest share of commercial buildings subject to Oregon’s Building Performance Standard. Whether you manage a 35,000-square-foot suburban office park, a mid-rise downtown tower, or a regional headquarters, understanding your BPS compliance obligations—and the practical cost to achieve them—is critical. The 2028 deadline for Tier 1 office buildings is now less than two years away, and building owners who haven’t yet taken action will face escalating compliance pressure.

This guide walks through what Oregon office building BPS compliance actually means, what your building’s energy performance target will be, how much an ASHRAE Level 2 energy audit costs, and what realistic compliance strategies look like for office buildings of different sizes and ages.

What Is Oregon’s Building Performance Standard?

Oregon’s Building Performance Standard (BPS), codified under OAR 330-300 and administered by the Oregon Department of Energy (ODOE), requires commercial buildings 35,000 gross square feet or larger to achieve annual energy benchmarking targets. The standard measures building performance using Energy Use Intensity (EUI)—total annual energy consumption divided by building square footage, expressed in energy units per square foot per year (kBtu/sf/year).

Tier assignment is based on building size and property type, not energy ranking. Office buildings of 35,000 square feet or more are Tier 1, with deadlines staggered by size: June 1, 2028 (200,000+ sq ft), June 1, 2029 (90,000–200,000 sq ft), and June 1, 2030 (35,000–90,000 sq ft). Office buildings of 20,000–35,000 square feet are Tier 2 and must report benchmarking data by July 1, 2028. Non-compliant Tier 1 buildings face civil penalties capped at $5,000 plus $1 per square foot of gross floor area per year until compliance is demonstrated to ODOE.

In my experience advising office building owners in Portland, Eugene, Salem, and Medford, most building owners underestimate both the timeline required to gather data and the actual cost to achieve compliance. Understanding your building’s baseline performance, your compliance target, and your improvement options now allows you to plan efficiently rather than scrambling near the deadline.

Office Building EUI Benchmarks and Tier Assignment

Your office building’s tier and deadline depend on gross floor area (excluding parking garage area). Whether your building must go beyond benchmarking depends on how its weather-normalized EUI compares to the Energy Use Intensity Target (EUIt) ODOE assigns for its activity type, derived using the OR BPS EUI Target Tool:

Building size (office / nonresidential)	Tier	Compliance date
200,000 sq ft and greater	Tier 1	June 1, 2028
90,000–200,000 sq ft	Tier 1	June 1, 2029
35,000–90,000 sq ft	Tier 1	June 1, 2030
20,000–35,000 sq ft	Tier 2	July 1, 2028

A Tier 1 office building whose weather-normalized EUI exceeds its EUI target must notify ODOE at least 180 days before its compliance date, complete an ASHRAE Level 2 energy audit by a Qualified Energy Auditor (QEA) before the deadline, and lay out a plan to implement cost-effective efficiency measures. Tier 1 buildings that meet their target still must benchmark and document their O&M program and Energy Management Plan.

Your building’s exact position against its EUI target is calculated from 12 consecutive months of actual utility data (within the prior 24 months) in ENERGY STAR Portfolio Manager. This is why the first critical step in BPS compliance is accurate utility data collection and benchmarking. Buildings often surprise owners—a newer office tower in Portland may perform better than expected, while an older suburban office park may rank lower than the owner assumed.

Determining Your Office Building’s Baseline EUI

The process of determining your baseline EUI requires:

1. Utility Bill Analysis: Collecting 24 months of electric, gas, and water bills for your office building. For buildings with separate metering for different tenants or systems, you’ll need to consolidate bills for the entire building footprint.

2. Gross Square Footage Verification: Confirming your building’s total gross square footage (including walls, mechanical spaces, and common areas). Many office buildings have conflicting square footage numbers—architectural plans may differ from county assessor records. ODOE requires documented, verified square footage, often from a certified architect or engineer.

3. Utility Benchmarking Software: Using EPA ENERGY STAR Portfolio Manager or a comparable tool to calculate baseline EUI. This free EPA tool is the standard used by ODOE for official benchmarking.

4. Tier Assignment: Submitting your baseline EUI to ODOE (typically through a preliminary BPS compliance reporting) to receive official tier assignment and compliance deadline.

Once you have your baseline EUI and tier assignment, you know exactly what your target EUI must be by your deadline. If you’re Tier 1, your target EUI typically ranges from 11.5 to 14.8 kBtu/sf/year depending on your specific building subtype and regional factors.

Quantifying Your Energy Improvement Gap

Most Tier 1 office buildings in Oregon will need to reduce baseline energy consumption by 15–30% to achieve compliance, depending on current performance. This reduction translates into real dollar savings—and real cost to achieve those savings.

If your 50,000-square-foot General Office building currently operates at 18.2 kBtu/sf/year (Tier 2 performance), your compliance target as a Tier 1 building would be approximately 13.5 kBtu/sf/year. That’s a required 26% energy reduction, or about 235,000 kBtu of annual savings. At typical Oregon commercial electricity rates of $0.12–$0.15 per kWh and $1.00–$1.20 per therm for natural gas, this represents $22,000–$28,000 in annual utility cost savings once improvements are complete.

However, achieving that 26% savings requires identifying and implementing specific energy measures. This is where the ASHRAE Level 2 energy audit becomes essential—it quantifies the specific improvements, their costs, and their payback periods.

ASHRAE Level 2 Energy Audit: Cost and Process

An ASHRAE Level 2 energy audit is the industry standard assessment for identifying cost-effective energy improvements and verifying compliance pathways. For office buildings in Oregon, Level 2 audit costs depend primarily on building size, complexity, and age:

Building Size	Typical Audit Cost	On-Site Days	Timeline
35,000–50,000 sf	$8,500–$12,000	2–3 days	4–6 weeks
50,000–100,000 sf	$12,000–$16,000	3–4 days	5–7 weeks
100,000–250,000 sf	$16,000–$22,000	4–6 days	6–8 weeks
250,000+ sf	$22,000–$35,000	6–10 days	8–12 weeks

A qualified ASHRAE Level 2 auditor will examine all major building systems—HVAC, lighting, controls, insulation, and operational practices—and deliver a detailed report recommending specific energy efficiency measures ranked by return on investment. For a typical mid-size office building, 15–25 specific improvement recommendations will be identified.

The audit is essential not only for compliance planning but also for accessing rebates and incentives. Energy Trust of Oregon, the statewide energy efficiency program, offers rebates for many office building improvements and often requires a Level 2 audit as the prerequisite for incentive eligibility. For qualified office buildings, Energy Trust offers cash incentives for improvements to HVAC, lighting, controls, and envelope upgrades.

In my experience, office buildings that get audited early and prioritize high-ROI measures are more likely to meet compliance deadlines without financial distress. Waiting until 2027 to commission an audit and begin improvements creates scheduling bottlenecks and eliminates opportunities to sequence improvements strategically.

Common Energy Improvements for Office Buildings

Most office buildings achieve BPS compliance through a combination of these measures:

HVAC System Upgrades and Optimization (15–25% typical savings) Older rooftop units (pre-2010) are often prime candidates for replacement with high-efficiency units. Recommissioning existing systems—recalibrating thermostat setpoints, repairing dampers, fixing ductwork leaks—often delivers 10–15% savings at minimal cost. Energy Trust rebates can cover 30–40% of rooftop unit replacement costs.

Lighting and Controls Conversion (20–30% typical savings) Converting remaining fluorescent or older LED fixtures to high-efficiency LED with occupancy sensors and daylight harvesting can reduce lighting energy by 60–75%. For a typical office building where lighting represents 18–22% of total energy consumption, this alone can deliver 12–15% overall building savings. Incentives can offset a meaningful share of conversion costs.

Building Automation and Control Recalibration (8–15% typical savings) Many office buildings have BMS systems that are poorly programmed or tuned. Implementing demand-controlled ventilation (varying outdoor air based on actual occupancy), optimizing equipment scheduling, and adding smart thermostats can deliver significant savings at relatively low cost. Auditors often identify $3,000–$8,000 in optimization opportunities that can be implemented immediately at minimal cost.

Envelope and Insulation Improvements (5–12% typical savings) Sealing air leaks, upgrading insulation in attic spaces, and replacing single-pane windows with insulated units improve both energy performance and occupant comfort. These improvements have longer payback periods (7–12 years) but are often cost-effective in combination with other measures.

Water Heating and Hot Water System Upgrades (3–8% typical savings) For office buildings with significant restroom facilities or kitchens, upgrading to efficient water heating systems and installing low-flow fixtures reduces water heating energy costs.

Compliance Pathways and Timelines

Most office buildings achieve BPS compliance through a phased improvement approach:

Phase 1: Low-Cost Operational Improvements (Months 1–3) Implement operational changes and quick wins identified in the audit: thermostat recalibration, HVAC maintenance, control optimization, lighting scheduling. Cost: $0–$15,000. Typical energy savings: 5–10%.

Phase 2: Capital Improvements (Months 4–18) Implement the highest-ROI capital improvements: lighting retrofit, HVAC upgrades, controls installation. Cost: $75,000–$200,000 depending on building size. Typical energy savings: 15–25%. Secure Energy Trust rebates during this phase.

Phase 3: Final Verification and Documentation (Month 18–24) Commission post-retrofit energy modeling to verify compliance target achievement. Submit BPS compliance reporting to ODOE documenting compliance status and completion date. This phase ensures you meet your 2028 deadline (for Tier 1) with documentation in hand.

For Tier 1 office buildings, completing Phase 1 by mid-2027 and Phase 2 by early 2028 positions you for compliant BPS compliance reporting well ahead of the June 1, 2028 deadline. Waiting until 2027 to begin the audit compresses this timeline and increases risk of deadline non-compliance.

Case Study: Mid-Size Suburban Office Building

To make this concrete, here’s a real example:

Building Profile: 65,000 gross square feet, General Office, suburban Portland location, built 1998, currently Tier 2 performance with baseline EUI of 17.8 kBtu/sf/year.

Compliance Target: Tier 1 target of 13.2 kBtu/sf/year (26% energy reduction required).

Audit Cost: $13,500 (3-day audit, 6-week turnaround).

Recommended Improvements (from audit):

• Rooftop unit replacement: $95,000, saves 2.1 kBtu/sf/year, 7.2-year payback
• Lighting retrofit with controls: $67,000, saves 1.8 kBtu/sf/year, 4.1-year payback
• BMS optimization: $12,000, saves 0.9 kBtu/sf/year, 1.8-year payback
• Window replacement (north/east exposure): $140,000, saves 0.8 kBtu/sf/year, 11.3-year payback

Energy Trust Rebates: $58,000 (HVAC: $28,000; Lighting: $26,000; Controls: $4,000)

Net Cost After Rebates: $216,000

Projected Compliance Performance: 13.0 kBtu/sf/year (exceeds 13.2 target)

Timeline: Audit (6 weeks) → bidding and permitting (6 weeks) → construction (8 weeks) → post-retrofit verification (4 weeks) = approximately 6 months of work.

Total Investment: $229,500 (audit + improvements − rebates)

Annual Utility Savings: $24,700

Simple Payback Period: 9.3 years

This building achieves compliance, saves $24,700 annually in perpetuity, and positions itself well for future regulations. The owner can access Energy Trust financing at favorable terms to help fund Phase 2 improvements.

FAQ: Office Building BPS Compliance

Q: If my office building is only 33,000 square feet, am I exempt from BPS?

A: Yes. Buildings under 35,000 gross square feet are not required to comply with Oregon BPS. However, verify square footage carefully using official documentation. The threshold is gross square footage including mechanical spaces, not rentable square footage.

Q: My building is multitenant. Who is responsible for BPS compliance?

A: The building owner (not individual tenants) is responsible for compliance. This is a property-level obligation. For multitenant buildings with submetered utilities, the owner must consolidate all submetered consumption for compliance calculations.

Q: Can I use a lower-cost energy assessment instead of a full ASHRAE Level 2 audit?

A: For official BPS compliance pathways and to access Energy Trust incentives, ODOE requires an ASHRAE Level 2 audit conducted by a qualified energy auditor. A lower-cost Level 1 audit is insufficient for compliance planning and incentive qualification.

Q: What if my office building is smaller than 35,000 square feet? Do I still have to comply?

A: If it’s between 20,000 and 35,000 square feet, it’s a Tier 2 building and must benchmark and report its energy use by July 1, 2028 — no audit mandate and no penalties under current rules. Buildings under 20,000 square feet are not currently covered, though ODOE may expand the program in the future.

Q: Can I meet my 2028 deadline with just operational improvements, without capital investments?

A: It depends on your building’s current performance and tier. Many Tier 1 office buildings will require some capital improvements to reach compliance targets. However, combining operational improvements (Phase 1) with strategic capital investments (Phase 2) often delivers the best ROI and is more achievable than trying to rely solely on operational changes.

Q: How do I find a qualified energy auditor in Oregon?

A: The Oregon Department of Energy maintains a list of ODOE-listed Qualified Energy Auditors (QEAs) authorized to conduct ASHRAE audits for BPS compliance. Verify that your auditor holds current QEA (Qualified Energy Auditor) certification and has experience with office buildings comparable to yours.

Next Steps: Start Your Compliance Planning Now

For Tier 1 office buildings, the 2028 deadline is now within the typical timeframe required to plan and execute energy improvements. Waiting another year to begin compliance planning significantly increases risk of deadline non-compliance and eliminates opportunities to sequence improvements strategically and access rebate programs.

The first step is getting your building audited by a qualified ASHRAE Level 2 auditor and understanding your baseline performance and compliance target. For immediate questions about whether your building is Tier 1, contact the Oregon Department of Energy directly or review your building’s benchmarking data in EPA ENERGY STAR Portfolio Manager.

If you’re managing an office building in Portland, Eugene, Hillsboro, Salem, or elsewhere in Oregon and want to understand your compliance obligations and cost to achieve compliance, our energy audit and BPS compliance consulting services are designed to help building owners plan efficiently and meet deadlines on schedule.

The 2028 deadline will arrive faster than it seems. Office buildings that start compliance work now will meet their obligations efficiently and without financial distress. Those that wait will face compressed timelines, scheduling bottlenecks, and the risk of substantial penalties.

Learn more:

• ASHRAE Level 2 Energy Audit Explained
• How Much Does an Energy Audit Cost?
• Oregon BPS Compliance Deadlines
• Energy Trust of Oregon BPS Incentives
• Contact us for a compliance consultation