Woodburn Building Performance Standard

Woodburn and Silverton sit on opposite sides of the I-5 corridor in Marion County, and they represent two very different commercial building problems under Oregon’s Building Performance Standard. Woodburn is a distribution and industrial hub — it hosts one of the largest outlet center complexes in the Pacific Northwest and a growing concentration of food processing and cold storage facilities along the I-5 interchange. Silverton is a small historic city with a concentration of civic buildings, a regional medical campus, and light commercial stock that edges above BPS thresholds in places.

Both cities contain covered buildings. Both are subject to the same OAR 330-300 requirements. But the compliance challenges, the building types, and the urgency look different depending on which side of the valley you’re on.

Woodburn & Silverton BPS Snapshot

Data point	Detail
County	Marion
Woodburn population	~27,000
Silverton population	~11,000
Primary electric utility	Pacific Power
Primary gas utility	NW Natural
Avg. commercial electric rate	~$0.09–$0.11 / kWh
Key covered building types	Outlet retail, cold storage, food processing, civic/government, medical
Tier 2 reporting deadline	July 1, 2028
Tier 1 deadline (35,000–90,000 sq ft)	June 1, 2030
Tier 1 deadline (90,000–200,000 sq ft)	June 1, 2029
Tier 1 deadline (200,000+ sq ft)	June 1, 2028

Note: Silverton is below the typical population threshold for dense commercial BPS coverage. Its covered buildings are mostly institutional and medical — still subject to BPS, but lower in count than Woodburn.

Woodburn’s Covered Building Stock

Woodburn’s commercial real estate is anchored by the Woodburn Premium Outlets, a multi-building open-air outlet center that brings well over 400,000 sq ft of retail space under one ownership and management structure. As a nonresidential property over 200,000 sq ft, the outlet campus faces the earliest Tier 1 deadline — June 1, 2028 — less than two years out. For a retail complex of that scale, an ASHRAE Level 2 energy audit involves analyzing HVAC systems across dozens of tenant spaces, common-area lighting and mechanical systems, parking lot and exterior lighting, and the overall building envelope across multiple structures.

Beyond the outlets, Woodburn’s I-5 interchange area has attracted distribution and cold storage development. Industrial and warehouse buildings at or above 35,000 sq ft are Tier 1 commercial properties under OAR 330-300. Cold storage and food processing facilities tend to carry high EUI baselines because of continuous refrigeration loads — these are the properties most likely to trigger the conditional audit requirement when their measured EUI is compared against the ODOE target.

The Woodburn area also includes a cluster of agricultural services businesses — equipment dealers, packing houses, and processing facilities — some of which may qualify for the BPS exemption pathway for industrial or agricultural operations. That exemption is not automatic; an application is required at least 180 days before the compliance deadline.

Silverton’s BPS Landscape

Silverton’s covered building inventory is smaller and more institutional in character. Legacy Health’s Silverton Medical Center is the most significant covered property in the city — a hospital campus that at 35,000+ sq ft falls under Tier 2 as a healthcare facility. Tier 2 hospitals must benchmark EUI and report to ODOE by July 1, 2028, with no audit mandate and no penalties. But benchmarking is not passive; it requires utility data collection, ENERGY STAR Portfolio Manager entry, and annual reporting. Our Annual BPS Benchmarking service handles that process end-to-end for institutions that don’t want to manage it internally.

Silverton also has civic and government buildings — city hall, fire stations, and public works facilities — that may meet coverage thresholds. Government buildings follow the same BPS pathway as private commercial properties; the owner is simply a public agency rather than a private entity. For more on how municipal buildings handle BPS compliance, see our Government & Municipal Building BPS post.

The Compliance Process for Mid-Valley Buildings

Whether you’re managing a retail complex in Woodburn or an institutional campus in Silverton, the BPS compliance sequence is the same:

Step 1 — Confirm coverage. Calculate gross floor area excluding parking. Match building type to the tier table above. If you’re covered, identify your specific compliance deadline based on size.

Step 2 — Benchmark EUI. Collect 12–24 months of utility data from Pacific Power and NW Natural. Enter it into ENERGY STAR Portfolio Manager. Calculate your current Energy Use Intensity in kBtu/sq ft/year. Compare against the ODOE EUI target for your building type.

Step 3 — Determine audit need. If your EUI meets the target, you’re on the documentation and O&M plan pathway. If your EUI exceeds the target, you need to notify ODOE at least 180 days before your deadline and complete an ASHRAE Level 2 audit with a Qualified Energy Auditor.

Step 4 — Implement and report. For buildings requiring an audit, the auditor’s report will identify Energy Conservation Measures (ECMs) with cost and savings estimates. You implement the cost-effective ones and document your compliance pathway. For buildings meeting the target, you document the O&M program and Energy Management Plan and submit by the deadline.

What the Audit Costs for a Mid-Valley Property

For most commercial properties in the Woodburn and Silverton area, an ASHRAE Level 2 audit runs $7,500–$17,500 flat fee. Larger or more complex buildings — a multi-structure outlet campus, a cold storage facility with specialized refrigeration systems — run toward the higher end of that range. The audit is a one-time cost that also unlocks access to ODOE’s ECAPP early compliance incentive: up to $0.85 per square foot, capped at $50,000 per building, for work completed at least a year before the compliance deadline. For a 50,000 sq ft covered building, that’s up to $42,500 in potential incentive offsets.

Energy Trust of Oregon also offers BPS Pathway coaching with up to $3,000 in incentives for energy-saving projects, along with standard commercial equipment incentives that stack with ECAPP.

Frequently Asked Questions

Does the Woodburn Premium Outlets need to comply with Oregon BPS?

Yes. The outlet center is a nonresidential commercial property over 200,000 sq ft and falls under Tier 1 with a June 1, 2028 compliance deadline. Given the scale of the campus, an ASHRAE Level 2 audit for a complex of this size should be underway now to allow sufficient time for findings implementation before the deadline.

My food processing building in Woodburn is 45,000 sq ft. Does it qualify for an agricultural exemption?

Possibly. ODOE provides an exemption pathway for industrial and agricultural operations. The criteria are specific, and the application must be filed at least 180 days before your compliance deadline. Whether your facility qualifies depends on its primary use classification. We can help you determine whether an exemption application or a compliance audit is the right path.

Is there any additional local energy reporting for Woodburn or Silverton buildings beyond Oregon BPS?

No. Unlike Portland, neither Woodburn nor Silverton has a local energy benchmarking or reporting ordinance. Oregon BPS under OAR 330-300 is the only compliance program that applies to commercial buildings here.

Silverton Medical Center is a hospital. Does it need an ASHRAE Level 2 audit?

Hospitals at 35,000 sq ft or more are Tier 2 buildings under Oregon BPS. Tier 2 requires benchmarking and reporting by July 1, 2028 — no audit mandate, no penalties. That said, voluntary benchmarking through our Annual BPS Benchmarking service is still worth doing: it establishes a baseline EUI, identifies potential savings, and positions the facility for future compliance periods if Tier 2 obligations tighten.

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The 2028 deadline is approaching for Woodburn’s largest covered buildings, and mid-valley property owners who haven’t started the compliance process are already inside the realistic planning window. Schedule your compliance audit — flat-fee, no hourly billing, results in weeks.