Oregon Building Performance Standard: A Practical Guide for Building Owners

Oregon is launching its first statewide Building Performance Standard (BPS), a regulation designed to reduce energy consumption and greenhouse gas emissions from existing commercial and multifamily buildings. Starting in January 2025, building owners must begin tracking energy use and reporting performance against defined targets to comply with new state regulations.

The BPS draws from the ASHRAE/IES Standard 100-2024 framework and incorporates Oregon-specific compliance pathways, performance thresholds, and reporting schedules. If your business owns or operates buildings in Oregon, you must understand your responsibilities under this standard—and prepare accordingly.

What is the Oregon Building Performance Standard?

The Oregon BPS is a performance-based regulation adopted by the Oregon Department of Energy. It requires Tier 1 and Tier 2 buildings to track their energy use intensity (EUI) and meet specific thresholds to reduce energy waste and emissions. The standard applies to existing buildings and campuses and is structured to support the state’s broader climate goals, including carbon emissions reductions and increased energy efficiency across the building sector.

Who Must Comply Oregon's BPS Ordinance?

The Oregon BPS applies to two categories of buildings:

Tier 1 Buildings:

Nonresidential buildings with a total gross floor area of 35,000 square feet or more.

Tier 2 Buildings:

Multifamily buildings, schools, hospitals, and nonresidential buildings between 20,000 and 35,000 square feet.

District campuses and connected buildings that share energy systems may also be subject to compliance requirements.

What Are the Compliance Requirements?

1. Benchmark Energy Performance

Covered buildings must calculate and submit their Energy Use Intensity (EUI), which represents the energy used per square foot, normalized for weather and occupancy. Energy benchmarking must be completed using ENERGY STAR Portfolio Manager.

2. Establish An Energy & Emissions Management Plan

Tier 1 buildings must designate a Certified Energy Manager (CEM) to develop a formal Energy Management Plan (EMP). This plan includes:

• Measured EUI and annual energy data.
• Energy efficiency measures (EEMs) and implementation timelines.
• Staff training and commissioning plans.
• A plan for fossil fuel phase-out and electrification readiness.
• Capital planning for long-term equipment upgrades.

Tier 2 buildings have simplified requirements and must complete benchmarking and submit documentation but are not required to develop an EMP.

3. Meet or Beat Your Building’s EUI Target

Each building type has a defined EUI target based on national performance data and Oregon’s climate zones. If your measured EUI is at or below your building's EUI target, you are in compliance.

If your EUI is above the target, you must:

• Undergo a Level 2 Energy Audit with Decarbonization Assessment.
• Implement the recommended optimized bundle of energy efficiency measures.
• Recalculate EUI after implementation to verify compliance.

4. Submit Verification of Improvements

Within 15 months after implementing upgrades, you must submit updated data to demonstrate that your building now meets its EUI target. If the target is still not met, further action may be required.

How Oregon Defines Performance Targets

Performance targets are set based on:

• Building type and primary activity (e.g., office, hotel, school).

• Oregon’s climate zone.

• Number of operating shifts per day.

• Square footage and usage mix.

For mixed-use buildings, Oregon allows the use of weighted average EUI targets, and exemptions exist for historical buildings and vacant properties.

What Happens If You Don’t Meet the Targets?

Buildings that fail to meet performance targets must:

• Complete an audit.
• Implement all cost-effective measures.
• Submit ongoing documentation and performance data.

If targets are still not met after improvements, conditional compliance may be granted while additional steps are taken. Noncompliance may result in penalties or enforcement by the Oregon Department of Energy.

What Should Building Owners Do Now?

If your building is subject to Oregon’s BPS, you should:

• Determine your building’s tier and compliance path.
• Begin benchmarking energy use now using ENERGY STAR Portfolio Manager.
• Designate a Qualified Energy Manager if required.
• Prepare your Energy and Emissions Management Plan.
• Schedule your energy audit if performance is below the target.
• Budget for implementation of cost-effective energy efficiency measures.
• Engage early with utilities and service providers for support and incentives.

Why This Matters For Oregon Businesses

Complying with the Oregon Building Performance Standard helps your organization:

• Reduce energy costs through efficiency.
• Improve occupant comfort and indoor air quality.
• Increase building value and marketability.
• Avoid potential noncompliance penalties.
• Support Oregon’s clean energy transition and climate commitments.

Early compliance and proactive upgrades not only reduce risk but also create long-term value. As buildings move toward net-zero carbon performance, Oregon’s BPS gives businesses a clear framework for action.