The practical difference
Think about a recurring question from an owner: “Why did energy use change, and what will we do about it?” The EMP is where the building’s energy information and management decisions come together. The O&M records help explain whether schedules, equipment condition or incomplete tasks could be contributing to that change.
| Question | EMP | O&M program |
|---|---|---|
| What is being managed? | Energy performance, goals and accountable decisions | Systems, equipment and controls |
| What does the team track? | Energy use, EUI, comparisons and changes in operation | Tasks, frequencies, condition and completion records |
| What happens next? | Review results and assign priorities or decisions | Carry out work, record findings and follow through |
| How are they connected? | References the O&M program and implementation records | Feeds useful operating evidence back into management review |
What belongs in the energy management plan
Section 5 of WAC 194-50 addresses energy accounting, initial EUI and weather-normalized EUI, annual updates and comparison with the target, and changes in occupancy, operating hours or equipment that affect energy use. It also incorporates the O&M program, implementation plan and implementation documentation. Annual occupant access to the EMP is part of the rule.
A useful working plan helps the next manager understand the building without repeating the whole investigation. Keep a clear description of the property, a responsibility list, the location of energy records, a review process and a record of decisions. Where information is incomplete, label the gap and assign follow-up rather than presenting an assumption as a measured result.
What belongs in the O&M program
The O&M program translates operating intentions into tasks and evidence. Section 6 directs implementation through Annex L. Include equipment and control inventories, maintenance responsibilities, task timing and the records needed to follow what was completed. The detailed O&M guide walks through that work.
The same contractor report can support both documents, but in different ways. An equipment finding belongs with the relevant maintenance task. A decision about how that finding affects the energy plan belongs with the owner’s management review. Keep the connection visible instead of pasting the whole report into several disconnected folders.
A simple example of how they work together
Suppose a manager notices increased energy use after the building’s operating hours change. The EMP record would document the change, the comparison being reviewed and who will investigate. The O&M program would point to the relevant operating schedules, controls and inspection tasks. The team would then record what it found and any authorized correction.
The example does not establish a savings estimate or prescribe a technical solution. Its purpose is to show a traceable sequence: information, review, assigned action, evidence and follow-up. That sequence remains useful even when an investigation finds no equipment fault.
A target still needs attention
Tier 2 does not currently have to meet a performance target. It still involves measuring energy use and determining or reporting the applicable energy metric. WAC 194-50-070 assigns the target determination to the QEM and includes the national median site EUI exception when a target cannot be developed. Do not leave the metric out of the plan because a performance improvement is not presently mandated.
Keep the inputs consistent across the plan, Portfolio Manager and filing forms. A mismatch in area, activity or operating assumptions makes later comparisons hard to interpret. If an owner changes a building’s use or service arrangements, record the change and ask the QEM how it affects the reporting assumptions.
Organize one connected evidence folder
A practical folder structure separates the management plan, equipment/task register, energy records and completed-work records, with an index connecting them. Use a stable building ID and equipment IDs in filenames. Keep controlled final versions, note who maintains each document and avoid personal login credentials in shared files.
- Compare existing plans against current reporting requirements.
- Resolve contradictions between the plan, maintenance schedule and actual operations.
- Assign future updates and occupant access, not only submission tasks.
- Keep dated decisions and evidence of actual implementation.
Reporting tools are different from optional development aids
Commerce's current Tier 2 instructions require both completed EMP and O&M reporting tools with the compliance application. The Word EMP template and Excel O&M development workbook are optional aids. Download current versions through the document library; an existing document may be used if it meets the standard.
The twelve-month energy-data requirement is separate from when new EMP/O&M implementation can begin. Follow current Commerce timing guidance and use the overall compliance checklist to plan the remaining steps. For scope and published service options, see pricing or request a building-specific assessment.
This is an owner-focused explanation, not a determination for a particular building. Requirements and program terms can change. Check the linked current official materials and confirm the building-specific route with Commerce and the responsible professionals.
Meter & Mortar is an independent service provider. Preparation support does not constitute Commerce approval or an incentive award. For service scope, see published pricing and submission responsibilities.