Washington Tier 2 guide for multifamily buildings

Check the building rather than counting units

Coverage depends on the building and its floor area, not just apartment count. Annex Y establishes the Tier 2 schedule for multifamily buildings over 20,000 gross square feet. Multiple structures, connected areas, mixed uses and group reporting need particular attention. Do not assume that one parcel, one owner or one service contract automatically means one compliance record.

Start a property register with a building ID, actual use, gross area and evidence source for each structure. Note retail, offices, common areas and parking so the QEM can review the reporting assumptions. Resolve differences between the owner’s records, Portal record and Portfolio Manager before creating a filing package.

Make owner and manager responsibilities explicit

Property managers often hold the maintenance records while owners control contracts, authorizations and capital decisions. Agree who can share records, correct the building profile and approve work. If an association or board is involved, identify the person with authority to act and the process for obtaining a decision.

A QEM has defined Tier 2 target and submission responsibilities under WAC 194-50-040. A management company or outside preparer can help coordinate tasks, but the owner still needs an implementation process that works at the property. Our property-manager page explains how a portfolio can be reviewed building by building.

Coordinate energy records across accounts

Whole-building data can involve owner and resident accounts as well as shared systems. RCW 19.27A.170 addresses utility data provision. Ask the serving utilities about their aggregation and Portfolio Manager process instead of assuming common-area bills describe the whole property.

Keep a private list of the relevant meters, fuels, date ranges and building boundaries. Flag master meters, separately metered spaces, account changes and shared equipment. Collect authorized aggregated data through the appropriate utility process; an introductory assessment does not need tenant names, unit-level personal details or utility passwords.

The energy-data period is separate from how long a new plan has been operating. Section 5 requires twelve consecutive months of measured energy data within the applicable two-year window. Ask the QEM to confirm the usable period and any gaps before relying on an EUI comparison.

Connect maintenance records to the actual property

Collect the inventory and service records for systems that serve the building, including shared heating, hot water, ventilation, lighting and controls where present. Then establish how the tasks, schedules, findings and repair follow-through are recorded. A contractor’s scope may cover only part of the property; identify what remains with the owner or manager.

The O&M program guide gives a task-register checklist. The EMP comparison explains how those operating records connect to energy review and management decisions. Treat this as coordination of actual work, not just assembly of a document for submission.

Do large multifamily buildings have to meet a target now?

Multifamily Tier 2 buildings currently do not have to meet a performance target, but they still need the required energy monitoring, EMP, O&M and reporting. The QEM determines the applicable EUIt or addresses the national median site EUI exception under Section 7. Size alone is not a reason to copy a Tier 1 nonresidential improvement pathway into a multifamily Tier 2 filing.

Keep operational questions separate from the minimum filing pathway. An owner may choose energy improvements for comfort, reliability or cost reasons; that is a building-specific decision and may involve technical services beyond record preparation.

Review the multifamily incentive without assuming a payment

Eligible multifamily owners may be able to raise the incentive calculation up to $0.75 per eligible square foot through the program's anti-displacement provisions. Cost limits, a signed agreement, approval, participating utilities and payment capacity matter. Read the full incentive guide and Commerce program terms before budgeting or accepting a commitment.

Make the decision traceable: who reviewed the agreement, what area and estimated costs support the application, and who will track its approval and payment? Keep an incentive estimate separate from the compliance scope and the owner’s contract with a service provider.

A useful first working session

Bring the owner or authorized manager together with the maintenance and utility-data contacts. The aim is to identify the building, confirm authority, locate existing records and assign a short gap list. That is more useful than trying to solve every technical question in the first meeting.

• Reconcile the building ID, uses, area and reporting boundary.
• Confirm utility-data access and the available energy period.
• Locate the current EMP, maintenance program, contracts and logs.
• Assign a QEM and the owner’s implementation responsibilities.
• Review reporting forms and any potential exception with supporting evidence.
• Set a working schedule before July 1, 2027; label internal target dates as recommendations, not statutory deadlines.

Sources

1. Commerce: Tier 2 coverage, implementation and deadline
2. WAC 194-50-160: multifamily reporting schedule and evidence
3. WAC 194-50-040: Tier 2 responsibilities
4. WAC 194-50-050: energy monitoring
5. WAC 194-50-070: energy target requirements
6. Commerce: multifamily incentive provisions
7. RCW 19.27A.210: state energy performance standard