1. Confirm the building, area and reporting route
Begin with the building record in the Clean Buildings Portal, the owner's notice and the actual floor-area evidence. Correct errors rather than treating an assessor estimate or a missing notification as a final coverage decision. Annex Y assigns owners responsibility for reviewing those records and says missing notification does not remove the obligation.
Create a separate working record for each building. A street address, tax parcel and connected complex do not always describe the same reporting boundary. Flag mixed-use space, shared systems and multiple structures for review before combining energy or floor-area figures.
- Record the building ID, owner, use, gross floor area and source of the measurement.
- Identify parking, connections to other buildings and disputed classifications.
- Confirm who has authority to update the Portal record and share access.
2. Assign people and document access
A Tier 2 submission involves a qualified energy manager (QEM); the QEM's target and submission roles are set out in WAC 194-50-040 and WAC 194-50-070. Hiring a preparer does not transfer the owner's implementation duties. Agree who collects records, who operates equipment and who reviews and submits the application.
A useful responsibility list names an owner decision-maker, a property contact, the maintenance lead, the utility-data contact and the QEM. Identify a backup for each role so a staff change does not leave the filing dependent on one login or an unavailable contractor.
3. Assemble complete benchmarking records
Use ENERGY STAR Portfolio Manager to organize measured building energy use. Section 5 calls for at least 12 consecutive months of measured data within the applicable two-year window before the compliance date. Include the relevant energy sources and review gaps, dates and reporting boundaries. For an early submission, Annex Y3.2.1 uses a two-year lookback from submission; confirm the applicable period with the QEM. This is an energy-data requirement, not a requirement to operate a new O&M program for twelve months.
Ask utilities early about whole-building data and sharing. Keep a meter-to-building list in the private working folder so an account change, vacant suite or shared meter can be explained. Do not email tenant names or account credentials as part of an initial service inquiry.
4. Determine and report the applicable energy metric
The QEM determines the energy use intensity target (EUIt) and documents the applicable building activity. Where the standard's target cannot be developed, the rule provides for reporting Portfolio Manager's national median site EUI. Section 7 explains those paths. Tier 2 does not currently have to meet a performance target, but benchmarking and target-related reporting still matter.
Keep the assumptions beside the calculation: area, activity type, operating hours and any mixed-use allocation. Resolve conflicting inputs before copying values into reporting forms.
5. Put the EMP and O&M program into use
Develop and implement the energy management plan (EMP) and operations and maintenance (O&M) program. Commerce's current instructions allow implementation to begin at any time before applying for compliance. Existing documents can be used if they meet the standard; the optional Word and Excel development tools are not the mandatory reporting forms.
Use the EMP versus O&M guide to separate management decisions from equipment tasks, then work through the O&M program checklist. A purchased document with no building-specific responsibilities or implementation evidence leaves work unfinished.
6. Review the application as an evidence package
Annex Y4.2 lists the EMP and its reporting tool, O&M program and its reporting tool, Form A (or Form J for grouped buildings), and Forms B and C subject to the applicable exceptions. Follow the current Portal instructions for the building's route. Keep the completed reporting tools with the documents they describe.
- Check building IDs, areas and owner names agree across the package.
- Resolve blanks and explain applicable exceptions with the QEM.
- Keep submission receipts, Commerce correspondence and approved revisions.
- Assign the ongoing energy and maintenance recordkeeping after filing.
7. Investigate exceptions without assuming approval
Exemptions and extensions are different application routes. Under Annex Y, an exemption application is due at least 180 days before the compliance date and approval applies to the current cycle. An extension also requires an application and supporting grounds; it is not permission to stop work or casually miss the deadline.
If records suggest an exception, collect the supporting documents and ask Commerce about the correct route promptly. Separately review Tier 2 incentives before budgeting for a payment; compliance coverage alone does not guarantee an award.
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.