Regulations for Energy Efficiency in the PNW: What They Mean for Healthcare Buildings

By: Julianna Plant, Senior Preconstruction Manager

New building performance standards impacting healthcare are coming to Washington and Oregon to reduce energy use and emissions from the building sector. How prepared is your organization?

The state of Washington has taken a leading role in enforcing new energy-efficiency standards that could influence how other states implement strategies for decarbonization.

In 2019, Washington passed the Clean Buildings Act (CBA). The resulting Clean Building Performance Standards (CBPS) set by the Department of Commerce took effect in July 2021 with the goal of improving the operational efficiency of our existing commercial building stock by meeting ASHRAE 100 standards.

By 2026, commercial buildings larger than 220,000 square feet must meet minimum energy performance (as measured by Energy Use Intensity, or EUI). The following year, buildings 90,000 square feet and above will fall under the same energy compliance requirements. And by 2028, the requirement will hit buildings larger than 50,000 square feet.

Owners who don’t meet the requirements by the deadline will face fines until they retrofit their building to meet the target EUI.

Meanwhile, Oregon is still in the final rulemaking phase of its building-performance standards, which are set be finalize in late 2024. The state’s Department of Energy will then be mandating that building owners benchmark their energy use starting in 2028 to inform potential future standards and EUI compliance for buildings larger than 200,000 square feet.

At the moment, there’s no set date for when Oregon will enforce compliance and levy fines.

Taking the first steps Washington’s CBPS primarily impacts existing buildings—not buildings under construction—and has a dictated timeline for improvements.

The first step to assessing the impact is to understand your building portfolio’s current state, energy use, operations and management and what base target EUI each building must meet by which deadline. If you don’t already know your building’s energy use, your organization’s facility managers are great resources who can help draft energy plans and operations plans. You might also start by checking with your utility company.

Energy Star Portfolio Manager can also be a good place to collect information.

Owners should also consider hiring or consulting with an energy auditor or qualified professional to help them understand their building’s target EUI and, if necessary, what they will need to modify to meet the energy performance metrics.

Once owners have a clear understanding of their portfolio’s energy use and anticipated compliance needs, they can begin making informed decisions about phased upgrades, operational changes, and the investments they’ll be prioritizing.

Updates could be a simple switch to LED lighting paired with local rebates to offset the costs, installing submeters, or implementing education programs to influence user-behavior. For other buildings, it could require bigger steps, like building envelope modifications, or substantial MEP upgrades with opportunities to add high-performance building systems, which require lengthy permit processes and significant capital funding.

Other strategies might include upgrading electrical infrastructure or implementing renewable energy such as solar, micro wind, King County sewer recovery pilot program, while creating building resiliency.

While the timeline may seem far away, it’s important to remember that compliance requires 12 months of energy tracking, so the deadline to be watching is June 1, 2025. Start now to give yourself 24 months to evaluate funding options, energy efficiency measures, permitting, design and logistics.

Capitalize on funding opportunities

Another incentive to start early is to give yourself maximum time to secure possible funding, tax credits, rebates, and financing.

I often recommend that owners create a go/no-go matrix to evaluate which funding options might work in the near and long-term. Remember that you may be eligible to pair local, state, federal, and utility funding sources to offset your costs, so don’t limit yourself to just one source.

While assessing these funding pathways, it’s worth asking the following questions as you weigh each opportunity:

  • Are you eligible?
  • What is the effort level to apply or comply?
  • Realistically, what is the probability of receiving funds?

Starting early means giving your organization amply time to achieve compliance once the first minimum EUI requirement takes effect in about two years’ time.

This blog post was adapted from a presentation by Lewis’ Julianna Plant and Interface Engineering, Inc.’s Andrew Flanagan at the 2024 Oregon Society for Healthcare Engineering Spring Symposium in Bend, Oregon.