Service · Existing Buildings
Oregon's Building Performance Standard turns energy use into a compliance number. We benchmark your building, show you how far it is from its target, and close the gap the lowest-cost way, usually by fixing how the systems you already own are run.
Oregon's Building Performance Standard (HB 3409, 2023) covers most commercial buildings over 20,000 ft², and the larger ones must do more than report.
Non-residential buildings, hotels and motels of 35,000 ft² or more, excluding parking. You benchmark the building, meet its energy use intensity (EUI) target, and keep an operations and maintenance plan and an energy management plan.
Non-residential buildings, hotels and motels of 20,000 to 35,000 ft², plus multifamily, hospital, school, university, dormitory, senior care and similar buildings of 35,000 ft² or more. You report by July 1, 2028, then every five years.
| Tier 1 floor area | Compliance due |
|---|---|
| 200,000 ft² and up | June 1, 2028 |
| 90,000 to 200,000 ft² | June 1, 2029 |
| 35,000 to 90,000 ft² | June 1, 2030 |
Both tiers use ENERGY STAR Portfolio Manager. Your EUI comes from 12 continuous months of all energy use within the 24 months before you file, and the first filing also needs your energy data back to January 1, 2026. Tier 1 buildings that don't comply can be penalized. Tier 2 buildings only report and face no penalties today.
In Portland? The city's own energy reporting program still applies, with reports due each April 22. It also uses Portfolio Manager, so the same data and setup serve both.
Everything starts with one number: your building's weather-normalized EUI minus its target. Many owners don't know theirs yet. We handle the paperwork that gets you there.
Most buildings that are over target don't need new equipment first. They need the equipment they already have to run the way it was designed to. That's what commissioning does, and it's usually the lowest-cost way to comply.
Start with the building automation system. Schedules that run nights and weekends, supply air and static pressure setpoints that never reset, heating and cooling fighting each other, overrides nobody removed. These are controls problems, and fixing them costs far less than replacing equipment. We use your existing BAS first, setting it up to trend the data the analysis needs.
Retro-commissioning. For a building that's never been tuned, or hasn't been in years, retro-commissioning is a systematic look at how each system actually runs, followed by fixes to the sequences, setpoints and schedules. See retro-commissioning.
Monitoring-based commissioning. Savings drift away when nobody is watching. Continuous monitoring catches faults and drift as they happen, verifies that fixes stuck, and keeps the building under its target in the years after you file. Where your controls can't measure something, such as equipment runtime, airflow or heating plant output, Bluefin Intelligence sensors fill the gap.
Targeted upgrades, only where they pay. Some gaps are too large for operations alone. When that's the case, we rank capital measures by cost and payback so you spend only where the data supports it.
When the target isn't cost-effective. Tier 1 has an investment-criteria path: a building can comply by carrying out the optimized bundle of measures that pay for themselves over their life. Owners aren't required to spend whatever it takes. We help you document that path when it's the right one.
Each step narrows where the money goes, so you spend on sensors and fixes only where the data says they'll pay off.
Most of it happens remotely. Utility data, Portfolio Manager, bill analysis, BAS trend review and controls troubleshooting are all done through secure remote access. We come on site for the hands-on parts: functional testing and commissioning the fixes. That keeps the cost down and lets us serve buildings well outside Portland.
We're independent. We don't sell equipment and we aren't tied to a utility program, so the recommendation is the one that's best for the owner. Bluefin's principal is a licensed mechanical engineer in Oregon, Washington, California, Nevada, Arizona and Hawaii and a Certified Commissioning Professional (CCP), which matters when your filing depends on energy calculations and plans done by a qualified professional.
The first step is a compliance check for each building. It tells you whether the law applies, where your building stands against its target and what it would take to comply, before you commit to anything larger.
| What we need from you | What you get |
|---|---|
| 12 to 24 months of utility bills, or access to your online accounts | Your weather-normalized EUI against your target |
| Gross floor area | Your compliance date and what's at stake if you miss it |
| Your ODOE notice or building ID (UBID), if you have one | The measures most likely to close the gap, ranked |
| Equipment list or mechanical drawings, if available | A recommended path and timeline |
We give you a secure upload link for your project, so bills and drawings go straight into your project folder instead of email attachments.
Own a building over 20,000 ft² in Oregon?
Tell us about the building and we'll check it for you: whether the law applies, how your energy use compares with the target, and the lowest-cost way to comply.
Benchmarking measures a building's energy use per square foot (its EUI), adjusts it for weather, and compares it with similar buildings or a target. Oregon's Building Performance Standard requires it in ENERGY STAR Portfolio Manager.
Non-residential buildings, hotels and motels of 20,000 ft² or more are covered. At 35,000 ft² and up they're Tier 1 and must meet an EUI target; from 20,000 to 35,000 ft² they're Tier 2 and only report. Multifamily, hospital, school, university, dormitory and senior care buildings of 35,000 ft² or more are also Tier 2. ODOE publishes a property inventory list, and covered owners receive a notice. We confirm your tier as part of the compliance check.
Tier 1 buildings are due June 1, 2028 (200,000 ft² and up), June 1, 2029 (90,000 to 200,000 ft²) or June 1, 2030 (35,000 to 90,000 ft²). Tier 2 buildings report by July 1, 2028.
You close the gap with energy measures, or you comply through the investment-criteria path by carrying out the cost-effective measures. A Tier 1 building that expects to miss its target must report early, at least 180 days before its compliance date, and complete an energy audit and life-cycle cost analysis. We can lead both. Penalties apply only to Tier 1 buildings that don't comply.
Usually not first. In most buildings the cheapest savings come from how the existing systems are controlled: schedules, resets, setpoints and sequences. Capital upgrades come later, and only where the numbers support them.
Sometimes. Utility programs such as Energy Trust of Oregon fund existing-building commissioning and other energy measures, and state incentives for early compliance have been offered at times. We'll look for any incentives your building qualifies for and help you apply when they're available. See our incentives page.
Portland's energy reporting program also uses Portfolio Manager, so the same data and setup serve both. Washington has its own law, the Clean Buildings Performance Standard, which works much the same way: larger buildings must meet an energy target, smaller ones benchmark and report, and both use Portfolio Manager. Its sizes, dates and rules differ from Oregon's, so we confirm the requirements for each Washington building individually.
Yes. Our principal has spent much of his career on projects in Washington, California and Nevada, and holds PE licenses in Oregon, Washington, California, Nevada, Arizona and Hawaii. Benchmarking laws elsewhere use the same Portfolio Manager setup and monthly data flow, so we support them too: California's statewide benchmarking law (AB 802) and local programs, Reno's energy and water efficiency program, and Honolulu's benchmarking ordinance. California and Reno are both moving toward performance targets like Oregon's, so benchmarking now puts you ahead of them. Because most of the work is done remotely, distance isn't a barrier; we travel only for on-site testing and commissioning.