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The State of Oregon adopted new energy performance requirements for commercial and multifamily buildings. These are in addition to Portland’s commercial energy reporting requirements; here is what commercial property owners need to know.
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Like the City of Portland’s program, the State of Oregon’s program will use ENERGY STAR Portfolio Manager®, a free online tool, and property owners are responsible for compliance. However, the two programs have different reporting requirements and deadlines, depending on building size and type. The State of Oregon’s program also includes minimum energy use targets for some buildings.
We are working closely with the Oregon Department of Energy to align the data processes, but property owners will need to report to both places. Learn more about how this may affect you below, and consult the State of Oregon’s website for full information and details about their program, or email the State of Oregon Department of Energy at oregonbps@energy.oregon.gov for more information.
Already reporting to City of Portland?
If you already submit annual energy performance reports to the City or Portland, you are well-positioned for future reporting with the State of Oregon.
For 2026 and 2027, you will continue annual energy reporting to the City by April 22, as usual. In 2028, you may also need to submit a report to the State depending on your building type and size, as shown in the chart on their website.
Explore more details of the State's compliance requirements for your building(s), learn more about the State's program on their website or email the State of Oregon Department of Energy at oregonbps@energy.oregon.gov if you have additional questions. If you already submit annual energy performance reports to the City, you are well-positioned for future reporting with the State.
Other commercial property owners
The State of Oregon’s program includes commercial buildings not currently covered by City of Portland’s program. For instance, the State’s Tier 1 requirements apply to warehouses and Tier 2 requirements include benchmarking for multifamily residential buildings and schools.
These property owners will also use ENERGY STAR Portfolio Manager. Learn more about the State of Oregon’s full Building Performance Standards and requirements on their website.
Example reporting scenarios
Each building owner must assess whether their building is required to report to the City of Portland and/or the State of Oregon. Here are three common buildings, including types and sizes, and the requirements these specific examples would have to meet. Please refer to the City of Portland and State of Oregon websites to determine what requirements your building(s) must meet.
Hotel
In addition to reporting to the City every year, a 200,000 sq. ft. hotel in Portland would be considered a Tier 1 building by the State of Oregon and would be required to report energy benchmarking data to the State and demonstrate compliance with an energy use target by June 1, 2028, and every five years thereafter.
Large Office
In addition to reporting to the City every year, a 100,000 sq. ft. office building in Portland would be considered a Tier 1 building by the State of Oregon and must report benchmarking data to the State and demonstrate compliance with an energy use target by June 1, 2029, and every five years thereafter.
Small Office
In addition to reporting to the City every year, a 30,000 sq. ft. office building in Portland would be considered a Tier 2 building by the State of Oregon and must report energy benchmarking data to the State by July 1, 2028. The Oregon Department of Energy will then evaluate Tier 2 benchmarking data and make recommendations for future Tier 2 Building Performance Standards to the Governor and Legislature by October 1, 2028.