Performance · Washington CBPS · Seattle BEPS
I license Threshold to engineering firms and Qualified Persons who deliver CBPS and BEPS compliance. If you own or manage a building, start here: tell me about it, and I'll suggest licensed teams that can screen it and scope the work.
Coverage
Floor area excludes parking. A Seattle building can be covered by both state and city standards, with different deadlines and metrics.
WASHINGTON STATE · COMMERCE
Nonresidential, hotel, motel, and dormitory floor area over 50,000 sq ft. An EUI target or an alternative pathway, plus an energy management plan and an O&M program.
| GROSS SQ FT | COMPLIANCE DUE |
|---|---|
| 220,001 and up | June 1, 2026 · passed |
| 90,001–220,000 | June 1, 2027 |
| 50,001–90,000 | June 1, 2028 |
CORE OF THIS PRACTICE
CITY OF SEATTLE · OSE
Each building over 20,000 sq ft. Benchmarking verification and a GHG report first, then greenhouse gas intensity (GHGI) targets by five-year intervals. Reports are due October 1.
| GROSS SQ FT | REPORT | FIRST TARGET |
|---|---|---|
| 220,001 and up | 2027 | 2031 |
| 90,001–220,000 | 2027 | 2032 |
| 50,001–90,000 | 2028 | 2033 |
| 30,001–50,000 | 2029 | 2034 |
| 20,001–30,000 | 2030 | 2035 |
| Portfolios and campuses | 2028 | 2033 |
CORE OF THIS PRACTICE
WASHINGTON STATE · COMMERCE
Commercial buildings of 20,001–50,000 sq ft, and multifamily buildings over 20,000 sq ft. Benchmarking, an energy management plan, and an O&M program, due July 1, 2027. No EUI target.
For one Tier 2 building, a filing service may be the better fit, and I'll say so on the first call. Licensed teams screen Tier 2 buildings within a larger portfolio along with the rest.
What's at stake
| THE RISK | WHAT IT CAN COST | FIRST STEP |
|---|---|---|
| A Tier 1 building misses its CBPS compliance date | Up to $5,000, plus up to $1.50 per sq ft for a continuing violation, set by Commerce rule (WAC 194-50) | Get the building screened: confirm coverage, pathway, and what documentation exists |
| A Seattle building misses its GHGI target | Up to $10/sq ft nonresidential, $7.50 multifamily, $2.50 affordable housing, once per five-year interval | Screen against the target interval and estimate the gap before capital decisions are made |
| A BEPS report is late or inaccurate | Up to $15,000 for buildings of 50,000 sq ft or more; up to $7,500 below | Review the benchmarking data before verification |
| The benchmarking data doesn't match the bills | Targets, gaps, and exposure are all calculated on the wrong numbers | Flag and correct the data on the owner side before anything is filed |
For building owners and managers
COMING TO THRESHOLD
An initial triage you run yourself in Threshold. Your results start the referral, so the team you choose begins from your building's record.
I suggest up to three licensed teams that fit the building's standard, type, location, and scope, and you choose who to talk to. Throughline charges no referral fees to owners or teams; referrals are part of the Threshold license.
For engineering firms, Qualified Persons, and energy coaches
Your team keeps the engineering judgment, the client relationship, and the attestation. Threshold adds a quality-control step and automated reporting to your existing Portfolio Manager workflow, and selected licensees receive referrals from building owners who need their services.
Import an ENERGY STAR Portfolio Manager export for one property or a whole portfolio, or a CSV. Re-import a fresh export and the bills update; any decision on a changed bill is withdrawn for review.
Threshold flags bills that differ from the same meter's other bills. Keep, flag, or correct each one with a note; every correction keeps the original and corrected figures, the justification, and who made it, and doubles as the list of what to fix in Portfolio Manager.
Guideline 14 weather-normalized baselines; each fuel's cold-responsive, warm-responsive, and base load; EUI and GHGI screened against CBPS and BEPS targets; the performance gap; deadline and penalty exposure; penalty avoided per dollar of a priced scope; and a short survey that screens pathways and end-use deductions.
Analysts and QPs work on the same client portfolio. The system checks roles of record against credentials, and it time-stamps and attributes every decision. Editable Word, PDF, and Excel reports go to the QP as a draft record; the QP reviews it, then prepares, signs, and files the compliance documentation.
Referral eligibility is selective. Owners who request a team here are pointed to up to three eligible licensees by standard, building type, location, and scope, and choose who to talk to. No referral fees in either direction.
Onboarding, subconsulting on the advisory scope, and the Qualified Person role when a project needs one.
Your data stays yours. Each firm works in its own private instance and database, and only people the firm adds can sign in. Data is encrypted at rest and in transit, user activity is logged, and each instance is backed up daily, weekly, and monthly, with the oldest backups kept 89 days. At the end of an engagement, you download a complete export, and the data is deleted within thirty days.
RULES AS OF OCTOBER 28, 2026
Licenses are priced per building, with no minimum building count and no seat charge; accounts for your analysts and subcontractors are included. A license can cover a single project, a portfolio, or ongoing work across your clients, with support billed hourly. Referral eligibility is selective. Pricing on request.
After the screening
Boundaries and sources
Bills out of line with the meter's history; weather-normalized baselines; coverage, deadlines, and targets from the published rules; the gap and potential exposure before any relief.
Pathway selection, audit findings, measure savings, and every attestation. That's the licensed team's Qualified Person or engineer of record, or me when I'm engaged in that role.
Files, certifies, or stands in for a determination by Commerce or the City of Seattle.
EACH PROGRAM FILE RECORDS ITS SOURCES, AND AN AS-OF DATE · FIRMS ARE TOLD IN WRITING AT LEAST TWO BUSINESS DAYS BEFORE AN UPDATE REACHES THEIR INSTANCE · Washington Department of Commerce, Clean Buildings Performance Standard (WAC 194-50; 2026 Integrated Document) · City of Seattle Office of Sustainability & Environment, Building Emissions Performance Standard and Director's Rule 2025-01