Beware of Misleading Tier 2 Solicitations: What Washington Building Owners Should Know

A letter arrives with your building’s address, a compliance deadline and a warning about fines. It looks official, and suddenly you are wondering whether you have missed something important. Before signing a contract or sending money, take a moment to check who sent it. Understanding your building’s requirements starts with reliable information.

Washington’s Clean Buildings Performance Standard, or CBPS, is a state program that requires covered buildings to track and manage their energy use. The Department of Commerce administers it. Tier 2 generally covers commercial buildings larger than 20,000 and up to 50,000 square feet, along with multifamily residential buildings larger than 20,000 square feet. The first Tier 2 reporting deadline is July 1, 2027. Each building’s size, use and possible exemptions need to be reviewed before deciding what applies.

For Tier 2, the work includes tracking energy use, developing and implementing an energy management plan, and establishing an operations and maintenance program. A qualified energy manager helps guide that work. These requirements connect utility information with how a building operates every day. Tier 2 buildings must also calculate and compare their energy use with a target, but Commerce says they are not currently required to meet that target. An unfamiliar compliance notice should not lead an owner to assume an expensive equipment replacement is automatically required.

The confusion around these requirements has created an opening for misleading marketing. In February 2026, Commerce published a warning about third-party letters and notices that appeared to come from, or refer to, the department while containing misleading or inaccurate information. Its current website also warns about suspicious calls and marketing materials. Pressure to sign immediately, unclear claims of government affiliation, or statements that your building is already in violation deserve careful checking.

If a message seems suspicious, contact Commerce’s Clean Buildings team at Buildings@Commerce.wa.gov before acting. Use the contact information on Commerce’s own website to verify the communication. Ask any service provider to explain its scope, fees and the basis for its claims about your building. Incentive funding is available for eligible Tier 2 projects, but payments depend on program requirements, approval and available funding. A solicitation alone does not establish eligibility or guarantee payment.

Student Energy Managers serves as a local trusted messenger, helping building owners and tenants understand the process and find a practical starting point. SEM is a paid student workforce supported by experienced energy professionals. Students help organize building information, review utility data, prepare management documents and work with the people who operate and occupy the building. Professional supervision and review are part of that process. Owners receive useful support while students develop skills through real work in their communities.

Commerce has highlighted this student workforce approach. Its May 2025 Clean Buildings Bulletin featured Wenatchee High School’s paid Advanced Energy Management internship, describing students working as part of a professional energy management team for clients including their school district and JCPenney. That feature offers a public example of the work behind SEM’s community model. Commerce remains the source for official requirements and compliance decisions, while SEM helps people understand and work through the process.

If you own a building, begin by confirming its requirements and gathering the records your team will need. If you are a tenant, share any notice with the building owner or property manager so the response starts with a review of the whole building. You can bring your questions to SEM, including questions prompted by a confusing solicitation. Visit SEM’s Get Started page to connect with a student workforce that is here to help you move forward with clear information and professional guidance.