Self-Led Education Portal: Operations & Maintenance

The WA State Clean Buildings Operation and Maintenance (O&M) Program requirement targets clear and thorough maintenance plans for the major energy uses in a building and is outlined in Section 6 of the standard. The City of Seattle’s Building Tune Up (Seattle BTU) requirement  overlaps many of the WA State requirements and can be repurposed to fulfill parts of the State law.

WA State Clean Buildings O&M vs. Seattle Building Tune-Up (BTU)

Both the WA State Clean Buildings and Seattle BTU laws require building owners to conduct routine O&M and implement low-cost/no-cost fixes to keep equipment and systems like schedules and set-points operating at their most optimal efficiency points. If your building is compliant with the Seattle BTU program, you have fulfilled many, but not all, of the WA State Clean Buildings O&M requirements. Use the WA State Department of Commerce’s O&M Plan Reporting Tool to guide you through development of your plan and discover which pieces you may have already completed. If you want more direction, consider joining our Light Coaching Pathway for advanced templates and one-on-one support.

The details below show how the WA State Clean Buildings and Seattle BTU overlap and differ to help outline how you can streamline your efforts to comply with both laws.

Important: These are two separate laws that both require compliance proof with the respective authority having jurisdiction (AHJ). Being compliant for one law does not automatically fulfill the requirements of the other.

COMPARE AND CONTRAST:

Steps to ensure system compliance with WA State Clean Buildings

1) Inventory your equipment

2) Create a maintenance plan: Utilize the inventory of equipment to create a plan for each major energy user. The plan should identify the required tasks, required service frequency, resources needed, and the responsible party.

Resources to consider: 1) Seattle Building Tune-Ups Summary Report and workbook to create tasks, 2) Manufacturer O&M manuals, 3) Annex D of the Clean Buildings Law which includes a list of possible maintenance tasks.

3) Set goals: Define goals for the operation of your system. Focus on occupant satisfaction such as visual or thermal comfort, indoor air quality, and efficiency.

4) Define standards: Create standards and performance indicators around acceptable equipment conditions. Operators should understand when equipment is operating outside of the standard or is nearing the end of the useful life.

5) Complete tasks: Complete the maintenance tasks that defined in your plan and follow the frequency schedule. Be sure to document when the tasks are being completed.

6) Inspect: Verify that the maintenance tasks are being completed. Evaluate whether the task type and frequency make sense for your organization.

7) Document: Keep records of your plan and execution. O&M protocols should be treated as living documents as buildings change with upgraded equipment and changes to use and occupancy. All documentation should be organized and accessible for facilities teams and reviewed with new staff to ensure the persistence of O&M protocols overtime.

Resources to consider: 1) Seattle BTU final report, 2) Internal work order systems, 3) Vendor service contracts.

What documentation is required?

Documentation for the WA State Clean Buildings law does not have a set template. Building owners or their authorized representative may submit their O&M Program in a format that works for them to the State’s online Clean Buildings Portal.

Who is qualified to assess, implement, and ensure compliance?

For WA State Clean Buildings, the building owner is ultimately responsible for compliance but can task others with the implementation of the program.

The energy manager is responsible for creating a formal process to ensure that tenant improvements maintain alignment with the building’s energy targets according to activity type.

No certifications are necessary to complete and implement the WA State Clean Buildings O&M program, but it is highly recommended organizations engage on-going maintenance contractors and your in-house facilities staff to conduct the work – and to get better operating cost-savings. Check out Building Operator Certification for a great way to grow in-house skills.

What are the deadlines to comply?

For WA State Clean Buildings, compliance deadlines vary by building size. O&M programs must be functional and in action one year prior to the deadline.

Compliance deadlines for submitting documentation:

  • Tier 1:

    • June 1, 2026: 220,001+ sq. ft.

    • June 1, 2027: 90,001—220,000 sq. ft.

    • June 1, 2028: 50,000—90,000 sq. ft.

  • Tier 2:

    • June 1, 2027: 20,000-49,999 sq. ft. and multifamily housing over 20,000 sq. ft.

Here is an example timeline for a 55,000 sq. ft. building in Seattle:

How do you submit documentation?

WA State Clean Buildings documentation should be submitted via the WA State Clean Buildings portal by a building representative.

  • Seattle BTU covers the following systems:

    • Heating , Ventilation and Cooling (HVAC)

    • Domestic Hot Water (DHW)

    • Building Envelope

    • Lighting

    • Water Use

  • For Seattle BTU, a “Tune-Up Specialist” (see below) must complete the Seattle Building Tune-Ups Summary Report, review it with the building owner, and submit it to the City via the Seattle Services Portal (an online reporting tool). Make sure your Tune-Up Specialist provides you with the final copy of your report.

  • For Seattle BTU, work must be completed by a qualified Tune-Up Specialist that holds specific certifications and years of experience. This person can be either in-house or hired, and several of the certifications are the same as WA State Clean Buildings “Qualified Person”. Learn more here.

  • Seattle BTU assessment and corrective action details must be submitted via the online Seattle Services Portal by the Tune-Up Specialist.

  • All buildings located within the City of Seattle with 50,000 sq. ft. or more of nonresidential space (excluding parking) must comply with the Seattle Building Tune-Ups requirement every five years on a City specific schedule. Buildings that are City Light customers, but not within the city limits, are not covered by Seattle Building Tune-Ups (e.g., Shoreline, Burien, etc.)

Which systems are impacted?

The WA State Clean Buildings law covers the following building systems:

  • Heating, Ventilation and Cooling (HVAC)

  • Domestic Hot Water (DHW)

  • Building Envelope

  • Lighting

  • Refrigeration

  • On-Site Power

Who is Required?

The WA State Clean Buildings O&M requirement applies to all commercial buildings 20,000 square feet or larger in WA, regardless of whether the building already meets the energy performance (EUIt) requirements.

  • Seattle BTU is a more prescriptive law and all submissions are reviewed to confirm compliance. It requires that a qualified building Tune-Up Specialist (more below) conduct an assessment of systems and operations to identify corrective actions, as well as the implementation and verification of required corrective actions for all required systems.

    The Seattle BTU program predefines the maintenance tasks, frequency, acceptable condition, and corrective actions during the compliance cycle.

    The O&M program outlined in the WA Clean Buildings law is created by the building personnel and is reviewed and implemented by staff at the cadence laid out in their plan. Maintenance records should reflect the implementation of this work.

    The WA Clean Buildings O&M Program is a continuous process that must be implemented on an on-going process.

  • Compliance deadlines for submitting Seattle BTU documentation are:

    • October 1, 2023: 200,000+ sq. ft.

    • October 1, 2024: 100,000—199,000 sq. ft.

    • October 1, 2025: 70,000—99,000 sq. ft.

    • October 1, 2026: 50,000—69,000 sq. ft.

    Since Seattle’s BTU deadlines are about 2-3 years ahead of the State’s, building owners can use the tune-up to get started with State O+M requirements.

    Seattle’s O&M tasks cover specific assessment elements that are detailed in the BTU workbook and this Owner’s Guide . While the building’s Tune-Up Specialist must complete the assessment and identify corrective actions, in-house staff, maintenance consultants, and Tune-Up Specialist may implement the required corrective actions. Corrections, however, must be verified by the Tune-Up Specialist before submitting to the City of Seattle for review.

    The Seattle BTU report must be completed and submitted to the City every five years, via the online Seattle Services Portal by the Tune-Up Specialist. Failure to complete and report is subject to penalties. Annually reviewing tune-up tasks and making corrections is encouraged but not required.

Video shared with permission from the Resource Conservation Management Support Program at Washington State University Energy Program.

View Washington State University’s Clean Buildings requirements webinar series episode featuring “Operations & Maintenance for Clean Buildings”:

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