ASHRAE Level 1 vs Level 2 vs Level 3: What Oregon BPS Requires

If you’ve been quoted on a “Level 1 walkthrough audit” by your local utility and you think you’ve satisfied Oregon’s Building Performance Standard, you haven’t. Oregon BPS requires an ASHRAE Level 2 energy audit specifically — not Level 1, not a Level 3, not a hybrid. That distinction sounds like a technicality. It’s not. It’s the difference between filing a compliant Form Q and being out of compliance under ORS 330-300.

This post explains what each ASHRAE audit level actually involves, why Oregon picked Level 2 as the BPS standard, and how to know whether the audit you’ve already had performed meets the requirement.

Primary keyword: ASHRAE Level 2 Oregon BPS Secondary keywords: ASHRAE Level 1 vs Level 2, energy audit levels Oregon, ASHRAE Standard 100, Oregon BPS audit requirements

The Short Answer

Oregon BPS requires an ASHRAE Level 2 energy audit conducted in accordance with ASHRAE Standard 100 with Oregon amendments. A Level 1 walkthrough is not sufficient. A Level 3 investment-grade audit exceeds the requirement and is more expensive than necessary for most buildings. Level 2 is the right tool, and ODOE has been clear about it.

What Each Level Actually Involves

ASHRAE — the American Society of Heating, Refrigerating and Air-Conditioning Engineers — defines three standardized energy audit levels in its Procedures for Commercial Building Energy Audits. Each level builds on the prior one.

ASHRAE Level 1: The Walkthrough

A Level 1 audit is a high-level visual assessment of the building plus a review of utility billing data. The auditor walks through the building, identifies obvious efficiency opportunities, and documents low-cost / no-cost measures alongside potential capital projects worth further study. There’s no detailed measurement, no energy modeling, and no life-cycle cost analysis. The deliverable is a brief report with general recommendations.

A Level 1 audit is useful for screening — figuring out whether a building is worth a deeper analysis. It’s not useful for compliance with a building performance standard that requires documented energy conservation measures and life-cycle cost analysis.

ASHRAE Level 2: The Energy Survey and Analysis

A Level 2 audit is the structured engineering analysis Oregon BPS requires. It includes:

• Detailed analysis of the building’s energy use patterns, broken down by end use
• A more thorough on-site survey of building systems including envelope, HVAC, lighting, controls, plug loads, and domestic hot water
• Measurement of key building system performance where data isn’t available from existing controls
• Energy modeling calibrated to actual consumption
• Identification of all practical energy conservation measures
• A life-cycle cost assessment on each recommended measure
• A formal report documenting findings, recommendations, and economic analysis

The Level 2 audit is the level at which an auditor produces actionable, financially-modeled recommendations. It’s also the level at which the analysis is rigorous enough to satisfy a state compliance mandate.

ASHRAE Level 3: The Detailed Analysis

A Level 3 audit goes beyond Level 2 with detailed engineering analysis of capital-intensive modifications, often involving subsystem-level performance monitoring, more sophisticated energy modeling, and investment-grade financial analysis. It’s typically used when a building owner is making a major capital decision and needs a high degree of certainty on projected savings. Level 3 audits are significantly more expensive than Level 2 and exceed what Oregon BPS requires.

Side-by-Side Comparison

Feature	Level 1	Level 2	Level 3
Visual walkthrough	Yes	Yes	Yes
Utility bill analysis	Basic	Detailed	Detailed
End-use breakdown	No	Yes	Yes
On-site measurement	Minimal	Yes	Extensive
Energy modeling	No	Yes	Yes (advanced)
Life-cycle cost analysis	No	Yes (required)	Yes (investment grade)
Subsystem monitoring	No	Limited	Yes
Typical cost (Oregon)	Often free or low cost	$7,500-$20,000+ flat	$20,000-$50,000+
Oregon BPS compliant	No	Yes	Yes (overkill)
Best use case	Screening	State compliance	Major capital decisions

Why Oregon Picked Level 2

The Oregon Department of Energy chose ASHRAE Level 2 as the BPS standard because it strikes a defensible balance between rigor and cost. Level 1 is too superficial to drive real energy reductions. Level 3 is more expensive than most building owners can justify for compliance purposes. Level 2 produces the engineering quality needed for ODOE to evaluate building performance and produce defensible compliance decisions, without imposing investment-grade costs on every covered building owner.

It’s also the level that’s compatible with most utility incentive programs and federal tax incentive structures, which keeps the broader economics workable for building owners.

The Trap We See on First Calls

Here’s how this trips owners up: a building manager gets a “free energy audit” from PGE, Pacific Power, or EWEB through a utility commercial efficiency program. The audit identifies some lighting and controls upgrades. The manager files a copy in the facilities folder and assumes the BPS box is checked. Then 2027 rolls around, the deadline starts feeling close, and they discover the utility audit was a Level 1 walkthrough — useful, but not Form Q compliant.

The fix isn’t disastrous. The Level 1 work isn’t wasted (it’s a useful baseline). But the Level 2 audit still has to happen, and now it’s happening on a compressed schedule rather than the full 2026 timeline that would have been ideal.

If you’ve had a recent utility audit, the question to ask is: did it include energy modeling, end-use breakdown, life-cycle cost analysis on each measure, and a deliverable that meets ASHRAE Standard 100 documentation requirements? If the answer is no, it was a Level 1.

How to Verify You’re Getting a Level 2

A few questions to ask any auditor before you sign:

• “Will the report include a calibrated energy model of the building?”
• “Will every recommended energy conservation measure include a life-cycle cost assessment?”
• “Will the report be structured to satisfy ASHRAE Standard 100 with Oregon amendments?”
• “Will you produce a Form Q compliance package for ODOE submission?”
• “What are your auditor’s QEA credentials? (ASHRAE BEAP, AEE CEA / CEM, etc.)”

If any of those answers is unclear, you’re not getting a compliant Level 2. Walk away.

A Real Comparison

A Salem property owner came to us with a Level 1 utility audit from 2024 that had identified four potential measures: an LED lighting retrofit, RTU economizer repair, controls calibration, and weatherstripping replacement. Total estimated savings on the Level 1: roughly $14,000/year.

Our Level 2 audit on the same building identified all four of those measures plus a chiller plant rebalancing, a domestic hot water recirculation pump upgrade, and a building automation system reprogramming sequence. With life-cycle cost analysis, three of the original four measures had different (in some cases very different) ROI calculations than the Level 1 had estimated. Total identified savings: roughly $34,000/year, with measures sequenced to capture the largest savings first.

The Level 1 wasn’t wrong. It just wasn’t deep enough to find the highest-value opportunities, and it didn’t produce a deliverable Oregon BPS would accept.

What This Means for Your 2026 Planning

If your Oregon commercial building is 35,000 square feet or larger and covered under BPS, the audit you need is a Level 2, not a Level 1, and not a Level 3. Anyone telling you a walkthrough audit is sufficient is either confused about Oregon’s specific requirements or selling you something else.

For a city-specific look at how this plays out, see Portland BPS compliance or our guide to the 2026 BPS action checklist. For more on what an audit actually looks like in practice, read what happens during an ASHRAE Level 2 site visit.

If you want a flat quote for a Level 2 audit on your specific building, email Mike at vanvicklebros@gmail.com with the address, square footage, and primary use.