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 330.135, facing $1,000/day penalties up to $25,000/year.

The cost differential between audit levels matters too. But the real issue is compliance. Oregon Department of Energy has been crystal clear in guidance documents and enforcement conversations: buildings subject to ORS 330.135 require documented ASHRAE Standard 211-2018 analysis with life-cycle cost assessment on every recommended measure. That’s Level 2. Not Level 1. Not Level 3. This post explains what each ASHRAE audit level actually involves, why Oregon picked Level 2 as the BPS standard, and how to verify that the audit you’ve already had performed—or are planning to commission—meets the requirement.

The Short Answer

Oregon BPS requires an ASHRAE Level 2 energy audit conducted in accordance with ASHRAE Standard 211-2018 with Oregon amendments as specified in ORS 330.135. A Level 1 walkthrough is not sufficient. A Level 3 investment-grade audit exceeds the requirement and is more expensive than necessary for compliance purposes. Level 2 is the legally required tool, and ODOE has been explicit about it in every compliance guidance document issued since the BPS became effective.

Buildings meeting the size threshold (35,000 gross square feet or larger) must submit Form Q documenting completion of a compliant ASHRAE Level 2 audit by their deadline—2028 for Tier 1 buildings, 2030 for Tier 2 buildings. Submitting a Level 1 walkthrough or a utility “free audit” will be rejected. Getting this wrong costs time and money. Getting it right the first time saves both.

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 (ASHRAE Standard 211-2018). Each level builds on the prior one, and each serves a different purpose in building energy management. Understanding the differences is essential for compliance planning.

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—often 10-20 pages—that provides screening-level insights.

A Level 1 audit is useful for screening — figuring out whether a building is worth a deeper analysis. It’s commonly offered free or at low cost ($1,000-$3,000) by utilities like PGE, Pacific Power, and EWEB as a first step in their commercial efficiency programs. The analysis is typically completed in a few days to a week. However, Level 1 audits are not useful for compliance with a building performance standard that requires documented energy conservation measures with specific energy modeling and detailed life-cycle cost analysis.

The practical problem: a building manager gets a “free energy audit” from PGE, files the report, and assumes the BPS box is checked. Two years later, when compliance deadlines loom, they discover the utility audit was a Level 1 walkthrough—useful as a baseline, but not Form Q compliant.

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 (HVAC, lighting, plug loads, hot water, etc.)
• A comprehensive 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 using 12-24 months of utility data
• Identification of all practical energy conservation measures
• A life-cycle cost assessment on each recommended measure (equipment cost, maintenance, utility rates, equipment lifespan, financing scenarios)
• A formal written report documenting findings, recommendations, economic analysis, and compliance status

The Level 2 audit typically requires 2-5 days of on-site work (depending on building size and complexity) and 3-4 weeks of post-visit analysis and modeling. A typical ASHRAE Level 2 audit in Oregon costs $8,000-$18,000 depending on building size and complexity, or roughly $0.10-$0.18 per square foot.

This 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 state compliance mandates. Oregon specifically requires Level 2 analysis to generate the data needed for Form Q submission and ODOE review.

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 (sometimes with calibrated simulation by season or month), and investment-grade financial analysis. Level 3 audits may include:

• Detailed subsystem performance testing and monitoring
• Advanced energy modeling with hourly or sub-hourly simulation
• Detailed engineering analysis of specific major improvements
• Investment-grade financial analysis with sensitivity analysis
• Equipment manufacturer consultation and performance verification

It’s typically used when a building owner is making a major capital decision (e.g., a $500,000+ chiller replacement or major envelope retrofit) and needs a high degree of certainty on projected savings. Level 3 audits are significantly more expensive than Level 2 (typically $20,000-$50,000+ for most Oregon commercial buildings) and exceed what Oregon BPS requires for compliance.

The overhead cost and extended timeline of Level 3 audits makes them impractical for buildings simply trying to achieve BPS compliance on schedule. Level 3 analysis is appropriate for very large buildings pursuing major capital improvements, or buildings with highly specialized systems requiring deep technical analysis.

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 (calibrated)	Yes (advanced)
Life-cycle cost analysis	No	Yes (required)	Yes (investment grade)
Subsystem monitoring	No	Limited	Yes
Building Automation System (BAS) trend data	No	Yes	Yes
Typical cost in Oregon	Free-$3,000	$8,000-$18,000	$20,000-$50,000+
Timeline	5-10 days	4-6 weeks	8-12 weeks
Oregon BPS compliant	No	Yes	Yes (exceeds requirement)
Form Q acceptable	No	Yes	Yes
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 for documented, specific reasons outlined in their 2023 BPS Compliance Guidance Document and rulemaking record. Level 1 is too superficial to drive real energy reductions—it’s a screening tool, not a compliance mechanism. Level 3 is more expensive than most building owners can justify for compliance purposes alone, and it’s unnecessary for buildings simply trying to meet the standard.

Level 2 produces the engineering quality needed for ODOE to evaluate building performance against the established benchmarks, identify buildings requiring improvement, and produce defensible compliance decisions—without imposing investment-grade costs on every covered building owner. It’s the sweet spot: rigorous enough to satisfy a state mandate, practical enough to be achievable across a diverse portfolio of Oregon commercial buildings.

Oregon’s BPS regulation also recognizes that Level 2 analysis is compatible with most utility incentive programs and federal tax incentive structures, including Section 179D deductions and IRA-related incentives. This alignment keeps the broader compliance economics workable for building owners and aligns state compliance with federal incentive policy.

Real-World Example: What Level 1 Misses

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 (estimated $45,000 investment, $8,000/year savings), RTU economizer repair ($5,000 investment, $3,500/year savings), controls calibration ($8,000 investment, $2,000/year savings), and weatherstripping replacement ($12,000 investment, $1,500/year savings).

Total Level 1 estimated savings: roughly $14,000/year; total improvement investment: $70,000.

Our Level 2 audit on the same building identified all four of those measures plus:

• A chiller plant rebalancing ($15,000 investment, $6,000/year savings)
• A domestic hot water recirculation pump upgrade ($18,000 investment, $4,500/year savings)
• A building automation system reprogramming sequence ($22,000 investment, $7,000/year savings)

With life-cycle cost analysis and 20-year equipment lifespan assumptions, three of the original four measures had significantly different ROI calculations than the Level 1 had estimated. The LED retrofit, for example, showed a 6-year payback in the Level 1 but a 3.8-year payback in the Level 2 when utility rate changes and maintenance savings were properly modeled.

Total identified savings from Level 2: roughly $32,000/year; total improvement investment: $120,000. 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 that satisfied Oregon BPS Form Q requirements. The building owner would have spent $70,000 on improvements and captured less than half the energy savings that were actually available.

The Compliance Trap We See

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 as a baseline, but not Form Q compliant under ORS 330.135.

The fix isn’t disastrous. The Level 1 work isn’t wasted (it’s a useful baseline to build from). But the Level 2 audit still has to happen, and now it’s happening on a compressed schedule rather than the full 2026-2027 timeline that would have been ideal. Compressed schedules mean:

• Higher auditor rates (rush fees apply)
• Difficulty finding available auditors (peak-season booking)
• Less time to plan improvement implementation
• Risk of missing the deadline if audit or improvements take longer than expected

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 211-2018 documentation requirements? If the answer is no, it was a Level 1.

How to Verify You’re Getting a Level 2

A few specific questions to ask any auditor before you sign an engagement:

• “Will the report include a calibrated energy model of the building that matches actual consumption within a specified tolerance (typically within 5-10%)?”
• “Will every recommended energy conservation measure include a life-cycle cost assessment with payback period, net present value, and return on investment?”
• “Will the report be structured to satisfy ASHRAE Standard 211-2018 with Oregon amendments per ORS 330.135?”
• “Will you produce a Form Q compliance package for ODOE submission, with documentation that you meet QEA (Qualified Energy Auditor) requirements?”
• “What are your auditor’s specific credentials? (ASHRAE BEAP, AEE CEA / CEM, or PE with energy focus)?”
• “Will the report include an on-site survey of building envelope, HVAC systems, lighting, controls, hot water, and plug loads?”
• “How many days of on-site work does the audit include?”
• “What utility data do you require, and how far back?”

If any of those answers is vague or incomplete, you’re not getting a compliant Level 2. Walk away and find an auditor who can clearly articulate what they’ll deliver.

What This Means for Your 2026-2027 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 something less than what compliance requires.

Tier 1 buildings (deadline 2028) should schedule audits in 2026 or early 2027 to leave room for improvement implementation. Tier 2 buildings (deadline 2030) have more flexibility, but early action still provides advantages—better auditor availability, stronger Energy Trust incentive funding, and more time for improvements.

The compliance math is straightforward: you need an ASHRAE Level 2 audit, conducted by a Qualified Energy Auditor, documented on Form Q, and submitted to ODOE. Oregon regulations are specific. The audit must meet ASHRAE Standard 211-2018. There’s no shortcut, no substitute, and no acceptable alternative.

About the Author

Mike VanVickle is a commercial building energy compliance specialist based in Oregon. He has guided dozens of property owners through Oregon’s Building Performance Standards process, from initial audit scoping through ASHRAE Level 2 completion and ODOE submission. He holds expertise in ORS 330-300 compliance timelines and has worked with Energy Trust of Oregon incentive programs to reduce compliance costs for building owners.

Sources & References

• Oregon Department of Energy — Building Performance Standards
• ORS 330.135 — Oregon Building Performance Standards Requirements
• ASHRAE Standard 211-2018 — Standard for Commercial Building Energy Audits
• Energy Trust of Oregon — Commercial Energy Incentives
• ODOE BPS Compliance Guidance Document (2023)
• ASHRAE Procedures for Commercial Building Energy Audits