Oregon BPS for Multifamily Buildings: What Apartment Owners Need to Know

Multifamily buildings—apartment complexes, condominiums, and other residential properties with multiple units—make up a substantial portion of Oregon buildings subject to the Building Performance Standard. However, multifamily properties face unique challenges in BPS compliance that differ from office buildings, retail centers, and industrial facilities. Property owners and managers of multifamily buildings need to understand these specific considerations to plan effective compliance strategies.

Multifamily Buildings Under Oregon’s BPS

Any multifamily building of 35,000 square feet or larger is subject to Oregon’s Building Performance Standard. This includes:

• Large apartment complexes with 100+ units
• Mid-size residential buildings of 50,000-75,000 square feet
• Condominium buildings with centralized heating, cooling, or utilities
• Affordable housing properties and government-assisted multifamily buildings
• Mixed-use buildings that include substantial residential components

The energy performance requirements for multifamily buildings are based on ASHRAE Standard 100 with Oregon amendments, the same standard applied to other building types. However, the practical realities of auditing multifamily buildings and implementing improvements differ significantly from other building types.

Special Challenges of Multifamily BPS Compliance

Tenant Privacy and Access Unlike office buildings where an auditor can access every space, multifamily buildings include private residential units. Accessing individual apartment interiors requires tenant permission and coordination. Some tenants may be unwilling to grant access, limiting the auditor’s ability to fully assess interior conditions, unit-level HVAC settings, or appliance efficiency.

This creates a practical challenge: auditors must make reasonable estimates of interior conditions based on common unit inspections and general building characteristics rather than fully inspecting every unit. Qualified energy auditors experienced with multifamily buildings understand this limitation and structure audits accordingly, but it’s important for property owners to recognize that multifamily audits may be somewhat less detailed than office building audits.

Mixed Occupancy and Operational Variability Residential buildings have more variable occupancy and operational patterns than office buildings. Some units are occupied 24/7 year-round; others are vacant, occasionally occupied, or seasonally used. This variability affects energy consumption patterns and makes baseline energy consumption harder to predict. Auditors must account for this variability when estimating energy savings from improvements.

Tenant Relationships and Communication Any improvements affecting tenant comfort or building operations require communication with and often cooperation from tenants. HVAC adjustments, thermostat replacements, or hot water temperature modifications affect tenants directly. Property managers must be prepared to explain improvements, address tenant concerns, and manage expectations around changes in heating/cooling availability or hot water temperature.

Utility Billing and Consumption Data Multifamily buildings vary in how utilities are metered and billed:

Master-metered buildings (building owner pays all utility costs) provide clear consumption data for auditing and benchmarking. These buildings have straightforward energy management and can easily track whether improvements are achieving expected savings.

Tenant-submetered buildings (each unit has separate meters and pays its own utilities) create data fragmentation. Benchmarking must account for buildings where the owner doesn’t control all utility costs. Improvements focused on common areas (corridors, common spaces, exterior lighting) may not show up clearly in the overall building consumption data.

Mixed-billing buildings (some utilities master-metered, others tenant-metered) create additional complexity in data collection and analysis.

When pursuing Energy Trust incentives, the specific metering and billing approach matters. Buildings with clear, complete consumption data are easier to process for incentives and demonstrate energy savings.

Typical Energy Improvements in Multifamily Buildings

The energy efficiency improvements most commonly recommended in multifamily building audits include:

Common Area Lighting Upgrading corridors, common areas, stairwells, and exterior lighting to LED with occupancy sensors typically offers excellent savings with relatively straightforward implementation. These upgrades don’t require tenant access and show clear energy reductions.

HVAC Controls and Optimization For centralized HVAC systems, improved building controls, better maintenance protocols, and optimization of heating/cooling schedules can reduce consumption without affecting tenant comfort. Boiler and chiller upgrades, where systems are aging and inefficient, can offer substantial savings but require capital investment.

Water Heating Systems Hot water production is a major energy expense in multifamily buildings. Insulation of hot water pipes, point-of-use water heating in remote areas, fixture upgrades, or hot water system replacement can significantly reduce consumption.

Building Envelope Window replacement, insulation improvements, air sealing, and weatherstripping reduce heating and cooling loads. These improvements benefit the entire building and don’t require tenant cooperation for implementation.

Occupancy-Based Systems Occupancy sensors for lighting, demand-controlled ventilation, and automated building controls can reduce waste while maintaining comfort.

Tenant Communication and Buy-In

Successful multifamily BPS compliance requires effective tenant communication. Property managers should:

Explain the BPS and Why It Matters Many tenants will be unfamiliar with the BPS. Providing simple, clear explanation of what it is, why buildings must comply, and what improvements might be planned helps reduce tenant concerns or resistance.

Be Transparent About Changes If planned improvements affect tenant comfort, thermostat settings, or building operations, explain this in advance. Surprises create frustration; transparency builds understanding.

Address Tenant Concerns Tenants may worry that energy efficiency improvements mean reduced comfort (colder winters, warmer summers). Explain that efficient building operation maintains comfort while reducing waste. Address specific concerns directly.

Highlight Potential Rent Impacts In many cases, building energy improvements can be recovered through modest rent increases over time. Transparent communication about this dynamic helps tenants understand the value and long-term benefit of improvements.

Implementation Challenges Unique to Multifamily

Coordinating Construction with Occupancy Common area improvements or envelope work must be coordinated around occupied units. Noise, disruption, and access issues require careful planning. Projects that might take two weeks in an unoccupied office building could take twice as long in a multifamily property due to occupancy constraints.

Tenant Turnover High-turnover multifamily properties may face challenges maintaining operational improvements. If efficiency depends on tenant behavior (thermostat settings, proper use of controls), turnover means constantly re-training new residents.

Capital Availability Multifamily properties often operate on tighter profit margins than commercial properties. Capital for efficiency improvements may be more constrained. This makes Energy Trust incentives particularly valuable for multifamily owners.

Financing Improvement Costs Some multifamily owners pursue Property Assessed Clean Energy (PACE) financing or other innovative financing mechanisms to fund improvements without requiring large upfront capital. Understanding available financing options is important for multifamily owners.

Benchmarking Considerations for Multifamily

Multifamily buildings use a specific benchmarking methodology. Energy consumption is typically normalized by heated/cooled square footage and adjusted for weather and occupancy patterns. The benchmarking process accounts for the fact that residential buildings operate differently than offices.

If your multifamily building is tenant-metered, accurate benchmarking becomes more complex because you don’t have complete consumption data. Working with an experienced energy auditor or benchmarking specialist who understands multifamily-specific methodologies is important for accurate benchmarking.

Affordable Housing and Public Housing Considerations

Multifamily properties that are affordable housing, public housing, or government-assisted properties face the same BPS requirements as market-rate multifamily buildings. However, additional funding sources may be available:

• HUD grants and programs may support energy efficiency in public housing
• Some state programs provide additional incentives for affordable housing efficiency
• Nonprofit and mission-driven organizations may access funding unavailable to market-rate properties

Early compliance action may unlock funding opportunities for affordable housing properties to improve both energy performance and building quality simultaneously.

Timeline and Planning for Multifamily Compliance

The compliance timeline for multifamily buildings is the same as for other building types, but the practical implementation timeline may be longer due to occupancy constraints:

2025-2026: Conduct benchmarking and ASHRAE Level 2 audit; develop improvement plan 2026-2027: Implement improvements and achieve compliance (for early movers) By 2028: Tier 1 deadline; compliance must be achieved By 2030: Tier 2 deadline

For multifamily buildings, starting planning in 2025 is especially important. The longer practical timelines for implementation mean that early starters will actually complete improvements on time, while late starters may face squeeze as deadlines approach.

Working with Multifamily-Experienced Professionals

Not all energy auditors have extensive multifamily building experience. When selecting an auditor, prioritize those with specific multifamily background who understand:

• Tenant communication and access coordination
• Multifamily-specific benchmarking approaches
• Practical implementation challenges in occupied residential buildings
• Financing options specific to multifamily properties

Similarly, when implementing improvements, contractors experienced with multifamily work understand how to minimize disruption and work around occupied units.

Get Expert Guidance for Multifamily Compliance

Multifamily building compliance presents distinct challenges and opportunities. The good news is that many multifamily buildings can achieve compliance through relatively straightforward improvements focused on common areas and building systems.

Oregon Building Compliance has extensive experience helping multifamily property owners and managers understand their BPS obligations, plan effective compliance strategies, and navigate the unique challenges of residential building compliance.

If you own or manage a multifamily building 35,000 square feet or larger, contact Oregon Building Compliance today to discuss your building’s specific compliance requirements, timeline, and what improvements might be most cost-effective for your property.