Form Q Submission Guide for Oregon BPS: Step-by-Step Compliance Filing

Oregon’s Building Performance Standard requires every covered building to submit Form Q—the official compliance documentation—to the Oregon Department of Energy by its assigned deadline. Form Q isn’t just a checkbox. It’s the legal record that your building has completed an ASHRAE Level 2 audit, identified energy conservation measures, and either implemented them or documented why you haven’t. Getting Form Q right is the difference between compliance and non-compliance. Getting it wrong triggers penalties up to $1,000 per day, up to $25,000 per year.

This guide walks through the entire Form Q process: what it is, who submits it, what documents you need, exactly how to file it, common mistakes that get submissions rejected, how to verify approval, and what happens after your building is marked compliant.

What Is Form Q?

Form Q is the Oregon Department of Energy’s official verification form that a covered building has satisfied its Building Performance Standard obligation. It’s not a test. It’s not a rating. It’s a declaration and supporting evidence that your building has either:

1. Completed an ASHRAE Level 2 audit, identified energy conservation measures (ECMs), and implemented them to achieve the required energy savings, OR
2. Completed an ASHRAE Level 2 audit, identified ECMs, and documented a variance request explanation if you cannot implement the savings

Form Q submission is mandatory. It’s not optional, not voluntary, and not something you can skip. Oregon Department of Energy tracks submissions, cross-references property tax records and municipal building permits against the Form Q database, and issues notices of non-compliance to buildings that haven’t filed by their deadline.

The form itself is short—typically one to three pages depending on whether you’re claiming direct compliance or requesting a variance. But the documentation backing it up is substantial: a complete ASHRAE Level 2 audit report, proof of implementation (invoices, signed contracts, completion certificates), or a formal variance justification with engineering reasoning.

Who Files Form Q?

Your building owner or authorized representative files Form Q. That’s usually the building owner, property manager, commercial real estate firm managing the asset, or an energy consultant hired specifically to handle compliance. In many cases, property managers and energy firms work together: the energy consultant conducts the ASHRAE Level 2 audit, identifies recommended measures, coordinates implementation, and then the property manager or owner completes and submits Form Q to ODOE.

If you own a building subject to ORS 330.135 and your deadline has arrived or is approaching, and Form Q has not been filed, ODOE considers your building out of compliance. Penalties accrue from the deadline forward.

You don’t need a license to submit Form Q. You don’t need to be a professional engineer. You don’t need to hire ODOE-certified anything. You just need the audit documentation, evidence of implementation (or a variance justification), and the completed form submitted to ODOE through their online portal.

Building Coverage and Deadlines

Not every building in Oregon has to file Form Q. Only buildings that meet the size threshold and ownership criteria must comply:

• 35,000 gross square feet or larger
• Located in Oregon
• Subject to municipal building performance standards (ORS 330.135)

As of 2026, most major Oregon cities have adopted ORS 330.135 ordinances, including Portland, Eugene, Salem, Beaverton, Corvallis, Springfield, Bend, Medford, Gresham, and Hillsboro. A few smaller cities are still working through local adoption, but coverage is nearly statewide for buildings meeting the size threshold.

Tier 1 buildings (250,000+ square feet or served by the Public University System) had their Form Q deadline in 2028. Many Tier 1 buildings have already filed or are in their final compliance window.

Tier 2 buildings (35,000-249,999 square feet) have their Form Q deadline in 2030.

Your deadline is based on your building’s size, not when you commission an audit. If your building is 50,000 square feet and falls into Tier 2, your deadline is 2030 regardless of when you order the ASHRAE Level 2 audit. However, starting the audit process early (ideally 18-24 months before your deadline) is strongly recommended. Audits take time. Implementation takes time. Delays in either push you toward your deadline without a filed Form Q, triggering penalties.

Documentation You Need Before Filing Form Q

Before you open the Form Q portal and submit anything, you need to gather the supporting documentation. ODOE won’t accept a Form Q submission without complete backing evidence. Here’s what you must have:

1. Completed ASHRAE Level 2 Audit Report

This is non-negotiable. The audit must be:

• Conducted in accordance with ASHRAE Standard 211-2018 with Oregon amendments as specified in ORS 330.135
• Performed by a qualified energy auditor (professional engineer, energy auditor with recognized certification like BEAP or CEM, or engineering firm with demonstrated building energy experience)
• Dated on or before your submission date (the audit can’t be from the future, obviously, but it also can’t be older than 5 years at the time of Form Q filing)
• Calibrated to your building’s actual energy consumption using 12-24 months of utility billing data
• Including identified energy conservation measures with life-cycle cost analysis and payback calculations
• Including the auditor’s professional signature and seal if the auditor is a PE

The audit report itself is typically 30-60 pages for buildings under 100,000 square feet, and 60-150+ pages for larger buildings. It includes:

• Building systems summary
• Energy modeling results
• Breakdown of energy consumption by end use
• Identified conservation measures ranked by cost-effectiveness
• Implementation costs and estimated savings for each measure
• Payback periods and 25-year lifecycle costs
• Energy performance baseline
• Building envelope analysis
• HVAC system analysis
• Lighting system analysis
• Plug load and occupant behavior analysis
• Recommendations for optimization

You cannot submit Form Q with a utility “free audit” or an ASHRAE Level 1 walkthrough. Those don’t contain the required detail and will be rejected by ODOE.

2. Evidence of Implementation (If Claiming Compliance Through Measures)

If your building has already implemented energy conservation measures to achieve the required savings, you need documentation of that work:

• Signed contracts for the work (showing scope of work, pricing, timeline)
• Completion certificates or contractor sign-off confirming work is finished
• Invoices or payment records (redacted for sensitive pricing if needed, but showing work performed)
• Equipment specifications (if equipment was replaced—HVAC, lighting, controls, etc.)
• Commissioning reports (if the measures included system commissioning or controls optimization)
• Before-and-after utility data (optional but helpful: utility bills comparing pre-implementation and post-implementation periods to show actual savings)

ODOE doesn’t require you to have achieved the exact energy savings projected in the audit. But you do need to show that you implemented the recommended measures in good faith and followed the audit’s recommendations. If the audit recommended “replace lighting with LED and upgrade HVAC controls,” you show contracts and completion certificates for the LED replacement and control system upgrade.

If only partial implementation has occurred (e.g., you’ve completed the LED lighting retrofit but not the HVAC work), you can still file Form Q, but you’ll need a variance justification (see below) explaining why the remaining measures haven’t been completed.

3. Variance Request Justification (If Not Fully Implementing)

If your building has not fully implemented the energy conservation measures recommended in the ASHRAE Level 2 audit, you must submit a variance request explaining why. ODOE will review the variance request and either approve it (marking your building compliant despite incomplete implementation) or deny it (requiring you to continue working toward implementation).

A variance request must include:

• Detailed explanation of why the recommended measures have not been implemented
• Engineering or operational justification (e.g., “The HVAC replacement would require a two-week building shutdown, which is operationally infeasible for this hospital. The audit recommended phased implementation, which we’re pursuing. Phase 1 begins Q3 2026.”)
• Timeline for future implementation (if applicable—showing when you plan to complete remaining measures)
• Economic hardship documentation (if cost is the primary barrier—financial statements, capital budget constraints, etc.)
• Technical infeasibility explanation (if the building’s existing systems make certain measures impractical or impossible)

A weak variance request (“We ran out of time” or “We’re still thinking about it”) will be denied. A strong variance request (“The audit identified $800,000 in HVAC replacement measures on a building with a $400,000 annual operating budget; we’ve prioritized the lowest-cost recommendations and are implementing them on a 5-year cycle beginning 2026, starting with lighting and controls”) will likely be approved.

ODOE has discretion to approve, deny, or approve-with-conditions on variance requests. Buildings with a solid plan and good faith efforts typically get approval.

How to Access and Fill Out Form Q

Oregon Department of Energy manages Form Q submissions through an online portal accessed via the ODOE website:

https://energyreporting.oregon.gov

Here’s the step-by-step filing process:

Step 1: Create or Log Into Your ODOE Account

If you don’t already have an ODOE energy reporting account, you’ll need to create one. You’ll provide:

• Building owner or authorized representative name
• Email address (this becomes your login)
• Phone number
• Building address
• Building identification (either the tax lot number, city parcel ID, or both)

If you already have an account from prior ODOE submissions or Energy Trust of Oregon work, use your existing credentials.

Step 2: Locate Your Building in the ODOE Database

Once logged in, search for your building using:

• Property address
• Tax lot number
• City parcel ID

ODOE has pre-loaded the database with all buildings known to meet the size threshold. If your building doesn’t appear, contact ODOE (see contact information at the end of this guide) before filing Form Q. There may be a database discrepancy or a missing address match.

Once you locate your building, you’ll see:

• Your assigned Tier (1 or 2)
• Your Form Q deadline
• Your current compliance status (typically “not yet filed” for buildings approaching their deadline)

Step 3: Initiate Form Q Submission

Select “Submit Form Q” or similar button on your building’s compliance record. The portal will prompt you to:

• Confirm your building information (address, square footage, building type)
• State whether you’re claiming direct compliance (measures implemented) or requesting a variance
• Upload supporting documentation
• Provide contact information for follow-up (email, phone for ODOE to reach you during review)

Step 4: Upload Audit Report and Supporting Documents

Attach:

1. ASHRAE Level 2 Audit Report (PDF, required)
2. Implementation evidence (contracts, completion certificates, invoices) OR variance request letter (PDF or Word doc, required if not fully implementing)
3. Building energy modeling file (optional but recommended—the actual energy model or simulation file used in the audit, in .idf, .xlse, or format matching the auditing software)

File size limits are typically 10-25 MB per file; ODOE will specify limits in the portal. Keep file names clear and simple (e.g., “123-Main-St-ASHRAE-Level2-Audit-2026.pdf” rather than “building_audit_final_v3_REAL_final.pdf”).

Step 5: Review and Certify

Before submitting, you’ll be asked to certify that:

• The information is accurate and complete to your knowledge
• The ASHRAE Level 2 audit was conducted in accordance with ASHRAE Standard 211-2018
• Any claimed implementations have been completed as described
• Any variance request is truthful and supported by the evidence provided

You’ll sign electronically (usually by typing your name or using a digital signature if required by your organization). This is a legal declaration; falsifying information can trigger additional penalties.

Step 6: Submit

Click “Submit Form Q” to send your package to ODOE. You’ll receive an email confirmation with:

• A submission date/timestamp
• A reference number for tracking
• An expected review timeline (typically 4-8 weeks)

Keep this email and reference number. You’ll use it to check status and respond to any questions from ODOE reviewers.

Common Form Q Submission Mistakes (and How to Avoid Them)

ODOE receives hundreds of Form Q submissions each compliance cycle. Reviewers have seen every mistake in the book. Here are the most common ones and how to avoid them:

Mistake 1: Submitting a Level 1 Walkthrough Instead of a Level 2 Audit

The error: Building owner gets a “free energy audit” from PGE or another utility, assumes it’s sufficient for compliance, and submits it with Form Q.

Why it gets rejected: Form Q explicitly requires an ASHRAE Level 2 audit. A Level 1 walkthrough doesn’t include the required energy modeling, detailed system analysis, or life-cycle cost assessment. ODOE reviewers will immediately identify it and reject the submission.

How to avoid it: Confirm with your auditor in writing that they’re conducting an ASHRAE Level 2 audit per Standard 211-2018 before they start. The quote and contract should explicitly state “ASHRAE Level 2.” If you’ve already received a Level 1 audit and your deadline is approaching, you need to commission a proper Level 2 audit immediately.

Mistake 2: Using an Audit Older Than 5 Years

The error: A building owner commissioned an ASHRAE Level 2 audit in 2021, didn’t implement anything, and tries to file Form Q in 2026 using the old 2021 audit.

Why it gets rejected: ODOE doesn’t accept audits older than 5 years at the time of submission (the regulation allows some discretion here, but the general rule is 5 years maximum). Building systems change, utility rates change, and building occupancy/operation can change substantially. An audit that’s 5+ years old doesn’t represent the current building condition.

How to avoid it: Know your Form Q deadline and work backward. If your deadline is 2028 and it’s 2026, commission the audit in 2027 so it’s fresh at submission time. If you already have an older audit and your deadline is within the next 12 months, update it: hire the same auditor to refresh the energy model with current utility data and add any systems that have changed since the original audit. An update is cheaper than a full new audit.

Mistake 3: Incomplete Implementation Documentation

The error: A building owner claims to have implemented LED lighting and HVAC controls (as recommended in the audit) but can only produce a contract for the lighting work. The controls work is incomplete or there’s no documentation.

Why it gets rejected: ODOE can’t approve “partial implementation” without a variance request explaining the gap. If you’re claiming measures are done, you need evidence that they’re done. ODOE will ask for completion certificates for the controls work or deny the submission pending variance documentation.

How to avoid it: Before filing Form Q, gather all completion certificates, invoices, and contractor sign-offs for every measure you’re claiming. If a measure is incomplete or delayed, include a variance request letter explaining the timeline and why. Don’t try to hide incomplete work; ODOE will find it or request it, and you’ll end up filing again anyway with added delay.

Mistake 4: No Variance Request When Claiming Non-Implementation

The error: An owner files Form Q saying “We implemented lighting only” but provides no variance justification for why the other measures (HVAC, building envelope, controls) haven’t been done.

Why it gets rejected: If you haven’t fully implemented the audit’s recommendations, you must provide a variance request. Without it, ODOE will treat partial implementation as non-compliance and reject the Form Q submission.

How to avoid it: If your building isn’t fully implementing the audit recommendations, always attach a variance request letter. Keep it factual and professional. Explain the barriers (cost, operational constraints, phased implementation timeline, technical infeasibility) and provide a realistic path forward.

Mistake 5: Wrong Building Identification

The error: The Form Q is submitted with a property address that differs slightly from what ODOE has in their database (e.g., “123 Main St” vs. “123 Main Street”), or a tax lot number is mistyped.

Why it gets rejected: ODOE uses property tax records and municipal databases to cross-reference Form Q submissions with covered buildings. A mismatched address or tax lot number can cause the submission to be associated with the wrong property, or not found at all in the compliance database.

How to avoid it: Before submitting, confirm your building’s tax lot number, city parcel ID, and exact legal property address with your county assessor’s office or tax statement. Use the same address format ODOE shows in their database after you search for your building.

Mistake 6: Illegible or Poorly Formatted Audit Report

The error: A building owner scans a paper audit report at low resolution, or the PDF has barely readable text. ODOE reviewers struggle to read it and may reject it due to illegibility.

Why it gets rejected: ODOE needs to verify that the audit meets ASHRAE standards. If the text is too blurry or the images are too dark, the reviewer can’t confirm critical details (auditor qualifications, building square footage, energy modeling results, recommended measures with costs and savings).

How to avoid it: Request the audit report directly from your auditor in digital PDF format (not a scan). If you have a paper copy, use a document scanner app (like Adobe Scan or a smartphone document camera) to create a high-resolution PDF. Test the PDF on your computer to ensure text is readable at 100% zoom.

What Happens After You Submit Form Q

ODOE Review and Questions

Once you submit Form Q, ODOE enters a formal review process:

1. Completeness check (1-2 weeks): ODOE reviewers verify that all required documents are present and legible. If something is missing or unclear, they’ll email you (using the contact email you provided) asking for clarification or a resubmission of a specific document.

2. Technical review (4-6 weeks): Reviewers examine the ASHRAE Level 2 audit to confirm it meets Oregon’s standards. They may ask questions about:

   • Building systems described in the audit
   • Energy conservation measures and their cost-effectiveness
   • Energy modeling assumptions
   • If a variance was requested, the justification and its reasonableness

3. Approval or conditional approval (1-2 weeks): ODOE issues a determination:

   • Approved: Your building is marked compliant. No further action required (unless you said you’d implement additional measures in the future, in which case ODOE may ask for follow-up documentation later).
   • Approved with conditions: ODOE approves your Form Q but requests a progress update (e.g., if you have a phased implementation plan, they may ask for a report in 12 months showing work completed).
   • Denied: ODOE rejects your Form Q and explains why. Common reasons include a flawed audit, missing documentation, or an unconvincing variance request. You’ll be given an opportunity to resubmit with corrections.

The entire review process typically takes 8-12 weeks from submission to final approval.

Status Tracking

You can check your Form Q status in the ODOE portal at any time using your login credentials and submission reference number. The status page shows:

• Submission date
• Current review stage
• Any pending questions from ODOE
• Expected approval date (if on track)

If ODOE has questions, respond promptly (typically within 2-3 weeks of their request). Delays in answering questions can push back your approval date.

Building Compliance Status

Once ODOE approves your Form Q, your building is marked “Compliant” in the state database. This status is reported to:

• Your city’s building department
• Your municipal utilities
• The state’s official building performance standard tracking system (available for public search)

If you’re refinancing the building, selling it, or applying for permits, potential lenders and buyers can verify your building’s compliance status through ODOE’s public database.

Timeline Recommendations

To avoid rushing, penalties, and incomplete submissions, here’s a recommended timeline working backward from your Form Q deadline:

18-24 Months Before Deadline:

• Start conversations with energy consultants and qualified auditors
• Request audit proposals and scope of work
• Evaluate quotes and select an auditor
• Sign audit contract

12-18 Months Before Deadline:

• Auditor conducts site visit and energy modeling
• Auditor delivers preliminary audit report
• Review findings and recommend energy conservation measures
• Start planning implementation projects

6-12 Months Before Deadline:

• Begin implementing priority energy conservation measures
• Gather contracts, invoices, and completion certificates as work finishes
• Finalize audit report with auditor (incorporating any system changes since site visit)
• Prepare Form Q documentation

3-6 Months Before Deadline:

• Complete all critical implementation projects
• Gather final completion documentation
• If not fully implementing, prepare variance request letter
• Create ODOE portal account and locate your building in the database

1-3 Months Before Deadline:

• Upload all documents to ODOE portal
• Submit Form Q
• Respond to any ODOE questions
• Receive approval (ideally before deadline, giving a safety margin)

Building this timeline into your planning means you’re not racing toward the deadline, ODOE has time to review without pressure, and you have a buffer if they ask questions or request clarifications.

Contact Information and Resources

If you have questions during the Form Q process:

Oregon Department of Energy

• Online Portal: https://energyreporting.oregon.gov
• Email: bps@oregon.gov (general Form Q questions and submissions)
• Phone: (503) 378-4040 (building energy program)
• Address: 550 Capitol Street NE, Salem, OR 97301

Form Q Guidance and Updates:

• ODOE publishes updated Form Q guidance and FAQs at https://www.oregon.gov/energy/bps
• Check the site regularly for deadline extensions, rule clarifications, or accepted variance justifications

Energy Auditor Resources:

• Energy Trust of Oregon: https://energytrust.org (rebates and training for auditors)
• ASHRAE: https://www.ashrae.org (audit standards and auditor certification)
• Building Performance Institute (BPI): https://www.bpi.org (auditor credentials and training)

Form Q: Final Thoughts

Form Q is the gateway to compliance with Oregon’s Building Performance Standard. It’s not complex, but it requires preparation, accurate documentation, and honest assessment of what your building has and hasn’t accomplished in terms of energy efficiency.

The most successful Form Q submissions come from building owners and managers who:

• Start the process early (18-24 months before their deadline)
• Work with a qualified ASHRAE Level 2 auditor from the start
• Document every step of implementation with contracts and completion certificates
• Submit complete, legible documentation to ODOE
• Respond promptly to ODOE reviewer questions

If you’re approaching your Form Q deadline and haven’t started, you still have time—but not much. Contact an energy consultant today to assess your building and begin the audit and implementation process. Penalties begin immediately after the deadline passes. Form Q is the tool that stops them.