Oregon BPS for Industrial and Warehouse Properties

The single most common misunderstanding about Oregon BPS in industrial buildings is the assumption that “industrial” means “exempt.” It doesn’t. Oregon’s Building Performance Standard under ORS 330-300 captures most industrial commercial property—warehouses, distribution centers, manufacturing support buildings, food processing plants, and the office and lab portions of industrial campuses. What it does carve out are specific process loads tied to manufacturing, and the boundary between “process load” and “everything else” is where the real compliance work for industrial owners begins.

This post is for owners and facilities directors of Oregon industrial properties, warehouses, distribution centers, and manufacturing campuses. It covers what’s covered, what’s exempt, where the gray areas live, and how the audit work actually runs for an industrial building under ORS 330-300.

The Quick Answer

Oregon BPS applies to commercial buildings 35,000 square feet and larger, including warehouses, distribution centers, and most industrial facilities. Pure manufacturing process loads (the equipment that turns inputs into finished product) can be excluded from the audit boundary under specific scoping rules codified in ORS 330-300 regulations. The office space, lab space, warehouse portions, and support buildings of an industrial campus are typically captured and subject to full BPS compliance.

The Process Load Exemption: What It Covers and What It Doesn’t

Oregon BPS recognizes that requiring a paper mill to run an ASHRAE Level 2 audit on its actual paper machine doesn’t produce useful results. The energy use of a paper machine is a function of the chemistry and mechanics of papermaking, not building operations, and standard energy conservation measures don’t apply. The same logic applies to semiconductor fabs, food processing lines, foundries, refineries, and other heavy industrial process equipment.

The result is a process-load exemption that excludes specific manufacturing process equipment from the audit boundary. But—and this is the part property owners almost always miss—the exemption is narrow. It applies to the process equipment itself and the building systems directly serving that process equipment. It does not apply to:

• The office buildings on the same campus
• The lab and R&D buildings supporting production
• The warehouse where finished product is stored
• The administrative and support buildings
• The HVAC and lighting in non-process areas
• The cafeteria, conference rooms, training facilities
• Parking lot lighting and site utilities not directly tied to process

For a typical Oregon industrial site with one or two pieces of large process equipment and a substantial commercial-style support footprint, the BPS audit captures most of the building square footage even when the process equipment is formally exempt.

What Counts as a Process Load vs. Building Systems

The boundary between process and non-process is critical for scoping compliance correctly under ORS 330-300:

System or Equipment	Typical Treatment
Direct manufacturing equipment (machining, molding, assembly lines)	Process load — typically excluded from audit boundary
Compressed air system serving production	Process load — typically excluded
Process cooling water systems	Process load — typically excluded
Process steam generation	Process load — typically excluded
HVAC for process spaces (but not space conditioning beyond process needs)	Mixed — building systems portion may be included
Office building HVAC and lighting	Building systems — included in audit
Warehouse HVAC and lighting	Building systems — included
Lab HVAC (if not dictated by process requirements)	Building systems — included
Domestic hot water for cafeteria and restrooms	Building systems — included
Loading dock conditioning and air infiltration control	Building systems — included
Outdoor lighting and parking lot lighting	Building systems — included

The boundary between process and non-process is sometimes obvious and sometimes contested. For a clean semiconductor fab in Hillsboro, the clean room HVAC is process-driven (because the air change rates and filtration are dictated by clean room class, not building comfort standards) but the cafeteria HVAC is straightforward building systems. For a food processing plant in Salem, the refrigeration equipment running the production process is process load, but the warehouse where palletized product is staged is building systems.

The right move is to scope this with ODOE and your auditor before the on-site work begins, not after it’s started.

Which Industrial Buildings Are Most Often Captured

In our experience auditing Oregon industrial properties, the most common building types we’re working with under ORS 330-300 are:

• Warehouse and distribution centers — Often 100,000+ sq ft, almost always captured. Lighting, HVAC for office space, dock door management, and refrigeration treatment are common focus areas.
• Manufacturing campus office buildings — The office and administrative space at industrial facilities (Boeing, Intel, Microchip, Columbia Forest Products sites)
• Lab and R&D buildings on industrial campuses — Captured even when adjacent to process areas with different rules
• Food processing plant warehouses and administrative buildings — Plant floor process equipment may be exempt, but the rest of the building is in scope
• Wood products mill office and support buildings — Facilities in the Pacific Northwest operated by Weyerhaeuser, Roseburg Forest Products, Stimson Lumber, and others
• Cold storage warehouses — Refrigeration equipment treatment depends on whether it’s process-driven or general building service
• Truck terminals and logistics facilities — Almost always captured at the 35,000 sq ft threshold
• Data centers (including those on industrial campuses) — Captured as high-energy-use facilities

How an Industrial BPS Audit Runs in Practice

The basic audit process is the same as for office or healthcare buildings, with several important adaptations for industrial sites.

Pre-Engagement Scoping

We spend more time on pre-engagement scoping for industrial buildings than for any other building type. Specifically, we want to understand:

• The manufacturing process and what equipment it involves
• The boundary between process and non-process loads
• The existing utility metering structure (sub-meters help significantly)
• The operating schedule and seasonal variations
• Which buildings on the campus are in scope and which are exempt

For a complex site with multiple buildings, we often recommend scoping with ODOE on the boundary questions before the audit work begins. Getting alignment on process load treatment upfront prevents complications later.

Two to Four Day On-Site Assessment

Industrial sites take longer on-site than typical commercial buildings because there’s more square footage, more building types, and more system complexity. A typical engagement runs two to four days, including time with operations and maintenance personnel who often have institutional knowledge that doesn’t show up in any building automation system or drawing.

Energy Modeling with Process Carve-Outs

The energy model has to handle the process load exemption correctly. We typically model whole-site energy use, then carve out the process loads to show the building systems baseline that’s actually subject to the audit. The Form Q deliverable then documents both the included and excluded loads with supporting data and calculations.

Life-Cycle Cost Assessment on Building Systems Measures

Just like a standard ASHRAE Level 2 audit, we run comprehensive LCCA on every recommended energy conservation measure within the audit boundary. For industrial buildings the highest-value measures are often:

• Compressed air system optimization (where compressed air is general-utility rather than process-specific)
• Warehouse and dock door lighting and controls
• HVAC controls for office and warehouse zones
• Outdoor lighting retrofits
• Heat recovery from process equipment (where applicable and feasible)
• Building automation system recommissioning and optimization

The Energy Trust of Oregon Incentive Math for Industrial

Energy Trust of Oregon offers up to $0.85 per square foot in BPS compliance incentives for all covered buildings. For a 200,000 square foot industrial facility, that’s up to $170,000 in available incentive money—substantial enough to fully cover the audit fee and a significant chunk of measure implementation.

For Pacific Power-served industrial buildings, there are also industrial-specific custom incentive paths through Energy Trust on larger measures. Manufacturing efficiency programs, compressed air optimization rebates, and process heat recovery incentives all stack on top of the general BPS incentive.

Flat Fee Schedule for Industrial Audits

Our flat fee schedule applies for most industrial buildings:

• 35,000-50,000 sq ft: $7,500
• 50,000-75,000 sq ft: $10,000
• 75,000-100,000 sq ft: $13,500
• 100,000-150,000 sq ft: $17,500
• 150,000+ sq ft: custom quote

For complex industrial campuses with multiple buildings or significant process-load scoping work, we typically scope custom—but the pricing remains flat (locked at scoping) rather than hourly or contingent. This gives you cost certainty upfront.

A Real Industrial Scenario: The Springfield Warehouse

A facilities manager at a 130,000 square foot Springfield location came to us in 2026. The site included a small office building (15,000 sq ft) attached to a much larger warehouse (115,000 sq ft) used for finished lumber storage and shipping. The property owner initially assumed the entire site was exempt because it was “industrial.”

We scoped the building as covered: the warehouse is a commercial-style building under ORS 330-300, and the office is obviously commercial. The actual production mill on the adjacent site was a separate building with its own process load treatment, not part of this scope.

The ASHRAE Level 2 audit identified the following:

• Warehouse lighting retrofit: LED with motion controls in storage aisles, 4-year payback, $18,000
• Dock door air infiltration sealing: Improving door seals and reducing hot/cold air infiltration, 1.8-year payback, $8,000
• Office HVAC and BAS recommissioning: Controls optimization and ventilation tuning, 2.3-year payback, $12,000
• Warehouse roof insulation upgrade: Marginal on LCCA, 8-year payback, included for analysis but not priority

Total identified annual savings: approximately $38,000 per year on a building that previously hadn’t received serious efficiency attention.

Energy Trust of Oregon incentive at $0.85 per square foot on 130,000 sq ft: up to $110,500. Audit fee: $17,500 flat. Net incentive position after audit: roughly $93,000 toward measure implementation.

The economics worked, the building is on track for ORS 330-300 compliance, and the warehouse lighting upgrade alone was reducing operating costs faster than the project payback period. The facility was positioned for successful compliance with substantial cost reduction.

Practical Recommendations for Industrial Property Owners

1. Don’t assume industrial means exempt — Most Oregon industrial buildings 35,000+ sq ft are captured under BPS. Verify your building’s status.
2. Understand the process load boundary — Work with your auditor to clearly define what’s process and what’s building systems.
3. Engage ODOE on scoping questions — If there’s ambiguity, get it resolved before the audit work begins.
4. Plan for multi-building campuses — Each building over 35,000 sq ft is potentially in scope; can’t combine them into one portfolio exemption.
5. Lock in auditor and timing in 2026 — The market gets tight in 2027.
6. Apply for Energy Trust incentives early — The grants are substantial for industrial facilities.

Bottom Line for Industrial Owners

Don’t assume industrial means exempt. Most Oregon industrial buildings 35,000 square feet or larger are captured under ORS 330-300, and the process-load exemption is narrower than most owners think. The right move in 2026 is a scoping conversation with a qualified auditor who understands the boundary questions, followed by an audit that’s structured to handle the carve-outs correctly.

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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 330-300 — Oregon Building Performance Standard
• ORS 330.135 — Requirements for Covered Buildings
• ASHRAE Standard 100-2018 — Energy Conservation in Existing Buildings
• ASHRAE Standard 211-2018 — Commercial Building Energy Audits
• Energy Trust of Oregon — Industrial Efficiency Programs
• ODOE Process Load Guidance for Industrial Facilities