How many commercial buildings in Albany, Oregon actually know they’re subject to a state energy mandate that takes effect in less than two years? Based on the conversations we have with Linn County property owners, the answer is: not enough. Oregon’s Building Performance Standard — signed into law as HB 3409 in 2023 and codified under ORS 330-300 — requires commercial buildings 35,000 square feet and larger to complete an ASHRAE Level 2 energy audit, benchmark their Energy Use Intensity (EUI), and demonstrate a compliance pathway before the 2028 Tier 1 deadline. Albany has a concentrated cluster of industrial, manufacturing, retail, and institutional buildings that fall squarely under this requirement, and the clock is running.

Albany sits at the junction of I-5 and US-20 — the commercial and industrial center of Linn County. The city’s economy carries the imprint of its metals and timber manufacturing roots: ATI Specialty Alloys & Components and other industrial operations along the Willamette River have driven decades of large-footprint building construction. Add the retail corridors along Pacific Boulevard, Heritage Mall, the Linn County government complex, Samaritan Albany General Hospital, and the light industrial parks near the airport, and you have a building stock that is older, more energy-intensive, and less likely to have been benchmarked than comparable properties in Portland or Eugene.

Albany BPS Snapshot

Data Point	Detail
City population (2025 est.)	~56,500
County	Linn (county seat)
Electric utility	Pacific Power
Gas utility	NW Natural
Average commercial electricity rate	~$0.108/kWh (Pacific Power Schedule 23)
Estimated covered buildings (35,000+ sq ft)	25–40 properties
Key commercial areas	Pacific Blvd corridor, Heritage Mall area, Airport Industrial Park, downtown, Millersburg industrial zone
Tier 1 deadline	2028
Tier 2 deadline (20,000+ sq ft)	2030 (anticipated)

Pacific Power rates in the Albany market run slightly higher than PGE rates in the Portland metro — roughly $0.108/kWh on average versus $0.095/kWh. That’s relevant because higher utility rates mean the dollar savings from efficiency improvements are greater, which strengthens the ROI case for implementing your audit recommendations. A 50,000 square foot Albany office building spending $85,000/year on electricity stands to save $12,750–$25,500 annually by hitting a 15–30% energy reduction target.

Which Albany Buildings Are Covered

The 35,000 square foot threshold under ORS 330-300 captures more of Albany’s building stock than most property owners realize. The city’s commercial inventory skews larger and older than you might expect for a mid-valley market.

Industrial and manufacturing facilities. Albany’s industrial base along the Willamette River and in the Millersburg area includes some of the largest buildings in Linn County. Metal fabrication plants, wood products facilities, and food processing operations routinely exceed 50,000–100,000 square feet, with EUI profiles often 30–50% above target due to process loads and aging HVAC.

Pacific Boulevard retail corridor. Heritage Mall, the Fred Meyer complex, and big-box retail between Queen Avenue and the Ellsworth Street Bridge include several buildings above threshold. Retail EUI runs 70–110 kBtu/sq ft/year — driven by high lighting loads, poor thermal zoning, and original-equipment rooftop units.

Samaritan Albany General Hospital. Healthcare facilities are the highest-EUI buildings in any city’s BPS inventory. Samaritan Albany General runs 24/7 with intensive HVAC, medical equipment, and ventilation loads — typically 150–250 kBtu/sq ft/year, two to three times higher than office buildings.

Linn County government buildings. The courthouse complex and administrative offices downtown carry deferred HVAC and lighting maintenance that pushes EUI well above target.

Downtown commercial buildings. Albany’s historic downtown along First and Second Avenues includes older buildings that have been expanded or combined past the 35,000 square foot mark, with energy performance reflecting decades of patchwork mechanical upgrades.

What BPS Compliance Looks Like for an Albany Building

The compliance process runs 12–18 months from start to finish:

Collect 12 months of utility data (months 1–2). Pull Pacific Power electric and NW Natural gas bills for every meter. Shared meters — common in Albany’s multi-tenant retail and industrial properties — require submetering or allocation before your EUI calculation means anything.
Complete an ASHRAE Level 2 energy audit (months 3–5). A qualified auditor inventories every major energy system, builds a calibrated energy model, and identifies Energy Conservation Measures (ECMs) with projected savings, costs, and payback periods. Albany audit costs typically run $15,000–$35,000 flat fee depending on building size and complexity.
Benchmark your EUI (months 5–6). Enter utility data into ENERGY STAR Portfolio Manager to calculate kBtu/sq ft/year. This is the number ODOE uses to evaluate compliance.
Implement and demonstrate progress (months 6–18). If your EUI misses the target — and for most Albany buildings audited for the first time, it will — you implement ECMs from your audit report. ODOE credits buildings that show a good-faith improvement pathway, not just buildings already at target.

For details on what happens during the on-site audit, see our ASHRAE Level 2 energy audit explainer.

Typical EUI by Building Type in Albany

These ranges reflect what we see in mid-valley Oregon markets with Pacific Power service territory and Albany’s climate profile — warmer summers and slightly colder winters than Portland, but milder than southern Oregon.

Building Type	Typical Albany EUI (kBtu/sq ft/yr)	Common Target EUI	Gap
Office (1970s–1990s construction)	80–115	58–72	22–43 kBtu
Retail (big-box and strip)	70–110	55–70	15–40 kBtu
Industrial/manufacturing	90–180	65–100	25–80 kBtu
Healthcare (hospital campus)	150–250	100–140	50–110 kBtu
Government/institutional	75–105	55–70	20–35 kBtu
Warehouse/distribution	35–65	25–40	10–25 kBtu

The industrial and healthcare categories are where Albany diverges most from the statewide averages. ATI and other metals-related operations run process loads that don’t exist in a typical office building, and Samaritan Albany General’s 24/7 operation pushes its EUI into a range that requires specialized audit approaches.

Energy Trust Incentives Available to Albany Building Owners

Albany falls within Pacific Power’s service territory, which means building owners are eligible for Energy Trust of Oregon incentives. Two programs apply directly to BPS compliance work:

Audit cost incentive. Energy Trust can reimburse up to 50% of a qualifying ASHRAE Level 2 audit. On a $25,000 audit, that’s up to $12,500 back. The application process requires that the audit meet ASHRAE Standard 100 scope requirements, which any BPS-compliant audit already does.

Capital improvement incentives. When you implement the energy conservation measures identified in your audit — HVAC replacements, LED lighting retrofits, building envelope improvements, controls upgrades — Energy Trust offers per-measure incentives that typically cover 20–40% of project costs. For an Albany industrial facility investing $200,000 in HVAC and lighting upgrades, that could mean $40,000–$80,000 in incentive dollars.

These incentives stack with the federal 179D Commercial Buildings Energy Efficiency Tax Deduction (up to $5.00/sq ft for qualifying improvements). Your CPA and energy auditor should coordinate on capturing both.

Building Types We Serve in Albany

We work with commercial property owners across every major building category in the Albany and greater Linn County market:

Office buildings in downtown Albany and along Pacific Boulevard
Industrial and manufacturing facilities in Millersburg, the Willamette River corridor, and near Albany Municipal Airport
Retail properties along Pacific Boulevard, Heritage Mall, and the I-5/US-20 interchange area
Healthcare buildings including Samaritan Albany General Hospital and affiliated clinics
Government and institutional buildings including the Linn County courthouse complex and city facilities
Warehouse and distribution centers along the I-5 corridor between Salem and Eugene

For insight into how different building types approach BPS, see our posts on office building compliance, industrial and warehouse BPS, and hotel energy compliance.

Frequently Asked Questions

Does my Albany building need a BPS energy audit?

If your commercial building in Albany is 35,000 gross square feet or larger, yes — ORS 330-300 requires you to complete an ASHRAE Level 2 energy audit and benchmark your EUI as part of Oregon’s BPS compliance pathway. The Tier 1 deadline is 2028. Buildings between 20,000 and 35,000 square feet fall under Tier 2 with an anticipated 2030 deadline. Residential single-family homes and small commercial properties below the thresholds are not covered.

How much does a BPS audit cost for an Albany building?

For most Albany commercial buildings, an ASHRAE Level 2 audit runs between $15,000 and $35,000 at a flat fee, depending on building size, system complexity, and whether process loads are involved. A 45,000 square foot office building is on the lower end. A 100,000+ square foot industrial facility with specialized process equipment is on the higher end. Energy Trust of Oregon incentives can reimburse up to 50% of the audit cost — potentially cutting your net investment in half.

What happens if my Albany building doesn’t comply by 2028?

ODOE is finalizing enforcement mechanisms, but ORS 330-300 includes potential financial penalties and mandatory reporting consequences. Beyond penalties, non-compliance creates practical problems: difficulty refinancing or selling, higher insurance scrutiny, and inability to demonstrate due diligence to tenants. The cost of an audit now is a fraction of the cost of scrambling in 2027 when auditor schedules are fully booked statewide.

Is Albany’s climate different enough from Portland to affect my audit?

Yes. Albany sits in the mid-Willamette Valley with slightly higher summer temperatures and comparable winter lows to Portland, but the real difference is humidity and heating degree days. Albany averages roughly 4,600 heating degree days versus Portland’s 4,400, which means higher heating loads and a different HVAC optimization profile. Your auditor needs to account for Linn County’s climate data — not Portland metro assumptions — when building the energy model and calculating ECM savings projections.

Can I use the same auditor who did my Portland building?

Yes, provided they’re familiar with Pacific Power rate structures and mid-valley climate conditions. The ASHRAE Standard 100 methodology is the same statewide, but utility inputs, rate schedules, and climate modeling differ. We calibrate every audit to the specific utility territory and climate zone of the property.

Albany Building Owners: Your 2028 Deadline Is 22 Months Away

Twenty-two months sounds like breathing room until you account for reality: 2 months for utility data, 3–5 months for the audit, and 6–12 months to implement capital improvements. Start in May 2026, and you land right at the deadline with zero margin for permitting delays or equipment lead times. The building owners who come out ahead start early, lock in Energy Trust incentive dollars before the program gets overwhelmed, and implement improvements on their own timeline instead of ODOE’s.

We provide flat-fee ASHRAE Level 2 compliance audits for commercial buildings in Albany, Millersburg, and throughout Linn County. No hourly billing, no scope creep — a fixed price for the complete audit, energy model, and prioritized improvement roadmap.

Schedule your compliance audit and find out exactly where your Albany building stands before the 2028 deadline forces the question.

Need ongoing compliance tracking after your audit? Our annual BPS benchmarking service handles utility data collection, ENERGY STAR Portfolio Manager updates, annual ODOE submissions, and year-over-year EUI tracking — so you stay compliant without adding work to your plate every year.

Set up annual benchmarking to keep your Albany building on track after the audit is done.

Albany Building Performance Standard