A hotel GM in the Old Mill District called last quarter with a question we hear a lot: “If we’re already doing a deep retrofit in 2027, does that count for BPS?” The answer, unfortunately, is “only if it’s documented through the specific ASHRAE Level 2 process the state requires and submitted through Form Q to the Oregon Department of Energy.” Good energy upgrades don’t automatically satisfy Oregon BPS — the documentation is the compliance.

That’s the quiet trap for a lot of Bend building owners, because Central Oregon tends to have more voluntary sustainability investment than most of the state. Doing the work is great. But if the engineering framework isn’t the one Oregon requires, you still owe the audit.

Bend’s Commercial Real Estate Profile

Bend’s commercial real estate market is small relative to Portland but unusual in its composition. Compass Commercial tracks roughly 900 commercial buildings totaling 13.7 million square feet across office, retail, and industrial. Office vacancy has stayed under 6 percent even through national slowdowns. Retail vacancy has been closer to 3 percent. Industrial is effectively full at under 2 percent. The result is a commercial market where buildings over 35,000 square feet are disproportionately concentrated in a handful of categories:

Bend Data at a Glance

Bend Detail	Figure
City population (2026)	~110,545
County	Deschutes
Primary electric utility	Pacific Power
Secondary utility	Central Electric Cooperative (parts of metro)
Total commercial sq ft tracked	~13.7 million
Commercial buildings tracked	~900
Office vacancy (recent)	~5.66%
Retail vacancy (recent)	~3.2%
Industrial vacancy (recent)	~1.99%
Anchor employer	St. Charles Health System (~3,800 caregivers)
Largest employers with buildings	St. Charles, outdoor recreation brands, tech startups
City elevation	3,600 feet
City climate target	40% fossil fuel reduction by 2030
Typical commercial EUI range	45–80 kBtu/sq ft/yr (heating-dominated climate)

The elevation matters. Bend sits at 3,600 feet, which means heating degree days run substantially higher than the Willamette Valley. A building’s baseline EUI in Bend will naturally be higher than the same building type in Portland or Salem, simply because of climate. This affects the energy performance targets ODOE applies — buildings in higher-elevation areas have adjusted benchmarks that account for climate differences.

Bend’s Building Categories and BPS Scope

Hospitality and resort properties: Hotels, resorts, and larger lodging properties serving Bend’s year-round tourism economy. These range from downtown boutique hotels to large resort properties on the south side. Most are heated year-round, and many were built in the 1980s–2000s with systems that are efficient by 1990s standards but lag current performance levels.

Healthcare and medical office: St. Charles Health System’s flagship Bend hospital and clinics, plus the clinics, medical office buildings, and support facilities in its four-hospital network across Central Oregon. St. Charles is Bend’s single largest employer. The health system has multiple sites that fall into BPS scope, and healthcare buildings are among the most energy-intensive building types due to 24/7 operation and extensive clinical facilities.

Tech and office (high-growth sector): Bend’s tech sector grew 64.8 percent between 2015 and 2020, adding roughly 2,280 jobs. The commercial office space that supports that sector is increasingly in scope. This includes tech company headquarters, R&D facilities, and corporate office parks. Many of these buildings were built in the 1990s–2010s and are fairly efficient by age standards, but are still subject to BPS requirements.

Old Mill District mixed-use: The 270-acre former mill site along the Deschutes has 55+ retail, restaurant, and entertainment tenants. The larger buildings on that campus are captured by BPS. The Old Mill represents Bend’s most prominent mixed-use commercial development and was designed with newer construction standards than much of Bend’s historic downtown stock.

Outdoor recreation and consumer brand HQs: Bend is home to a dense cluster of outdoor and consumer brand headquarters in commercial office space. This includes climbing equipment manufacturers, apparel companies, outdoor recreation retailers, and similar businesses. Many occupy office buildings in the 40,000–150,000 square foot range.

Multifamily and adaptive-reuse hotel projects: Larger apartment buildings and conversion projects (warehouse-to-lofts, historic hotel-to-condos) above the 35,000 square foot threshold. Bend has had significant adaptive reuse development along the downtown core and Old Mill District.

Warehouse and industrial: The industrial stock in Bend is tight and relatively small compared to western Oregon. Larger buildings (35,000+ sq ft) in the industrial category are captured. This includes distribution, light manufacturing, and flex space.

The Oregon BPS Mandate in Plain Terms

Oregon’s Building Performance Standard, adopted under ORS 330-300, requires covered commercial buildings 35,000 square feet and larger to:

Benchmark annual energy use through ODOE’s portal (due January 2025 for initial submission)
Complete an ASHRAE Level 2 energy audit on a defined schedule (typically 4–6 weeks of work)
Run a life-cycle cost assessment on every identified energy conservation measure (part of audit)
Submit a Form Q compliance report to ODOE by 2028 (Tier 1) or 2030 (Tier 2)

The ASHRAE Level 2 audit is the technical centerpiece. It’s a structured engineering review governed by ASHRAE Standard 100 with Oregon amendments — not a checklist, not a desk review, not a rebrand of your existing utility audit.

How the Audit Actually Runs in Bend

A typical Bend BPS audit runs four to six weeks from engagement to delivered report. We start with a kickoff call and data request (benchmarking records, utility billing history, building systems inventory), then schedule a one-to-two-day on-site walkthrough with your facilities team.

On-site, we measure key envelope and mechanical performance using portable instruments. We photograph and document existing conditions. We model the building’s energy use using ASHRAE-approved software and run a life-cycle cost assessment on every candidate energy conservation measure. We deliver a compliance-ready Form Q package and stay available to walk the report through any ODOE questions.

For large multi-building campuses (like a St. Charles multi-clinic portfolio), we typically work building by building rather than portfolio-wide, since buildings have different ages, systems, and efficiency levels.

Central Oregon has a smaller pool of qualified energy auditors than the I-5 corridor, so securing an auditor with Bend experience and availability is worth doing sooner rather than later. We expect availability to tighten significantly in 2027 as the deadline approaches.

Energy Trust and Utility Incentive Layer

This is where Bend building owners often win. Energy Trust of Oregon offers up to $0.85 per square foot in incentives for BPS-related audit and early-action work. A 50,000 square foot hotel qualifies for up to $42,500 in Energy Trust money, which is more than our $10,000 flat audit fee for that size bracket. The remaining incentive dollars can be directed toward actual equipment upgrades.

For buildings served by Pacific Power (Bend’s primary utility), Energy Trust flows directly. Pacific Power also runs commercial efficiency rebates that stack on top of Energy Trust for qualifying measures — HVAC upgrades, LED lighting, controls, and weatherization typically all qualify.

For buildings served by Central Electric Cooperative (some parts of the metro area), EWEB-style coordination applies — you’ll have two incentive pathways to evaluate.

Incentive Stacking Example (Bend Hotel)

A 75,000 square foot hotel in Bend:

Energy Trust incentive: 75,000 × $0.85 = $63,750
Pacific Power rebates for HVAC retrofit: ~$25,000
Pacific Power rebates for LED lighting retrofit: ~$15,000
Total available incentives: $103,750+

Our audit fee for a 75,000 sq ft building: $13,500

Remaining incentive dollars for implementation: $90,250+

That’s substantial funding for a hotel retrofit. Many Bend hospitality owners find that Energy Trust and Pacific Power incentives cover 50–70 percent of their improvement costs.

How Much Does an Audit Cost? — Flat-Fee Pricing

Building Size	Flat Fee
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

No hourly billing. No percentage of savings. No contingency. The fee you see at scoping is the fee at invoice.

Start Before the Rush

Compliance deadlines in 2028 and 2030 sound far off, but the audit and remediation cycle for a working commercial building typically runs 9 to 18 months. Central Oregon has a smaller pool of qualified energy auditors than the I-5 corridor, and we expect availability to tighten significantly in 2027 as the deadline approaches. Starting the audit in 2026 gives you room to:

Complete the audit by mid-2026
Apply for and secure Energy Trust and Pacific Power incentive commitments by late 2026
Plan and design your improvement measures by early 2027
Complete implementation by early 2028 (for Tier 1) or mid-2029 (for Tier 2)
Verify performance and file compliance documentation ahead of the deadline

Starting in 2027 compresses this timeline. Starting in 2028 means potential deadline risk.

Bend’s Climate Context

Bend’s elevation and climate create higher baseline energy use than western Oregon. A commercial building at 3,600 feet will naturally use more energy for heating than the same building in Portland or Salem. ODOE’s EUI benchmarks account for this through regional adjustment factors, but it’s important to understand that “above average” for the coast might be “average” for Bend when elevation and weather are factored in.

Similarly, air conditioning is less common in Bend than cooling is necessary, so retrofit opportunities focus heavily on heating efficiency, insulation, and heat recovery rather than cooling optimization.

Building Types and Compliance Risk in Bend

Hotels and hospitality (year-round and seasonal): These run 55–85 kBtu/sq ft/yr depending on occupancy and amenities. Compliance usually requires HVAC system upgrade (including heat recovery or desuperheater for hot water), lighting retrofit, and controls upgrade. Cost to achieve compliance: $5–12 per square foot.

Healthcare (St. Charles network): These run 70–100 kBtu/sq ft/yr due to 24/7 operation and clinical facilities. Compliance typically requires dedicated systems work (clinical HVAC, medical gas, OR ventilation, sterilization support). Cost to achieve compliance: $7–14 per square foot.

Tech and corporate office: These run 45–65 kBtu/sq ft/yr and tend to be newer than historical Bend stock. Compliance usually requires HVAC controls upgrade, lighting retrofit, and envelope work (if built 1990s or earlier). Cost to achieve compliance: $3–7 per square foot.

Old Mill District mixed-use: These run 50–70 kBtu/sq ft/yr and were built with relatively modern standards. Compliance usually requires lighting retrofit, HVAC controls, and envelope optimization. Cost to achieve compliance: $3–8 per square foot.

Retail and commercial mixed-use (downtown): These run 50–75 kBtu/sq ft/yr depending on business type and tenant density. Compliance usually requires HVAC controls, lighting retrofit, and envelope improvements. Cost to achieve compliance: $4–8 per square foot.

Warehouse and industrial: These run 25–50 kBtu/sq ft/yr depending on process and climate control. Compliance usually requires minimal work or targeted HVAC and lighting upgrades. Cost to achieve compliance: $2–6 per square foot.

How to Get Started with BPS Compliance in Bend

Here’s the step-by-step path most Bend building owners should follow:

Step 1: Confirm your building is captured (1–2 days) Get the building address, square footage, and primary use category. Cross-check against ODOE’s building list. If over 35,000 sq ft and not exempt, assume you’re in.

Step 2: Verify benchmarking is filed (1 day) Check ODOE’s benchmarking database or confirm with Pacific Power that benchmarking data was submitted in January 2025. If not, file immediately.

Step 3: Pull historical utility data (1 week) Gather 3 years of billing records from Pacific Power or Central Electric Cooperative. Request it now.

Step 4: Determine your utility service area (1 day) Confirm whether your building is served by Pacific Power or Central Electric Cooperative. This affects incentive pathways and auditor selection.

Step 5: Scope the ASHRAE Level 2 audit (1 week) Contact an auditor with Bend experience, get a flat fee quote, and agree on a kickoff date. Lock in a 4–6 week window.

Step 6: On-site audit walkthrough (1–2 days) Schedule facilities personnel availability. The auditor needs access to mechanical rooms, roof, and occupied spaces.

Step 7: Review draft findings (1–2 weeks) The auditor delivers a draft report. Review it and confirm the identified measures make sense for your building.

Step 8: Get the final Form Q report (1 week) The auditor delivers the final compliance report and Form Q template.

Step 9: Apply for incentives (3–6 weeks) Apply for Energy Trust of Oregon and Pacific Power rebates. A good auditor will help coordinate both applications.

Step 10: Plan and implement measures (4–18 months depending on scope) Based on audit findings and incentive commitments, plan your energy conservation measures. Implementation timeline depends on scope.

Step 11: Verify performance and maintain records (ongoing) After implementation, monitor building performance against audit baseline. Energy Trust requires metering and verification.

The entire path from scoping to final implementation typically takes 12–18 months for a straightforward Bend office or hotel building.

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 and Pacific Power incentive programs to reduce compliance costs for building owners in Central Oregon and across the state.

Bend Building Performance Standard