Does Oregon BPS really apply to industrial buildings? Short answer: yes, but with nuance around process-load exemptions. Long answer: if your Gresham building is 35,000 square feet or larger and you run any meaningful administrative, lab, clean room support, assembly, or warehouse space inside it, you need an ASHRAE Level 2 energy audit on a defined timeline regardless of what you manufacture.

That matters in Gresham more than in almost any other Oregon city. Gresham’s commercial real estate profile is roughly 70 percent industrial and warehouse by square footage. Boeing Portland runs a 1.8 million square foot Center of Excellence here with about 1,800 employees. Microchip Technology runs Fab 4, a 124,000 square foot ISO 3/4/5 clean room facility with around 700 employees on 24/7/365 operation. ON Semiconductor has an electronics manufacturing presence. The city’s built environment is heavy-duty industrial, and Oregon’s Building Performance Standard captures the office, lab, and support portions of those facilities even when specific process loads are exempt.

Gresham Commercial Profile

Gresham Data	Figure
City population	~110,000
County	Multnomah
County jurisdiction	Eastern Portland metro
Electric utility	Portland General Electric (PGE)
Industrial employment	~15,000+ workers in manufacturing, fabs, assembly
Commercial inventory mix	~70% industrial/warehouse; ~20% retail; ~10% office/institutional
Industrial tracked inventory	~2.1M+ sq ft (avg ~211,000 sq ft/building)
Office tracked inventory	~280,915 sq ft across ~18 buildings
Retail tracked inventory	~734,049 sq ft
Anchor employers	Boeing Portland, Microchip Technology (Fab 4), ON Semiconductor, Mt. Hood Medical Center
Primary industrial corridors	North Gresham along I-84, Burnside/Powell commercial strips
City climate target	Community Climate Action Plan targets

The Industrial Reality in Gresham

Gresham’s economy is rooted in heavy manufacturing. Boeing’s Center of Excellence produces components for the 737 MAX and 787 Dreamliner. Microchip’s Fab 4 manufactures high-reliability microcontrollers for aerospace, defense, and automotive applications. ON Semiconductor runs a wafer fabrication facility. These aren’t light assembly or tech companies — they’re 24/7 industrial operations with significant process loads, clean rooms, and utility-intensive manufacturing environments.

The Oregon Building Performance Standard doesn’t exempt manufacturing. What it does is create specific rules about which loads fall inside the audit boundary and which don’t. A Gresham industrial building typically includes:

Process load areas (the manufacturing floor, clean room, fab line, test chambers, etc.) — often exempt from audit scope under narrow process-load definitions
Administrative office areas — always in scope for BPS
Lab support and R&D spaces — typically in scope
Warehouse and assembly support — typically in scope
Building envelope, HVAC, and infrastructure serving mixed uses — in scope, with process-load adjustments

Getting the boundary right at the scoping stage is where a lot of compliance headaches get solved before they start.

Which Gresham Buildings Are Covered

Oregon BPS under ORS 330-300 applies to commercial buildings 35,000 square feet and larger. In Gresham that captures:

Boeing Portland Center of Excellence — Multiple office, support, and assembly buildings at the 1.8M sq ft campus. Individual buildings are evaluated for process-load scoping with ODOE. The office buildings and support facilities are clearly in scope; clean room support and assembly areas may have process-load exemptions depending on specific functions.
Microchip Technology Fab 4 — The 124,000 sq ft semiconductor fabrication facility includes administrative space, lab support buildings, and clean room infrastructure. The pure manufacturing process areas are typically scoped separately; office and lab support are in scope.
ON Semiconductor facility — Similar profile to Microchip; process loads are scoped separately from administrative and support functions.
Mt. Hood Medical Center — Hospital campus and affiliated medical office buildings above the threshold; all are in scope.
Gresham Station Shopping Center — 340,000 sq ft mixed-use lifestyle center with retail anchors and service tenants. Individual buildings above the threshold are separately captured.
Alta Civic Station — Mixed-use residential/commercial development in downtown Gresham.
Rockwood Commercial Center — Third major commercial corridor with office, retail, and mixed-use buildings.
Gresham Downtown office and retail buildings — The historic downtown core has office and commercial buildings, many constructed 1970s–1990s, above the threshold.
Warehouse and logistics facilities — The industrial stock concentrated in North Gresham and along I-84 corridor; buildings above the threshold with administrative space are captured.
Private K-12 and educational facilities — Schools and institutional buildings above the threshold.
Hotels and multifamily buildings — Lodging properties and larger apartment complexes.

What Oregon BPS Actually Requires

The compliance package for each covered building includes:

Annual benchmarking (completed January 2025) — Reporting of energy use to the Oregon Department of Energy. This establishes the baseline EUI (energy use intensity) for your building.

ASHRAE Level 2 energy audit (2026–2028) — A structured engineering assessment governed by ASHRAE Standard 100 with Oregon amendments. This is the most technically demanding piece. It requires an on-site engineering assessment, measurement of key building system performance, energy modeling, and structured life-cycle cost analysis.

Life-cycle cost assessment — For every recommended energy conservation measure, we calculate whether the upgrade actually pencils over its useful life at real Gresham electricity rates (roughly $0.126/kWh for PGE commercial customers in 2026).

Form Q compliance report (by 2028 or 2030) — The final compliance package submitted to ODOE.

For Gresham’s industrial-heavy portfolio, scoping conversations with ODOE around which process loads fall inside or outside the audit boundary are often essential — and getting them right at the start saves substantial time and cost.

Process-Load Exemptions: The Gray Area

Here’s where Gresham gets specific. If you operate a manufacturing facility, data center, or other process-intensive building, the ASHRAE Standard 100 definition of “process load” matters. Broadly:

Process loads (typically exempt from audit scope):

Manufacturing equipment directly producing goods (fab lines, assembly equipment, etc.)
Process-critical cooling or heating (semiconductors, pharmaceuticals, etc.)
Clean room support systems directly tied to the manufacturing process
Test chambers, environmental chambers, specialized equipment

Non-process loads (in scope):

Administrative office lighting, heating, cooling
Employee facilities (break rooms, restrooms, cafeterias)
Warehouse and staging areas
Lab spaces that support but aren’t the direct manufacturing process
Building envelope and general HVAC

The determination depends on the specific building and its use. We recommend a pre-audit scoping call with ODOE for any Gresham industrial client to clarify the boundary. This call typically takes 30 minutes and prevents months of back-and-forth later.

PGE Territory and Energy Trust Incentives

Gresham is served by Portland General Electric. Energy Trust of Oregon offers up to $0.85 per square foot in incentives for BPS compliance work. For a 70,000 square foot Gresham manufacturing support building, that’s $59,500 in available incentive money — nearly six times our $10,000 flat audit fee for that size bracket.

PGE also runs its own commercial efficiency rebate program. For industrial clients, the combined incentive stack on HVAC, compressed air, lighting, and controls upgrades often runs into six figures. We coordinate directly with PGE’s commercial services team early in the engagement to identify the full incentive stack and avoid overlaps.

Gresham’s wastewater treatment plant precedent is worth noting: the facility was the first in Oregon certified for thermal renewable energy certificates in 2018 and now runs on 92% biogas, saving around $500,000 per year. That kind of local sustainability track tends to translate into a building-owner ecosystem receptive to energy investment — and facilities teams that know how to execute when the audit findings come back.

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

Building Size	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. The fee is locked at the scoping call.

For multi-building portfolios (Boeing, Microchip, larger shopping centers), we typically offer a small discount on the second and third buildings in a series, since the scoping work overlaps.

Building Categories We Handle in Gresham

Industrial and manufacturing facility office, lab, and support buildings — The core of Gresham’s portfolio
Warehouse and distribution buildings — North Gresham logistics and staging facilities
Healthcare buildings, medical office buildings, and clinics — Mt. Hood system and smaller practices
Retail anchors and shopping center pads — Gresham Station, Rockwood, downtown retail
Mixed-use residential/commercial buildings — Alta Civic and similar developments
Hotels and larger multifamily — Gresham has growing lodging and residential stock
Private education and institutional buildings — Schools and community facilities
Historic downtown office and commercial buildings — The older downtown core with renovation potential

The Realistic Gresham Timeline

Compliance deadlines in 2028 and 2030 feel distant until you back out the actual work:

Audit and on-site work: 4–8 weeks
LCCA review and refinement: 1–2 weeks
Form Q preparation and ODOE technical review: 2–6 weeks
Physical upgrades driven by audit findings: 3–12 months for most facilities; longer for major equipment replacement

Starting in 2026 gives a Gresham industrial owner room to move at a normal pace. Starting in 2027 compresses the schedule. Starting in 2028 means expediting every phase and risking incomplete implementation.

For large industrial clients with multiple buildings, consider a portfolio audit approach: we can often batch the on-site work across several buildings and deliver multiple Form Q reports more efficiently than individual building audits.

Gresham-Specific Compliance Considerations

Multi-building portfolios: If you operate multiple buildings (Boeing, Microchip, larger retail groups), each building is individually tiered and has its own deadline. Don’t assume they’re all Tier 1 or all Tier 2. We verify each building on the ODOE dashboard and prioritize accordingly.

24/7 operations: Gresham’s industrial and healthcare facilities often run continuous operations. This affects when we can conduct on-site assessment and may require working during off-peak hours or on weekends. Build this into the project timeline.

Process-load negotiations with ODOE: For complex industrial facilities, ODOE’s process-load determination can take weeks or months. We manage this conversation on your behalf, but it requires technical documentation (process flow diagrams, load calculations, equipment specifications) early in the engagement.

Utility rate volatility: PGE commercial rates have been rising 5–7% annually. The life-cycle cost analysis assumes future rates will rise at a 2.5% annual average (conservative). If you expect rates to rise faster due to grid modernization or electrification, the simple payback on electrical efficiency measures improves.

Getting Started with BPS Compliance in Gresham

Here’s the action plan:

Confirm your building’s tier and deadline. Go to the ODOE BPS dashboard and look up your building’s address. Write down the tier (Tier 1 = 2028 deadline; Tier 2 = 2030 deadline).
Gather building documentation. Pull together utility billing history (past 3 years, all accounts), property tax assessment, building square footage, HVAC system inventory, and any existing energy audits or commissioning reports.
If you operate an industrial or process-intensive facility, schedule a 30-minute pre-audit scoping call with ODOE to clarify process-load boundaries. We can facilitate this.
Request audit proposals. Email three ASHRAE-qualified auditors with your building address, square footage, primary use, and any process-load questions. Ask for a flat-fee quote and proposed timeline.
Execute the audit. Once you’ve selected an auditor, schedule on-site work for a convenient date and commit to providing access and utility documentation.
Coordinate with PGE and Energy Trust. Have the auditor work with PGE’s commercial services team to identify all available incentives before finalizing the equipment recommendations.
Review the Form Q report. When you receive the audit report, schedule a review meeting with the auditor and your facilities team to understand the findings and prioritize recommendations.
Begin implementation. Phase in the recommended measures, starting with low-cost, high-impact items (controls, operational changes), then moving to capital equipment replacement.
Submit Form Q to ODOE before your tier deadline.

Use our contact form with your Gresham building details — address, approximate square footage, primary use, whether it’s part of an industrial complex, and the utility provider. We’ll return a flat quote and an Energy Trust/PGE incentive read the same week. For industrial clients navigating process-load scoping, our post on Oregon BPS for industrial and warehouse properties covers the specific gray areas.

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.

Gresham Building Performance Standard