Gresham Building Performance Standard

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
Electric utility	Portland General Electric (PGE)
Commercial inventory mix	~70% industrial/warehouse
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, Microchip Technology, ON Semiconductor, Mt. Hood Medical Center

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 — Office, support, and assembly building space at the 1.8M sq ft campus (individual buildings evaluated for process-load scoping)
• Microchip Technology Fab 4 — Office, lab support, and admin space at the semiconductor fab; clean room process loads typically scoped separately
• Mt. Hood Medical Center — Hospital, medical office, and support buildings
• Gresham Station Shopping Center — 340,000 sq ft mixed-use lifestyle center with retail and service tenants; larger anchor pads individually captured
• Alta Civic Station — Mixed-use residential/commercial development
• Rockwood Commercial Center — Third major commercial corridor in Gresham
• Historic Downtown Gresham office and retail buildings — Larger buildings in the downtown core
• Warehouse and logistics facilities — The industrial stock concentrated in North Gresham
• Private K-12 and educational buildings — Above the threshold
• Hotels, lodging, and larger multifamily buildings

What Oregon BPS Actually Requires

The compliance package for each covered building includes annual benchmarking to the Oregon Department of Energy (first reports were due January 2025), a full ASHRAE Level 2 energy audit governed by ASHRAE Standard 100 with Oregon amendments, a life-cycle cost assessment on every recommended energy conservation measure, and a Form Q compliance report submitted to ODOE by the 2028 or 2030 deadline depending on tier assignment.

The ASHRAE Level 2 audit 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. 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.

The Energy Trust and PGE Incentive Layer

Energy Trust of Oregon offers up to $0.85 per square foot in incentives for BPS compliance work. Since Gresham is served by PGE, Energy Trust applies directly. 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, and for industrial clients the combined incentive stack on HVAC, compressed air, lighting, and controls upgrades often runs well into six figures.

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

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

Building Categories We Handle in Gresham

• Industrial and manufacturing facility office, lab, and support buildings
• Warehouse and distribution buildings
• Healthcare buildings, medical office buildings, and clinics
• Retail anchors and shopping center pads
• Mixed-use residential/commercial buildings
• Hotels and larger multifamily
• Private education and institutional buildings
• Historic downtown office and commercial buildings

The Realistic Gresham Timeline

Compliance deadlines in 2028 and 2030 feel distant until you back out the actual work: audit (4-8 weeks), LCCA review and refinement (1-2 weeks), Form Q preparation and ODOE review (2-6 weeks), and any physical upgrades driven by the audit findings (typically 3-12 months). 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.

Email Mike at vanvicklebros@gmail.com with your Gresham building details — address, approximate square footage, primary use — and we’ll return a flat quote and an Energy Trust incentive read. For industrial clients navigating process-load scoping, our post on Oregon BPS for industrial and warehouse properties covers the specific gray areas. You can also review the full compliance process before scheduling a call.