Oregon City Building Performance Standard

Oregon City is the oldest incorporated city west of the Rockies, and its commercial real estate reflects that layered history — a compact downtown on the bluff, a retail corridor along Molalla Avenue and McLoughlin Boulevard, and industrial and light commercial development spreading south toward Canby. For building owners with properties at or above 35,000 gross square feet, that history now comes with a deadline: Oregon’s Building Performance Standard under ORS 330-300 requires Tier 1 buildings to complete an ASHRAE Level 2 energy audit and establish a compliance pathway by 2028.

The Oregon Department of Energy (ODOE) administers the program statewide. Oregon City buildings are subject to the state BPS — not Portland’s separate energy reporting program, which applies only within Portland city limits. For most Oregon City commercial property owners, this means one compliance program to track and one set of documentation to prepare.

Oregon City’s Commercial Building Stock and BPS Exposure

Oregon City’s covered commercial buildings are scattered across several distinct zones:

McLoughlin Boulevard corridor. The primary commercial spine running through Oregon City and into Gladstone contains the city’s largest retail and mixed-use buildings. Grocery stores, big-box retail adjacent to Clackamas Town Center to the north, and strip commercial centers along this corridor represent the most consistent source of buildings at or above the 35,000 square foot threshold.

Molalla Avenue and the bluff-level downtown. The historic downtown and adjacent commercial areas contain smaller buildings that typically fall below the Tier 1 threshold, but multi-story commercial structures and larger mixed-use buildings may qualify.

Industrial and flex commercial areas. Oregon City has a meaningful industrial base, particularly in the south and east portions of the city. Light industrial buildings, warehouses, and manufacturing facilities with significant square footage may be subject to BPS requirements depending on their gross floor area.

Zone	Building Types	Likely Threshold Coverage
McLoughlin Blvd retail	Grocery, big-box, strip centers	Yes for anchor buildings
Downtown/bluff	Mixed-use, office, civic	Selective — larger structures
Industrial south	Warehouse, light mfg, flex	Yes for larger facilities
Medical/office	Medical offices, professional	Tier 1 if ≥35K sq ft

What the 2028 Deadline Actually Requires

Oregon BPS compliance for Tier 1 buildings in Oregon City breaks down into three phases:

Phase 1 — Baseline your energy use. You need 12 consecutive months of utility data from your energy providers — typically Portland General Electric for electricity and NW Natural for natural gas. This data is entered into ENERGY STAR Portfolio Manager to calculate your Energy Use Intensity (EUI), expressed in kBtu per square foot per year.

Phase 2 — Complete an ASHRAE Level 2 audit. A Level 2 audit is the core compliance requirement. Unlike a Level 1 walkthrough, a Level 2 involves a detailed site visit, comprehensive systems inventory, energy modeling, and a written report identifying specific Energy Conservation Measures (ECMs) with estimated implementation costs and projected savings. The audit establishes your gap to the ODOE-specified EUI target for your building type.

Phase 3 — Document your compliance pathway. You need to show ODOE a credible plan to meet your EUI target. For buildings already close to their target, this may be straightforward. For older buildings with significant gaps, the ECM roadmap from your Level 2 audit becomes the compliance documentation.

Energy Trust of Oregon provides incentives that can cover up to 50% of ASHRAE Level 2 audit costs for eligible buildings served by PGE or Pacific Power. Oregon City’s PGE service territory makes most commercial buildings here eligible to apply.

Common Energy Challenges in Oregon City Commercial Buildings

Oregon City’s commercial building stock has characteristics that drive elevated EUI and create compliance risk:

Older building vintage. A meaningful portion of Oregon City’s commercial inventory was built before modern energy codes took effect. Buildings from the 1970s and 1980s often have original single-pane or early double-pane glazing, undersized or poorly zoned HVAC systems, and no building automation or energy management controls. These buildings typically show the largest gap between current EUI and BPS targets.

Industrial energy intensity. For manufacturing and food processing facilities in Oregon City’s industrial zones, energy intensity is structurally higher than office or retail. The BPS EUI targets vary by building type, and industrial buildings will be benchmarked against industrial standards — but facilities with older process equipment, inefficient compressed air systems, or poor thermal envelope performance may still face compliance challenges.

Retail refrigeration loads. Grocery and food retail buildings in Oregon City — especially older stores — carry significant refrigeration loads that drive EUI above target. Refrigeration system upgrades are among the highest-impact ECMs for this building type, and Energy Trust incentives specifically target commercial refrigeration improvements.

How We Help Oregon City Building Owners

OregonBuildingCompliance.com provides two services for Oregon City commercial building owners navigating BPS compliance:

Service 1 — One-Time ASHRAE Level 2 Compliance Audit: We handle the full compliance audit from site visit through written report delivery. You get your EUI baseline, your gap analysis against the BPS target for your building type, and a prioritized ECM roadmap with cost and savings estimates. Flat fee — no hourly rates, no scope creep. This is the document you need to demonstrate compliance to ODOE.

Service 2 — Annual BPS Benchmarking: For buildings that need ongoing EUI tracking and annual ODOE reporting, we manage utility data collection, Portfolio Manager updates, year-over-year tracking, and regulatory communication on a recurring basis. Particularly useful for property managers handling multiple buildings or owners who don’t want to manage the annual compliance cycle internally.

We serve the Clackamas County commercial market and understand the building types, utility providers, and Energy Trust program specifics relevant to Oregon City properties.

Connecting Oregon City to the Broader South Metro

Oregon City sits at the southern edge of the Portland metro BPS compliance geography. Neighboring jurisdictions with significant BPS compliance activity include Lake Oswego to the north along I-205 and Portland to the northwest. Oregon City building owners can draw on the same Energy Trust programs, PGE utility data infrastructure, and ODOE compliance resources as buildings throughout the metro.

For more background on the Oregon BPS program, read our Oregon BPS overview and our guide to what an ASHRAE Level 2 audit includes. If you’re comparing Oregon’s program to Washington’s Clean Buildings Performance Standard, see our Oregon BPS vs Washington comparison.

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Oregon City building owners: the 2028 Tier 1 deadline is approaching. If you own a commercial building above 35,000 square feet in Clackamas County and haven’t started the compliance process, schedule your ASHRAE Level 2 audit now. Know your EUI, understand your gap, and have your compliance pathway documented before the deadline pressure builds.