Do I need a Qualified Energy Manager for Tier 2?
Yes. Every Tier 2 filing needs a Qualified Energy Manager (QEM) to sign Form A in the Clean Buildings Portal, confirming that your Operations and Maintenance Program meets Section 6 of the standard and that your Energy Management Plan has been developed. The QEM also sets your building's energy-use target on Form B. Nothing else in the Tier 2 process needs a credential: the owner can benchmark, draft, upload and submit.
Who counts as a QEM
A QEM is "an individual designated by the building owner" who meets one of these:
| Path | Requirements |
|---|---|
| Experience | Completed Commerce's Tier 2 training and has two or more years of educational or professional experience in commercial building operations or building energy management |
| BOC Level I | Completed Commerce's Tier 2 training and holds Building Operator Certification Level I |
| Fellowship | Completed Commerce's Tier 2 training and worked full time for at least six months under a QEM, Qualified Person or Qualified Energy Auditor, producing a successful compliance application together |
| Qualified Person | Three years' professional experience in building energy-use analysis plus a listed credential (Washington-licensed engineer or architect, BOC Level II, Certified Energy Manager, and others). No Tier 2 course needed. |
What changed in August 2026. Before the rule change, BOC Level I on its own was enough. Now Commerce's training is required on every path except Qualified Person. If you read older guides that say otherwise, they are out of date.
Your own staff can be the QEM
The rule says "designated by the building owner" and does not require the QEM to be independent. A facilities lead, maintenance supervisor, property manager with hands-on building experience, or a church's long-serving building steward often has two years of relevant experience already. Form A has separate lines for "energy manager" and "QEM", and one person can fill both.
The training is free
Commerce's Tier 2 training is delivered by the Smart Buildings Center at no charge: one day in person, or two half-days online, with recordings available on demand. Recent and upcoming dates include live online sessions in October 2026, an in-person day in Spokane on 7 December 2026, and an online pair on 13–14 January 2027. Check the Smart Buildings Center page for the current schedule. There is no exam described; completing the course and meeting the experience requirement is what qualifies you.
If nobody on your team qualifies
- Check again. Two years of building-operations experience is a lower bar than it sounds. A maintenance contractor you already use may qualify and be willing to take the course.
- Hire a QEM for the review only. Commerce links a self-reported QEM directory. With documents already drafted, you are asking for a review and a signature, not a project, so ask for a fixed fee. How to find and brief a QEM has the brief to send.
What the QEM actually signs
Form A carries the statement "We state that this building complies with ANSI/ASHRAE/IES Standard 100 as amended by the AHJ to conform with RCW 19.27A.210", with yes/no answers on whether the Section 5 (EMP) and Section 6 (O&M) requirements have been met. The QEM is confirming that the O&M Program is developed and implemented, so they will want to see maintenance records, not just a plan. The kit's 12-month implementation log exists for exactly that reason.
Ready to see where your building stands? Run the free checker, or get the kit.