Portland Climate and Health Standards: What the PROPOSED Rules Mean for Owners Before Dec. 1

5 days ago

6 min read

First, the most important sentence in this post: the Portland Climate and Health Standards are PROPOSED. They have not been adopted. Nothing in this post is a rule you have to follow today.

That said, if you own a building with four or more units in Portland, it helps to know what's on the table. Council is accepting public testimony while the item is pending. The ordinance, document number 2026-377, was introduced by Councilor Candace Avalos and heard in the Housing and Permitting Committee on Oct. 20, 2026. It was continued to Dec. 1, 2026.

Here's what the PROPOSED rules would do, who they'd cover, and how to comment if you choose to. We've read the full draft code (Exhibit A) so you don't have to, although we'd love it if you did.

What are the Portland Climate and Health Standards?

The PROPOSED ordinance would add a new Chapter 17.104 to Portland City Code. It combines a few ideas in one package: energy reporting for larger buildings, carbon reduction targets that step down to zero by 2050, a fee for buildings that miss their targets, and climate and health disclosures for rental housing, such as cooling and gas stove ventilation.

Again, all of this is PROPOSED. The details could change at the Dec. 1 meeting, or later, or the ordinance may not pass at all.

Who would be covered

Under the draft, a "covered building" is any commercial building or residential building with four or more dwelling units, including two or more buildings that share the same electric or gas meter or heating and cooling system. Condominiums are not covered, and neither are buildings predominantly used for industrial, manufacturing, parking, education, warehouse or worship purposes.

In practice, the PROPOSED rules have two tiers for rental owners:

All residential covered buildings, meaning four or more units of any size, would have the climate and health inventory and the tenant notice.
Buildings of at least 20,000 square feet would also have annual energy reporting and the carbon performance targets.

If you own a duplex or a single-family rental, this ordinance as drafted wouldn't apply to you. If you own a fourplex, you'd be in the first tier only.

For 4+ unit buildings: inventory and tenant notice

Climate and health inventory

By June 1, 2028, and every five years after, the owner of each residential covered building would submit an inventory to the city listing the building address, year built, number of rental units, number of units with owner-supplied air conditioning and the type of cooling, and number of units with natural gas stoves, plus whether owner-supplied stove ventilation goes outdoors. The city would notify owners of this duty by Dec. 31, 2027, but under the draft, a missed notice from the city doesn't excuse the owner.

Prospective tenant notice

Starting Jan. 1, 2028, owners would include climate and health information in rental application forms. That includes city-provided instructions on how to look up average and peak energy costs and bill assistance, whether the stove is electric or gas with city-provided health information, whether the stove hood vents outdoors, and what mechanical and passive cooling the unit has. The city would notify owners of this duty by Nov. 30, 2027.

and now a couple shameless plugs.

This is the kind of policy the Portland Area Rental Owners Association (PAROA) tracks for members, so you hear about PROPOSED rules early, with a plain summary of what they say.

And if paperwork like this is the last thing you want on your plate, Northwest Real Estate and Property Management (NWRPM) handles compliance tasks for owners across the Portland Metro area.

For 20,000+ sq ft buildings: reporting and carbon targets

The bigger changes would land on larger buildings. Under the draft, every covered building of at least 20,000 square feet would submit an annual energy report by June 1, 2028, and every June 1 after that. A city pilot with five multifamily properties found the first-year reporting took 3 to 9 hours of active time per building, with a median of 6, and participants estimated about two hours or less in later years.

PROPOSED Portland Climate and Health Standards carbon targets: 80, 60, 40, 20 and 0 percent of baseline from 2030 to 2050 — The PROPOSED step-down: each building's own baseline, cut 20 percentage points every five years to zero in 2050.

The carbon targets are building-specific. Each building's emissions for 2027 or 2028 would set its baseline, and the target would step down every five years:

2030: 80% of baseline
2035: 60% of baseline
2040: 40% of baseline
2045: 20% of baseline
2050: zero carbon emissions

Before each compliance deadline, a qualified person other than whoever prepared the annual report would verify the building's data.

The carbon pollution impact fee

A building that misses its target would pay a carbon pollution impact fee. Under the draft, it's calculated by multiplying the building's emissions above its target for five years by the cost of carbon, which is set at $380 per metric ton of CO2e per year for the first interim standard in 2030. After that, the city administrator would determine the price, it would be reviewed at least every five years and approved by Council, and it couldn't drop below the previous level.

Fees would go into a dedicated fund used only to support compliance, with administrative costs capped at 7%. There's also an Alternate Compliance Plan option for owners of campus portfolios with shared utility services.

Exemptions and the no-pass-through rule

Some parts of the draft matter a lot to rental owners:

Regulated affordable housing would be exempt from the carbon targets and the fee.
The city administrator could grant extensions or one-year exemptions for specific situations, such as a demolition permit issued within three years of a compliance deadline, or utility data that isn't available despite good-faith efforts.
Costs associated with the carbon performance standards, including retrofits and the fee, could not be passed through to residential tenants.

For rental owners, this is one of the provisions with the most direct budget impact: under the PROPOSED language, an owner couldn't recover retrofit costs or fees from residential tenants.

Tenant displacement plans

If upgrades to meet a target would make a unit unsafe or unfit to occupy and require a residential tenant to relocate overnight, the draft would require the owner to give the city a contractor-signed description of the project and alternatives, plus a tenant impact plan. That plan would include advance payment for temporary housing, moving and storage help where belongings must be moved, transportation help in some cases, and a written right to return to the same unit. If upgrades would require relocating a tenant for more than ten days, or ending a tenancy, the city could instead let the owner pay the fee rather than do the upgrades.

Penalties and records

A first violation would get a written warning.
Later violations of the reporting, records, inventory, tenant notice and displacement sections could bring civil penalties of up to $100 per day.
Later violations of the carbon target, verification, alternate compliance or fee sections could bring civil penalties of up to $1,000 per day.
An owner would have 15 calendar days after a notice to pay or request an appeal.
Owners would keep reported information for at least three years and make it available for city audit.

What small owners should do now

If you own a 4+ unit building under 20,000 square feet, the PROPOSED duties are mostly about knowing your building: what cooling each unit has, whether the stoves are gas or electric, and whether the hoods vent outdoors. It doesn't hurt to start a simple list now. If you own a larger building, talk with your property manager, accountant or energy professional about what your 2027 and 2028 energy use might look like. Anyone who wants to comment, whether owner, manager or tenant, can use the Council Clerk's testimony process described below.

How to comment or testify before Dec. 1

Portland accepts public testimony on Council items. You can register to testify on this ordinance or read and submit written testimony. The Council Clerk's pages explain the format and deadlines. Testimony typically says who you are (owner, manager or tenant), which building type you're describing, and which sections of the PROPOSED code you're addressing.

For more on Portland and state policy that affects rental owners, see our Portland tenant protection laws study and our 2026 legislative session wrap-up.

and now a couple shameless plugs.

PAROA members get landlord forms, education and updates on proposals like this one before they become rules.

Own a Portland Metro rental and want someone else watching the details? NWRPM offers full management for owners who'd rather not read lengthy draft codes on a Sunday.

The bottom line

The Portland Climate and Health Standards are PROPOSED, not adopted. As drafted, every 4+ unit building would have an inventory and tenant notice duty starting in 2028, and buildings of 20,000+ square feet would also have annual energy reporting starting in 2028 and carbon targets starting in 2030, with a fee for missing them and no pass-through to tenants. The next step is the Dec. 1 meeting. The Council Clerk's testimony pages explain how and when to submit comments.

This post is general information, not legal advice. Details of the PROPOSED ordinance may change before any vote.