Guidance for Manufacturing, Agricultural, and Industrial Buildings

There is no "one-size-fits-all" approach, as the pathways and metrics for the MAI Alternate Compliance Option were designed to be customizable to your individual building. However, the guiding questions below might help you choose the most appropriate pathway and metric combination. More than one pathway or metric might make sense for you and your building, but you can only choose one!

Have you made any energy efficiency upgrades to your building yet?

If you don't know where to begin or have not made any energy efficiency upgrades in your building yet, the Prescriptive Pathway might be the best option for you. The Prescriptive Pathway requires you to receive an energy audit and devise an Action Plan. You then follow your Action Plan step-by-step and submit it to us along with other required documentation by the set deadlines. 

If you have already made investments and energy efficiency upgrades in your building (such as lighting upgrades, compressed air leaks, or others) OR if you have plans to make further investments in your building energy efficiency (such as replacing your HVAC system), you may want to choose the Performance Pathway. This is particularly true if you have already seen or will see energy savings reflected in your energy bills or production processes and don't want to go through the reporting requirements for the Prescriptive Pathway.

While the Prescriptive Pathway requires you to receive an energy audit, we recommend that you get one regardless of the compliance pathway you have chosen. Your energy auditor can work with you to help identify the best metric for you to choose for your compliance pathway, along with action items to help you reach your goal. 

Do you expect to expand your production over time?

If you expect to expand your production over time, there is a good chance that your production efficiency will increase (meaning that you are using less energy per widget you produce). That means that the 30% Production Efficiency Improvement metric is likely to be a good choice for you. This metric is available to you in both the Prescriptive Pathway and the Performance Pathway. 

In both cases, you are able to measure production efficiency in terms of energy used per widget produced OR energy per some other custom metric. If you choose a custom metric, you will need to get approval from the Office of Climate Action, Sustainability and Resiliency for your metric when you submit your MAI Alternate Compliance Option application. 

If you use the production efficiency metric in the Prescriptive Pathway, you will work with your energy auditor to create a step-by-step action plan to achieve your 30% Production Efficiency Improvement. If you choose this metric for the Performance Pathway, you will demonstrate improvements through annual benchmarking reports. 

Is your building eligible for an EPA Plant EPI Score?

If your building is eligible for an EPA Plant EPI Score, then your best compliance pathway might be the Performance Pathway using the EPI Score of 75 metric. You can check EPA's ENERGY STAR Plant website to see if your building is one of the eligible plant types. You will need to know your North American Industry Classification System (NAICS) code to look up your building type. If you do not know your NAICS code, you can check your OSHA 300A form or call the NAICS hotline. 

If you are eligible for an EPI Score, fill out the corresponding EPI spreadsheet to see where your score is right now, with a goal to reach a score of 75 by 2030. The higher your score is, the more efficient your building is. If your EPI score is already higher than 75, then you have already met your 2030 goal!

What is your building's current Energy Use Intensity (EUI)?

Energy Use Intensity (EUI) measures the energy used per square foot of area in your building. The lower your EUI score, the more efficient your building is (the opposite of EPI score). If your current EUI is lower than 43, then you might want to pursue the Performance Pathway using the EUI Score of 30 metric. You would be welcome to implement whatever methods you would like to improve energy efficiency in your building, thereby lowering your EUI. You would verify these improvements through annual benchmarking reports. 

Do none of these other metrics sound like the right fit?

If none of the above metrics sound like the right fit, or if you have already seen some improvements to energy efficiency in your building, you are likely to benefit from pursuing the 30% EUI Reduction metric. You are able to use this metric in either the Prescriptive Pathway or the Performance Pathway. 

If you use this metric with the Prescriptive Pathway, you will work with your energy auditor to create a step-by-step plan to reduce your EUI by 30% by 2030. It is important to note that you can get credit for energy efficiency measures that you have already implemented. For example, if you implemented an upgrade to your building in 2021 that reduced your EUI by 10% (as shown through benchmarking data from that year and the following year), your Action Plan could be to reduce your EUI by a further 20%.

If you use this metric with the Performance Pathway, you would implement any measures you would like to get to a 30% reduction in EUI over your baseline year. You will verify these improvements through annual benchmarking reports. 

The Energize Denver Rules and Regulations outline the minimum requirements for energy audits. You will need to ensure that your energy audit:

• Is submitted with your MAI Alternate Compliance Option application. You are NOT required to submit your energy audit through the online Denver Audit Template tool. 
• Has a baseline year between 2018 and 2022. Since 2022 is the first year that MAI buildings are required to submit a benchmarking report, this is the default year. 
  • You can choose another year between 2018 and 2022 as your baseline year as long as you have benchmarking data on file with Denver's Office of Climate Action, Sustainability and Resiliency for that and subsequent years
• Uses Weather Normalized Site EUI data for the baseline data
  • You can use Site EUI data if you are not able to find weather-normalized data
• Is completed on or after July 1, 2023
  • We can accept audits completed between January 1, 2017 and July 1, 2023 as long as the audit is updated to include the minimum requirements needed for the Prescriptive Pathway
• Includes the following Investment Analysis information:
  • Cost for each individual measure
  • Estimated site EUI savings and/or production efficiency improvement for each individual measure
  • Savings to investment ratio calculations for each individual measure
  • Return on investment calculations for each individual measure
  • Total project cost
  • Estimated site EUI savings and/or production efficiency improvement for the total project
  • Savings to investment ratio calculations for the total project
  • Return on investment calculations for the total project
• Evaluate both electric and fossil fuel systems in the building.
  • If the chosen energy audit program does not include an evaluation of fossil fuel systems, we encouraged you to pay for the additional evaluation

Although it is not required for compliance, we encourage you to pursue a design step with a building engineer after you have completed your energy audit, but before you submit your Action Plan. This will allow you to further evaluate the estimated energy savings or efficiency improvements that you will achieve from each measure recommended by the energy auditor. 

Finding the right person for your energy audit can be hard, but a good auditor will help you set the right goals and create a manageable Action Plan. Check out this guide to finding a qualified vendor, so that you can write a good scope of work, identify the qualifications that matter, and hire the right person to get the job done. You will need to choose an energy auditor who:

• Is licensed and insured to work in the State of Colorado
• Has one of the following credentials:
  • Professional Engineer (licensed in the United States)
  • Certified Energy Auditor (Association of Energy Engineers)
  • Certified Energy Manager (Association of Energy Engineers)
  • Building Energy Assessment Professional (ASHRAE)
  • High-Performance Building Design Professional (ASHRAE)
• Is a third-party individual or company who is not employed by the organization that owns or operates the building
• Has the ability to process Xcel Energy rebates and other rebates or incentives on your behalf, or who can coach you through processing rebates
• Has direct experience with performing energy audits at manufacturing, agricultural, or industrial buildings
• Understands how to document energy efficiency improvements that you have already implemented in your building
• Is able to inform you on extra-scope items that may be helpful to evaluate, along with the cost associated with that evaluation
• Has taken Denver's MAI Energy Auditor Training and has passed the comprehension test at the end - see the Energize Denver Directory of Service Providers to see who has completed the training
  • If you have a preferred energy auditor that you would like to use, please encourage them to complete the training so that they can be included in the Directory of Service Providers before completing your energy audit

There are several pieces of equipment that are common features in most commercial buildings. However, there are other items that are more unique to MAI buildings. Both the common building items and the MAI-specific items typically consume significant amounts of energy. You should ensure that your energy auditor looks for these items (noting their presence or not), and takes note of their approximate age, installation date, and quality. Common commercial building equipment includes:

• Lighting - note whether it is LED lighting or another type
• Heating, ventilation, and air conditioning (HVAC equipment)
• Boiler insulation and steam traps
• Motors

MAI Building-specific items include:

• Industrial motors
• Compressed air systems
• Process loads/manufacturing equipment and machinery
• Cold storage, including industrial refrigeration

There are a lot of building upgrade opportunities that your energy auditor can look for during your audit. Common commercial building opportunities include:

• Electrification, such as converting your furnace, air conditioner, or rooftop unit to a heat pump - we offer rebates to reduce the cost of doing this
• Decentralizing hard-to-electrify systems, such as converting a central boiler to a series of smaller, electric boilers
• HVAC efficiency improvements, such as radiant heating and direct evaporative cooling
• On-site renewables
• Energy management systems (EMS), holistic EMS, light sensors, lighting controls, or building automation systems (BAS)
• Retro-commissioning (RCx) or re-tuning programs. See resources on this from
  • California Commissioning Collaborative
  • ENERGY STAR
  • California Energy Commission
  • City of Philadelphia
• Combined heat and power (CHP) systems
• Efficient hydrogen fuel cells for power generation
• Building envelop/energy curtains

MAI-specific upgrade opportunities include:

• Compressed air upgrades/leak fixes
  • Xcel Energy’s Compressed Air Efficiency program offers compressed air system studies and rebates to improve your systems.
• Waste process heat recovery systems
• Converting gas-fired systems to infrared and/or induction heating systems
• High-efficiency dehumidifiers
• Variable Frequency Drives (VFDs) or variable speed motors
• Cold storage insulation, thermal assisted refrigeration or temperature/ammonia leak detection and management
• Innovative energy efficiency technology

You will benefit from working with an energy auditor who has experience with MAI processes. Finding the right auditor can take a lot of work, but an experienced energy auditor can provide a wealth of energy and cost savings opportunities for your building.

We developed the Prescriptive Pathway to allow you to customize your performance goals based on your individual building. You may have already made investments into energy efficiency in your building, and we want you to be able to get credit for those upgrades in your action plan. We can only account for upgrades made to your building since 2018.

In order to get credit for previous upgrades, you will need to submit documentation of these upgrades along with your Action Plan. The documentation needs to indicate

• The energy investment you made in the building
• The type of investment it was
• The date of the equipment installation
• The actual energy savings (based on benchmarking data) achieved through these investments. 

You will have to retroactively benchmark to the year prior to when you made these energy efficiency investments, if the benchmarking data is not already on file with the city. You should normalize the energy savings to your chosen metric (either EUI or production efficiency). Any verified energy efficiency upgrades will be applied to your Action Plan to meet your chosen metric. For example, if you installed a new boiler in 2020, and it resulted in a 10% production efficiency improvement (based on benchmarking data), your Action Plan would only have to outline how you will achieve an additional 20% production efficiency improvement by the final performance year.

If your building is in this situation, we recommend that you contact our Industrial Administrator to discuss the investments and, if approved, how this will affect your interim and final targets. 

Along with your completed energy audit report, you are also required to submit an Action Plan as part of your MAI Alternate Compliance Option application. You should work with your energy auditor, an energy engineer, or independently to create your Action Plan after you have finished the energy audit. Your Action Plan will document what recommendations you will implement by the interim implementation year (2026) and the final implementation year (2029) of the compliance period. Your Action Plan must include the following:

• What improvements and upgrades have you already implemented in your building?
  • The Action Plan may reflect any energy efficiency upgrades you have made in your building since 2018. 
  • Include as much detail as possible including:
    • What was installed or replaced
    • When the installation happened
    • Energy savings achieved by the installation
    • Equipment specifications
    • Installation invoices
• What Improvements and upgrades are you going to perform to achieve your 2026 and 2029 targets ahead of the 2030 monitoring year?
  • You may include the Renewable Credit and the Fossil Fuel Reduction Credit as part of your Action Plan, particularly if the energy audit recommendations will not achieve enough improvement on your chosen metric
  • You should include the expected Site EUI or production efficiency improvement for each upgrade in table format
  • You should include the expected completion date of each upgrade in table format
    • Upgrades for the interim target must be installed by the end of 2026
    • Upgrades for the final target must be installed by the end of 2029
• What is the total expected savings from all of the improvements and upgrades you are planning?
• What is your Milestone Reporting Plan?
  • You must acknowledge the program deadlines and the required reports as part of your Action Plan

Your energy audit and finalized Action Plan are due to the Office of Climate Action, Sustainability and Resiliency by December 1, 2024. You may request an extension on this deadline any time before December 1, 2024. However, your target dates will remain unchanged.

If you cannot complete an item in your approved Action Plan, or if you want to change the Action Plan after it is submitted, you must contact Denver's Office of Climate Action, Sustainability and Resiliency and indicate:

• Which measure(s) cannot be completed
• A reason for your inability to complete the measure
• An explanation for why you cannot apply for a timeline adjustment in order to complete the measure at a date after the performance period

We will work with you to adjust the Action Plan accordingly, if applicable. 

Once your Action Plan has been approved and your building improvements are underway, you will have several other reporting requirements in addition the annual benchmarking report. One of the key reports are your Implementation Reports. You will send two of these - an interim report in 2027 and a final one in 2030.

The interim and final implementation reports are meant to be a verification that the items described in your Action Plan were completed on time and as specified. The reports should contain:

• Documentation proving that you performed the items listed in your Action Plan, including specifics on what was installed, when, and by whom. You can prove these items by including invoices, model numbers, and other documentation.
• Information on whether everything in the Action Plan was implemented as described or if there were any deviations from the Action Plan. If there were deviations, we will need details about why it happened, when the deviations occurred, and whether the Action Plan now needs to be amended or updated.
• A signed acknowledgement that indicates that the items in the Action Plan were completed as described and by the required deadline.

These reports are your opportunity to communicate challenges and, if necessary, work with us to adjust your Action Plan. Of course, it is best for you to communicate any barriers or challenges as soon as possible, but the implementation report is a great way to document those challenges in a formal way.

Deadlines for the Implementation Reports are as follows:

• The interim Implementation Report is due by March 1, 2027. You will be reporting on if and how you have reached 50% of your estimated savings goal by completing the first half of your Action Plan. You must submit this interim Implementation Report to confirm the successful implementation of the first half of your Action Plan.
• The final Implementation Report is due by March 1, 2030. You must complete your Action Plan by the end of 2029 so that you can show compliance for the final performance year in 2030. You must complete this final Implementation Report to confirm that you have completed all items on your Action Plan and that you have achieved your final savings goals.

Templates for these Implementation Reports have not been created yet, but we expect to have them available to you by mid-2025. We will review the types of Action Plans that are submitted by buildings participating in the Prescriptive Pathway and determine a template that will best suit these Action Plans. 

The EMV report allows you to assess and verify the actual performance of the energy efficiency investments you made in the building against the predicted savings they would achieve. The EMV report requires you to calculate the actual savings you achieved between the baseline year and the final performance year, as indicated in your benchmarking reports.

You must complete and submit your Evaluation, Monitoring, and Verification Report by June 1, 2031, at the same time as your annual benchmarking submission. 

Based on your completed Action Plan, you should see a 30% savings in your chosen metric. If the Evaluation, Monitoring, and Verification Report and the 2030 benchmarking data show less than a 20% actual savings after taking advantage of the Fossil Fuel Reduction Credit and the Renewables Credit (if applicable), you will have to complete a Corrective Action Plan. 

We will be providing a template for this report at a later date closer to 2030.

The CAP is intended to explain why there is a gap between the predicted savings and the actual savings achieved by your building investments and upgrades. It is also used to ensure that new equipment in the building was commissioned correctly and is being operated as intended. An effective CAP identifies the root cause of problems and prevents their recurrence with rigorous documentation.

The CAP is also an opportunity to improve operations and maintenance (O&M) procedures in the building. Proper O&M allows you maximize building performance. Examples of Operations and Maintenance include:

• Retro-commissioning
• Returning
• Addressing reactive/proactive/predictive maintenance
• Continuous improvement models
• Staff training
• Green leasing practices
• Improving your building automation system

A completed CAP will be due on June 1, 2032 if it is needed, at the same time as your annual benchmarking report.

A template for the CAP will be available at a later date.

If you own an agricultural building and your Action Plan includes installing new grow lights, you must ensure that all grow lights are Design Lights Consortium (DLC)-listed horticultural grow lights, to ensure a minimum photosynthetic photon efficacy (PPE) of 1.9 micromoles per joule (μMol/J). The term “photosynthetic photon efficacy (PPE)” is an industry-accepted metric for horticultural lighting efficacy. 

The 2022 Denver Building and Fire Code, Section C403.15 stipulates dehumidification and cooling efficiency requirements and Section C405.4 stipulates minimum lighting requirements for plant growth and maintenance.

If you are pursuing either the Prescriptive Pathway or the Performance Pathway using the Production Efficiency metric, you will have to enter annual production data on your chosen metric when you submit your annual benchmarking report through ENERGY STAR Portfolio Manager (ESPM). To do so, follow these steps:

First, you will need to enter your custom metric data for the year. Go to the "Details" tab in ESPM and locate the "Entire Property Use" line:

Under the "Action" column, click on the "I want to..." drop-down menu and choose "Edit Use Details":

This will take you to a page where you can "Edit Use Details for Entire Property." Make sure that "Custom Use Detail 1" is where you enter the name and data for your custom metric. In this example, we used "Number of loaves of Bread Baked Annually" for a bread manufacturer. You can leave the "Units" blank or choose "Other" if you wish to define the units yourself.

If this is your first time benchmarking a custom metric, your "Current As Of" date should start with January 1 of the given benchmarking year. For example, if you are reporting 2022 dating in 2023, your "Current As Of" date should be January 1, 2022. The "Value" represents the total number of widgets produced in that calendar year. In this example, 1,000 loaves of bread were produced by our bakery between January 1, 2022 and December 31, 2022. Please note! The value you enter should be for the entire calendar year - no more and no less. The "(to present)" should be interpreted as December 31 of your benchmarking year (2022 in this example).

In your second year of benchmarking (in this example, 2023 data being reported in 2024), you will click "Add a New Row" and change the "Current As Of" date to January 1 of the new benchmarking year (in this example, 2023). You will notice that the previous year now has an end date, as demonstrated by the note that says "(through 12/31/2022)." Now add the total number of widgets produced for the new calendar year. In this example, our bakery increased its production to 1,100 loaves for 2023.

You will follow this process every year that you submit a benchmarking report for the given metric. You can also retroactively report your custom metric for previous years, back to your chosen baseline year. In this example, the bakery chose 2020 as its baseline year, so it back-reported data to 2020 by adding a new row for each benchmarking year:

Note: if you are reporting more than one custom metric, you can add your second metric in "Custom Use Detail 2" following the same methodology.

Click "Save" when you are finished to return to the ESPM homepage.

Next, you will need to calculate your production efficiency. Go to the "Summary" tab in ESPM and locate the "Custom Metrics" section. Click on the blue pen icon next to Custom Metrics:

Now, create your custom metric. Make sure to use "Custom Metric 1" to ensure your data is accurately reported. Unless otherwise agreed upon with the Office of Climate Action, Sustainability and Resiliency, your custom metric should be "Weather Normalized Site Energy Use (kBtu)" per your chosen metric. A "Name" will be auto-generated. You can change the name if you like.

Click "Save" and you will now see your custom metric on the Summary Page:

To see how your custom metric compares from your baseline year to your current year, you will need to add the custom metric to the Metrics Summary table. Click on "Change Metrics":

A box titled "Select Information and Metrics" will pop up. Make sure to select the following metrics:

• Property Information Tab
  • Custom Metric 1 - Name
  • Custom Metric 1 - Value
• Property Use Details tab
  • Custom Metric #1 - Name
  • Custom Metric #1 - Value

Please note that currently, you are only allowed to select up to seven metrics, so you may have to deselect some metrics in order to see the custom metric. Do not deselect Site EUI (kBtu/ft²).

Click "Apply Selection" to see your metrics on your Summary Page:

You can now see your custom Production Efficiency value in the "Custom Metric 1 - Value" row in the Metrics Summary table. The value in the "Change" column shows your Production Efficiency Improvement from the baseline year to the current benchmarking year. In this example, the bakery achieved a Production Efficiency Improvement of 35.4% from 2017 to 2019.

Section 2.4.3 (Data Verification) of the Energize Denver Technical Guidance for Buildings 25,000 Square Feet and Larger provides detailed instructions on the data verification process. For MAI Buildings, the benchmarking reports submitted for performance years (2026 and 2030) will require third party data verification. A Sample Data Verification Checklist is available, or you can generate one on the Reports tab within ENERGY STAR Portfolio Manager.

Certain metric options for MAI Buildings require you to submit additional data in addition to the annual benchmarking report. This including buildings following:

• Prescriptive Pathway, Production Efficiency Improvement metric
• Performance Pathway, Production Efficiency Improvement metric
• Performance Pathway, EPI Score metric

For the Production Efficiency metric, the data chosen for your production metric(s) must be reported in ENERGY STAR Portfolio Manger. In addition, you must provide production data to the data verifier for the chosen production metric(s). The verification of production metric(s) data should be included in the notes section in the "Summary of All Associated Metrics" section of the Data Verification Checklist.

For the EPI Score metric, you must provide the EPI spreadsheet and any other supporting documentation for information that goes into the spreadsheet to the data verifier. Other supporting documentation should include production data that are required inputs for the given EPI spreadsheet. 

If you are pursuing either the Prescriptive Pathway or the Performance Pathway using the Production Efficiency metric, you will have to enter annual production data on your chosen metric when you submit your annual benchmarking report through ENERGY STAR® Portfolio Manager (ESPM). To do so, follow these steps:

First, you will need to enter your custom metric data for the year. Go to the "Details" tab in ESPM and locate the "Entire Property Use" line:

Under the "Action" column, click on the "I want to..." drop-down menu and choose "Edit Use Details":

This will take you to a page where you can "Edit Use Details for Entire Property." Make sure that "Custom Use Detail 1" is where you enter the name and data for your custom metric. In this example, we used "Number of loaves of Bread Baked Annually" for a bread manufacturer. You can leave the "Units" blank or choose "Other" if you wish to define the units yourself.

If this is your first time benchmarking a custom metric, your "Current As Of" date should start with January 1 of the given benchmarking year. For example, if you are reporting 2022 dating in 2023, your "Current As Of" date should be January 1, 2022. The "Value" represents the total number of widgets produced in that calendar year. In this example, 1,000 loaves of bread were produced by our bakery between January 1, 2022 and December 31, 2022. Please note! The value you enter should be for the entire calendar year - no more and no less. The "(to present)" should be interpreted as December 31 of your benchmarking year (2022 in this example).

In your second year of benchmarking (in this example, 2023 data being reported in 2024), you will click "Add a New Row" and change the "Current As Of" date to January 1 of the new benchmarking year (in this example, 2023). You will notice that the previous year now has an end date, as demonstrated by the note that says "(through 12/31/2022)." Now add the total number of widgets produced for the new calendar year. In this example, our bakery increased its production to 1,100 loaves for 2023.

You will follow this process every year that you submit a benchmarking report for the given metric. You can also retroactively report your custom metric for previous years, back to your chosen baseline year. In this example, the bakery chose 2020 as its baseline year, so it back-reported data to 2020 by adding a new row for each benchmarking year:

Note: if you are reporting more than one custom metric, you can add your second metric in "Custom Use Detail 2" following the same methodology.

Click "Save" when you are finished to return to the ESPM homepage.

Next, you will need to calculate your production efficiency. Go to the "Summary" tab in ESPM and locate the "Custom Metrics section. Click on the blue pen icon next to Custom Metrics:

Now, create your custom metric. Make sure to use "Custom Metric 1" to ensure your data is accurately reported. Unless otherwise agreed upon with the Office of Climate Action, Sustainability and Resiliency, your custom metric should be "Weather Normalized Site Energy Use (kBtu)" per your chosen metric. A "Name" will be auto-generated. You can change the name if you like.

Click "Save" and you will now see your custom metric on the Summary Page:

To see how your custom metric compares from your baseline year to your current year, you will need to add the custom metric to the Metrics Summary table. Click on "Change Metrics":

A box titled "Select Information and Metrics" will pop up. Make sure to select the following metrics:

• Property Information Tab
  • Custom Metric 1 - Name
  • Custom Metric 1 - Value
• Property Use Details tab
  • Custom Metric #1 - Name
  • Custom Metric #1 - Value

Please note that currently, you are only allowed to select up to seven metrics, so you may have to deselect some metrics in order to see the custom metric. Do not deselect Site EUI (kBtu/ft²).

Click "Apply Selection" to see your metrics on your Summary Page:

You can now see your custom Production Efficiency value in the "Custom Metric 1 - Value" row in the Metrics Summary table. The value in the "Change" column shows your Production Efficiency Improvement from the baseline year to the current benchmarking year. In this example, the bakery achieved a Production Efficiency Improvement of 35.4% from 2017 to 2019.

Section 2.4.3 (Data Verification) of the Energize Denver Technical Guidance for Buildings 25,000 Square Feet and Larger provides detailed instructions on the data verification process. For MAI Buildings, the benchmarking reports submitted for performance years (2026 and 2030) will require third party data verification. A Sample Data Verification Checklist is available, or you can generate one on the Reports dab within ENERGY STAR Portfolio Manager.

Certain metric options for MAI Buildings require you to submit additional data in addition to the annual benchmarking report. This including buildings following:

• Prescriptive Pathway, Production Efficiency Improvement metric
• Performance Pathway, Production Efficiency Improvement metric
• Performance Pathway, EPI Score metric

For the Production Efficiency metric, the data chosen for your production metric(s) must be reported in ENERGY STAR Portfolio Manger. In addition, you must provide production data to the data verifier for the chosen production metric(s). The verification of production metric(s) data should be included in the notes section in the "Summary of All Associated Metrics" section of the Data Verification Checklist.

For the EPI Score metric, you must provide the EPI spreadsheet and any other supporting documentation for information that goes into the spreadsheet to the data verifier. Other supporting documentation should include production data that are required inputs for the given EPI spreadsheet. 

A 2021 study reported that growing one ounce of cannabis in Denver can emit over 249 pounds of carbon dioxide. This means the cannabis industry can play a huge role in reducing Denver’s emissions.  

Action does not need to be complex. For example, traditional lighting and HVAC systems can account for 45% of a facility's costs. A simple swap, like installing high-efficiency LED use less energy and reduce the need for ventilation. On top of saving up to saving energy, this swap will save your business money as well.  

Other resources are available to help the cannabis industry reduce their energy use:  

• The Colorado Department of Public Health and the Environment's has tips on greening the cannabis industry
• The National Cannabis Industry Association 2020 report discusses environmental best practices
• The Resource Innovation Institute's LED lighting report gives more information about the benefits of swapping traditional grow lights for LEDs.
• CSWG and their 2022 Cannabis Environmental Best Management Practices Guide

• 2020 McKinsey article on what electrification can do for industry
• 2021 Global Efficiency Intelligence report on electrification, including sector-specific electrification analyses
• 2020 Deloitte article which includes examples of certain industries/companies that are already electrifying
• 2018 US Department of Energy report on the electrification of buildings and industry

In your annual benchmarking report, be sure to break down your building use types as accurately as possible by square footage. For example, consider a 100,000 sq. ft. building that is:

• 50% manufacturing
• 40% warehouse
• 10% office

This building should benchmark as follows:

• 50,000 sq. ft. as a Manufacturing/Industrial Plant
• 40,000 sq. ft. as a Non-Refrigerated Warehouse
• 10,000 sq. ft. as an Office

If you are going to use the MAI Alternate Compliance Option, you must benchmark at least one of the approved MAI property types:

• Manufacturing/Industrial Plant (agricultural buildings should use this building type)
• Data Center (Class A data centers have >15% of the GFA in the building benchmarked as a Data Center)
• Drinking Water Treatment and Distribution Plant
• Wastewater Treatment Plant
• Energy/Power Station
• Other-Utility

Prior to 2023, MAI buildings were eligible for a benchmarking exemption. The first year of required benchmarking for MAI buildings is 2023, which reports on the 2022 energy use data. Because of this, the default baseline year for MAI buildings is 2022. However, the Energize Denver Ordinance calls for 2019 to be used as the baseline year, and commercial buildings may use 2018 as a baseline year if 2019 was an abnormal year. Therefore, MAI buildings may choose any baseline year from 2018 to 2022 for their performance requirements, as long as there is benchmarking data for that baseline year and all subsequent years on file with the city.

Simply fill out theMAI Designation Formand submit it to the city to designate your building as an MAI building (if approved).

Applying for the MAI designation allows the Office of Climate Action, Sustainability and Resiliency to collect information about the MAI operations conducted in your building. The MAI designation also allows you to benchmark your building as an MAI building and apply for the MAI Alternate Compliance Option.

Applying for the MAI Alternate Compliance Option allows you to follow one of the compliance pathways designed specifically for MAI buildings. Filling out the application tells us which pathway and metric you wish to pursue for your performance requirements. Having your plan and application on file with the city means that you now have a plan to achieve your 2030 performance target!

If you benchmark as an MAI property type but do not apply for MAI designation, you will be automatically switched the "Other" property type and assigned an 2030 EUI target of 49.2. If you receive MAI designation, but do not apply for the MAI Alternate Compliance Option, you will not have the option of using the compliance pathways and metrics that are more suited to manufacturing processes. Instead, you will be assigned to the 30% EUI Reduction metric on the Performance Pathway.

It all depends on what makes the most sense for your building and operations. You may want a step-by-step prescriptive process and the security of knowing that if you complete each step, you will meet your performance target. If this is the case, the Prescriptive Pathway is your best choice. However, you may want a less intensive planning process, and the freedom to explore different ways to get to your target metric by 2030. In this case, you should choose the Performance Pathway.

There is no one-size-fits-all for this question. Similarly to choosing your compliance pathway, the best metric for you will depend on your building, operations, previous investments, and future plans. For example, if you plan to increase your production over time, you may opt for the Production Efficiency metric or the EPI Score metric. However, if you have already made investments in energy efficiency, you may find that one of the metrics based on your EUI are best suited to your success.

For buildings that produce a standard product(s), especially if you plan to expand that production over time, the Production Efficiency metric might make the most sense for you. It allows you to normalize your site energy usage to a product you are producing instead of the size of your building. Similarly, the EPI Score metric would take production efficiency into account, if a relevant EPI exists for your plant type.

For the Performance Pathway, you will need to prove that you met your performance target with 12 calendar-months of benchmarking data. So, you will need to complete your investments or upgrades by the end of the preceding year (for example, you should finish your upgrades by December 31, 2025 in order to show compliance with your 2026 target). 

For the Prescriptive Pathway, the investments need to be completed by the end of the performance year (for example, upgrades being used to meet your 2026 target need to be completed by December 31, 2026). You will then need to document these upgrades in the corresponding Implementation Report.

Buildings that do not achieve their energy performance targets could be subject to penalties based on how far away the energy performance is from their target. 

If you are pursuing the Prescriptive Pathway, but do not comply with the requirements set out in that pathway, you will be automatically switched to the 30% EUI Reduction Performance Pathway and the penalized based on how far away your performance is from this performance target.

There are three buildings programs managed by the State of Colorado that may apply to some buildings in Denver.

The Colorado Building Performance Standards (BPS) requires benchmarking for 50,000 sq. ft. and larger via Building Performance Colorado. This requirement came to pass through House Bill 21-1286. As an MAI building that is 50,000 square feet or larger, you may have to comply with the State's benchmarking program. Please visit the Building Performance Colorado website to learn more about these requirements, or reach out to the Building Performance Colorado Help Center at benchmarking@buildingperformanceco.com.

The Greenhouse Gas Emissions and Energy Management for Manufacturing (GEMM) Phase I and Phase II stipulates greenhouse gas reductions and limitations for large industrial emitters. However, as of 2023, no facilities in the City and County of Denver are covered under GEMM I or GEMM II rules. The current cut-off for GEMM is a facility with direct greenhouse gas emissions at or above 25,000 tons per year.

The Greenhouse Gas Air Pollutant Emission Fee was adopted through House Bill 21-1266 (also known as the Environmental Justice Act) in 2021. This requires the Air Quality Control Commission (AQCC) to establish a fee for greenhouse gas emissions. The fee structure is still in development, but may have the same threshold as GEMM II of 25,000 tons per year. This would mean that no facilities in the City and County of Denver would be required to pay this fee.

• Kick-Off Agricultural Meeting, September 13, 2022 
  • View the slide show(PDF, 904KB)
• Kick-Off Manufacturing/Industrial Meeting, September 21, 2022
  • View the slide show(PDF, 1015KB)
• 2nd Agricultural Meeting, October 18, 2022
  • View the slide show(PDF, 560KB)
• 2nd Manufacturing/Industrial Meeting, October 20, 2022
  • View the slide show(PDF, 463KB)

• 3^rd Agricultural Meeting, November 15, 2022
• • View the slide show(PDF, 770KB)
• 3^rd Manufacturing/Industrial Meeting, November 16, 2022
• • View the slide show(PDF, 1MB)

• Final MAI Meeting, February 8, 2023
  • View the slide show(PDF, 1MB)

Disclaimer on meeting minutes: These notes represent topics of discussion that occurred during the meetings listed below. These do not represent any decisions that have been made about the program, nor do these constitute finalized rules and regulations for MAI buildings. These are simply notes for your reference to accompany the recording and slide decks in the "Stakeholder Meetings: Designing MAI Performance Targets" tab above.

Kick-Off Agricultural Meeting, September 13, 2022

• In this first session, we discussed the Energize Denver ordinance, the framework for shaping the performance requirements for the MAI industries, confidentiality concerns, and future engagement meetings.

• Additional topics of conversation included:

• Investigating holistic energy management systems (EMS) as a way to collect data and conserve energy;
• Green roofs as a way to reduce heat factors (and to align with the Green Building Ordinance [GBO]);
• New ideas on potential performance requirements, including a prescriptive approach to compliance (e.g., get an energy audit and complete a certain number of recommendations);
• Energy Star Portfolio Manager’s enhancement (coming in 2023) that allows building owners and cities to define new specific fields (such as an energy per unit of production metric);

• And many other topics, including building envelopes, water systems, battery storage, etc.

Kick-Off Manufacturing/Industrial Meeting, September 21, 2022

• In this first session, we discussed the Energize Denver ordinance, the framework for shaping the performance requirements for the MAI industries, confidentiality concerns, and future engagement meetings.
• Additional topics of conversation included:
  • The various benefits and drawbacks of different performance requirements, especially prescriptive requirements and prescriptive approaches
  • The challenges around transport gas contracts
  • 45Q Tax credits through the Inflation Reduction Act
  • How to orient future discussions around such topics as high vs low intensity buildings and mixed use buildings

2nd Agricultural Meeting, October 18, 2022

• A discussion on equity, including strategic energy management (SEM) for growers.
• Extending the first benchmarking deadline for MAI buildings to December 1, 2023, while sending updated notice/mailers before the rules are finalized that outlines that they need to benchmark by the end of 2023.
• Custom benchmarking metrics, including energy per weight of flower produced (kBtu/kg flower)
• A prescriptive approach to performance requirements (i.e., conduct an energy audit and complete some number of recommendations from the audit). This way, buildings can document in the audit what efficiency measures they might have already implemented, can learn what measures might make most sense for their building, and can learn about rebates, incentives, and financing options that would be applicable to their building.
• Additional compliance options, such as an electrification goal.
• How to handle multi-tenant buildings (i.e., either sub-meter and treat the MAI and non-MAI tenants as separate buildings, or treat the whole building as MAI and require separate energy audits for the different tenants/use types).

2nd Manufacturing/Industrial Meeting, October 20, 2022

• A discussion on equity.
• Extending the first benchmarking deadline for MAI buildings to December 1, 2023, while sending updated notice/mailers before the rules are finalized that outlines that they need to benchmark by the end of 2023.
• Custom benchmarking metrics, including energy per revenue (kBtu/$ revenue) and energy per widget.
• A prescriptive approach to performance requirements (i.e., conduct an energy audit and complete some number of recommendations from the audit). This way, buildings can document in the audit what efficiency measures they might have already implemented, can learn what measures might make most sense for their building, and can learn about rebates, incentives, and financing options that would be applicable to their building.
• Additional compliance options, such as an electrification goal.
• How to handle multi-tenant buildings (i.e., either sub-meter and treat the MAI and non-MAI tenants as separate buildings, or treat the whole building as MAI and require separate energy audits for the different tenants/use types).

3rd Agricultural Meeting, November 15, 2022

• Performance options, metrics, and deadlines, including performance credits for renewable energy and electrification.
• Agricultural grow lights minimum efficiency requirements (e.g., DLC-listed horticultural grow lights).
• How to evaluate performance, which would include annual benchmarking, data verification, and implementation and monitoring reports.
• Natural gas transport contracts, and how most buildings might have contracts that are 6 years or less in duration. This would potentially affect the optional electrification credit that was proposed.

3rd Manufacturing/Industrial Meeting, November 16, 2022

• Performance options, metrics, and deadlines, including performance credits for renewable energy and electrification.
• The second performance pathway for manufacturing/industrial buildings needs to be fleshed out some more, possibly including a custom production-based efficiency metric (as buildings can suggest their own metric in Energy Star Portfolio Manager) instead of, or in addition to, an EUI reduction goal. We also discussed the possibility of including a Scopes 1 & 2 greenhouse gas emissions reduction goal. Along these lines, we discussed whether we should allow the exclusion of process loads, and if we were to allow the exclusion of process loads, would that be possible with sub-metering? More details on these topics to come in our 4th stakeholder meetings.
• How to evaluate performance, which would include annual benchmarking, data verification, and implementation and monitoring reports.
• Natural gas transport contracts, and how most buildings might have contracts that are 6 years or less in duration. This would potentially affect the optional electrification credit that was proposed.
• Potential upgrades to buildings, including low and no-cost investments, and the differences between CapEx investments and operational/behavioral changes.

4th & Final MAI Meeting, February 8, 2023

• Recap of goals and previous meetings
• Proposed performance requirements, including performance pathways and metrics, energy audit minimum requirements and recommendations for the prescriptive pathway, and supplemental credits (renewables and fossil fuel reduction)
• A discussion on how to implement a performance evaluation in 2030 for the prescriptive pathway to show a minimum threshold energy savings
• How to handle new MAI buildings
• Penalties for non-compliance
• Next steps for buildings in 2023 and in the rulemaking process