MAI Compliance Options
Choosing the Right Compliance Path for Your MAI Building
Once your building has the MAI designation, you have flexibility in how you meet your energy target. Most MAI buildings follow the default path. If that doesn’t fit your operations, you can apply for an alternate metric that better reflects how your building uses energy.
When Should You Consider an Alternate Pathway?
The default path works well for many MAI buildings. It requires either a 30% site EUI reduction or achieving a site EUI of 52.9, whichever is more achievable for your building.
However, an alternate pathway may fit better if any of these are true:
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You’ve already made efficiency upgrades and want credit for them (you can request an earlier baseline year, as far back as 2018).
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Your energy use is tied to production volume rather than square footage.
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You’re an eligible manufacturing plant type that could use an ENERGY STAR® Plant Score.
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You’d rather commit to a defined list of projects than hit a numeric target.
How You’ll Prove Compliance
Almost all MAI buildings comply through the Performance Pathway: you either use the default metric or choose an alternate metric, meet its target by the deadline, and prove it through your annual benchmarking data.
In a select few cases, the Prescriptive Pathway may make more sense for an MAI building. It involves completing an Action Plan, which is a defined list of energy efficiency projects based on an ASHRAE level 2 energy audit, rather than hitting a numeric target. This pathway requires more reporting along the way, since you prove compliance by documenting the completion of your projects. For the full requirements, application checklist, and step-by-step compliance process, see Section 4.5.2.2 of the MAI Technical Guidance. The Help Desk is also available to help with any questions.
Your Metric Options
The default metric is applied automatically. The alternate metrics below require an MAI ACO Application.
If you’re unsure of your options, contact the Help Desk.
Mixed-use and multi-tenant MAI buildings (a mix of MAI and non-MAI tenants) have some restrictions on which metrics they can use, but also a few additional options. See Section 4.1.1 of the MAI Technical Guidance for details.
30% Site EUI Reduction
Works for any MAI building
DEFAULT
Cut your energy use intensity 30% from your baseline. Works for any MAI building.
52.9 Site EUI Target
For buildings whose 2022 baseline EUI is below 75.5
DEFAULT
Reach a site EUI of 52.9. This is the default for buildings whose 2022 baseline EUI is below 75.5.
30% Production Efficiency Improvement
Single-tenant or MAI-majority mixed-use · standard product buildings
Measure your weather-normalized site energy usage per unit produced (for example, per pound of product or per item made) and improve it 30%. A strong fit for buildings that make a standard product and expect production to grow. You propose the custom metric and the city reviews it case by case. Available to single-tenant or MAI-majority mixed-use buildings that produce a standard product.
Heads up: if you choose this metric, you’ll enter your custom metric into ENERGY STAR Portfolio Manager (ESPM) and resubmit your historical benchmarking reports for city review. After that, the custom metric must be updated annually in ESPM and included in your annual benchmarking report. Step-by-step instructions are in the MAI Technical Guidance, Appendix B.
30% Process Load Efficiency Improvement
Buildings that can separate process load from base load
Like the production metric, but it measures only your process-load energy, separated from your base load. Your building must be able to separate the two. Available to single-tenant or MAI-majority mixed-use buildings that produce a standard product.
Heads up: if you choose this metric, you’ll enter your custom metric into ESPM and resubmit your historical benchmarking reports for city review. After that, the custom metric must be updated annually in ESPM and included in your annual benchmarking report. Step-by-step instructions are in the MAI Technical Guidance, Appendix B.
ENERGY STAR Plant Score of 75
Eligible manufacturing plant types only
If your building is an eligible manufacturing plant type, the Plant Energy Performance Indicator (EPI) Score may be your best option. A higher score means a more efficient plant — the 2032 goal is a score of 75. If you already score 75 or above, you’re automatically in compliance once you choose this metric and submit your annual EPI spreadsheet.
Heads up: Not eligible for the Renewable Credit or Fossil Fuel Reduction Incentive, because the EPI spreadsheet already accounts for renewable energy and gas efficiency.
To check if your building is an eligible plant type, visit the EPA ENERGY STAR Plant website. You’ll need your NAICS code (find it on your OSHA 300A form or by calling the NAICS hotline).
How to check and submit your score: fill out the corresponding EPI spreadsheet on the EPA website to see your current score. Then submit that spreadsheet each year with your benchmarking report through the EPI Score submission form.
Propose an Alternate Metric
If none of the above fit your operations · reviewed case by case
If none of the above fit your operations, you may propose another metric tied to your process loads — for example, a greenhouse gas emissions intensity (GHGi) or power use effectiveness (PUE) metric. The city reviews these case by case.
Heads up: A GHGi metric is not eligible for the Renewable Credit or Fossil Fuel Reduction Incentive, because those reductions are already captured in GHG accounting.
Custom MAI Target
Requires completed energy audit
LAST RESORT
If you’ve completed an energy audit, explored renewable energy, and still can’t reach any other target, you can apply for a custom target. Your auditor adds up the estimated EUI savings from a defined set of efficiency measures and subtracts them from your building’s current EUI. That result becomes your final target. It’s not a required to-do list — once the target is set, you choose which mix of measures and renewables to implement to hit it.
Applying for a custom target involves an application narrative, an ASHRAE Level 2 audit that meets the minimum requirements for a custom target, a renewable energy options memo, and an on-site verification visit from the city. For the full submission requirements and evaluation process, see Section 4.5.1.1.5 of the MAI Technical Guidance.
A Note on Your Baseline Year
Your baseline year is 2022 by default. If you made efficiency upgrades before 2022 and want credit for them, you can request an earlier baseline year, as far back as 2018. If 2022 didn’t reflect normal operations (for example, production was still ramping up), you can request a later year with a short justification. To use an earlier baseline, benchmarking data for that year and every year since must be on file or back-reported.
Additional Credits That Can Help You Reach Your Target
Your MAI building may qualify for supplemental credits that make your target easier to reach. These credits recognize steps taken to add renewable energy, reduce fossil fuel use, or account for energy that powers vehicles rather than your building.
One exception: the ENERGY STAR Plant Score. These credits apply to most MAI metrics, but not the ENERGY STAR Plant Score. That score already factors in both the Renewable Credit and the Fossil Fuel Reduction Incentive.
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Renewable Credit
Count renewable energy toward your target. An MAI building can meet its performance requirement entirely by sourcing at least 30% of its total energy demand from qualifying renewables.
How to claim: submit the Renewable Credit Submission Form once a year by your benchmarking deadline.
Full details on what qualifies can be found in the MAI Technical Guidance.
2
Fossil Fuel Reduction Incentive
Unique to MAI buildings. Reduce direct fossil fuel use and receive up to 10% credit toward your target. Based on your benchmarking data, it's evaluated at both interim and final performance checks, then applied before the Renewable Credit.
Full details on this incentive can be found in the MAI Technical Guidance.
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Transportation Energy Use Credit
If your building's meters power vehicles (EVs, forklifts, EV charging), exclude that energy from your target. Choose one method per type of vehicle:
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Sub-metered use (recommended). Measure the actual energy your vehicles use with a sub-meter, then report it on the Transportation Energy Use Exclusion form once a year by your benchmarking deadline. You list each vehicle’s class, type, age, and fuel, plus the total kWh or therms used.
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​​Electric-only estimate. If you don’t sub-meter, electric vehicles can be estimated using national models and applied through a Standard Target Adjustment. This is the only transportation energy use that doesn’t have to be sub-metered, and it’s available only to buildings using an EUI metric.
For more details, see the Transportation Energy Use section of the MAI Technical Guidance.