The Prescriptive Pathway is the simplest route to Regulation 28 compliance—if your building qualifies. Unlike percent-reduction pathways that require proving historical improvements, the Prescriptive Pathway simply asks: “Does your building’s current EUI meet the CDPHE-prescribed target for your building type?”

For many buildings, particularly newer construction or those with recent major upgrades, the answer is yes. But understanding how targets are set and whether your building truly qualifies is critical.

What Is the Prescriptive Pathway?

The Prescriptive Pathway (sometimes called Pathway 1 or the EUI Target Pathway) requires your building to achieve an Energy Use Intensity (EUI) at or below a CDPHE-prescribed threshold. The target is determined by:

  1. Your primary building use type (Office, Retail, Warehouse, Multifamily, Hotel, Healthcare, etc.)
  2. CDPHE’s published EUI targets, derived from ASHRAE Standard 100 and adjusted for Colorado’s climate

If your building’s actual EUI (measured through benchmarking) is at or below the target, you’ve achieved compliance without any improvements. No ECMs required. No percent reduction needed. Just benchmarking and documentation.

How CDPHE Sets Prescriptive Targets

CDPHE’s targets are not arbitrary. They’re based on:

ASHRAE Standard 100: This national standard defines “high-performance” EUI levels for each building type using a large dataset of actual building performance. For example, the 75th percentile EUI for office buildings is approximately 15.5 kBtu/sq ft/year nationally.

Colorado Climate Adjustment: CDPHE adjusts national targets downward for Colorado’s climate. Colorado’s high elevation, low humidity, and cold winters reduce cooling loads compared to warmer climates, so targets are Colorado-specific and generally lower than national ASHRAE benchmarks.

Building Type Specificity: Different building types have dramatically different energy profiles. A warehouse uses far less HVAC-dependent energy than an office or hospital. Targets reflect these differences.

Current Prescriptive EUI Targets by Building Type

For a full breakdown of EUI targets by building type and how CDPHE sets them, see our EUI Targets guide.

Important: Targets are subject to periodic revision (typically every 5 years). Confirm current targets with your auditor at the time you file.

Buildings That Typically Meet Prescriptive Targets

  1. New Construction (Built 2015+): Modern code-built buildings with efficient HVAC, LED lighting, and controls often exceed prescriptive targets.
  2. Recently Major Upgraded Buildings: Buildings with recent lighting retrofits, HVAC replacements, or envelope improvements.
  3. Well-Operated Buildings: Older buildings that have been maintained, kept up to code, and operated efficiently.
  4. Buildings with Favorable Tenant Mix: Warehouses and light industrial with low energy density.
  5. Buildings with Renewable Energy: On-site solar or wind reduces the grid energy consumption and EUI.

Buildings That Struggle With Prescriptive Targets

  1. Pre-1990 Buildings Without Upgrades: Older HVAC, single-pane windows, poor insulation.
  2. Buildings with High Plug Loads: Data centers, laboratories, server facilities—even modern ones have high baseline EUI.
  3. Climate-Dependent Buildings: Buildings with naturally high energy profiles (hospitals, multifamily with electric heating, hotels with 24/7 HVAC).
  4. Multifamily Housing: Target of 12.1 is aggressive; many existing buildings run 13–14+.
  5. Buildings with Process Loads: Manufacturing, commercial kitchens, laundries.

The Prescriptive Pathway Process

Phase 1: Verify Your Compliance

  1. Collect 12 months of utility data (ideally 2025 calendar year)
  2. Calculate your actual EUI (or have an auditor do it)
  3. Compare against the prescriptive target for your building type
  4. If actual EUI ≤ target EUI, you’re compliant

Phase 2: Document for CDPHE

  1. Submit your benchmarking data to ENERGY STAR Portfolio Manager
  2. Generate the official Portfolio Manager report
  3. Attach supporting documentation: utility bills, building square footage verification, building use classification
  4. Include the prescriptive target calculation showing you meet it
  5. Submit to CDPHE by November 1 (with formal compliance declaration by Dec 31, 2026 or 2027)

Phase 3: Ongoing Annual Compliance

Every year (November 1), you must re-submit benchmarking data. If your EUI remains at or below the target, you maintain compliance. If energy use increases and you fall above target, you’ll need a path forward (either describe ECMs planned, or switch to a percent-reduction or GHG pathway).

Advantages of the Prescriptive Pathway

  1. No improvements required (if you already meet target)
  2. No percent-reduction modeling (simple: you meet it or you don’t)
  3. Lowest compliance cost (audit + documentation only)
  4. One-time verification (if you meet target, you’re done; no ongoing improvements to finance)

Disadvantages of the Prescriptive Pathway

  1. All-or-nothing: You either meet the target or you don’t. There’s no partial compliance.
  2. No credit for historical improvements: If you’ve already improved your building, that doesn’t help unless you’re already at target.
  3. Targets may tighten: CDPHE can revise targets every 5 years. A building that meets 2026 target might not meet 2030 target.
  4. Weather sensitivity: An unusually cold or hot year can push you above target temporarily.

Mixed-Use Buildings and Blended Targets

If your building has multiple primary uses (e.g., 60% office, 40% retail), CDPHE allows “blended” EUI targets calculated as a weighted average:

Blended Target EUI = (0.60 × Office Target) + (0.40 × Retail Target) = (0.60 × 16.5) + (0.40 × 18.2) = 9.9 + 7.28 = 17.18

You’d need to document the square footage breakdown and justify the percentages. Your energy audit should calculate this correctly.

Should Your Building Target the Prescriptive Pathway?

Ask your energy auditor:

  1. What is our actual current EUI? Calculate from 2021–2025 utility data.
  2. What is the prescriptive target for our building type?
  3. Are we currently above or below target?
  4. If above, how far above, and what would low-cost improvements get us to target?
  5. Is prescriptive pathway more cost-effective than percent-reduction or GHG pathway?

For many buildings, especially newer construction and well-maintained existing buildings, the prescriptive pathway is the easiest and cheapest route to compliance. For others, a percent-reduction or GHG pathway makes more economic sense.

Timeline for Prescriptive Compliance

  • Now (Q1 2026): Audit and EUI calculation
  • Spring 2026: Confirm prescriptive target and calculate compliance status
  • Summer 2026: If compliant, prepare documentation package
  • Fall 2026: Submit benchmarking and prescriptive compliance declaration
  • December 31, 2026 (100,000+ sq ft) or 2027 (50,000–99,999 sq ft): Formal compliance filing

If you meet prescriptive target, timeline is short and cost is low.

Bottom Line

The Prescriptive Pathway is the simplest road to compliance—if your building qualifies. Modern buildings, well-maintained existing buildings, and buildings with favorable energy profiles often do.

The first step is an honest audit: what is your actual EUI, and how does it compare to CDPHE’s target for your building type? If you’re within 10–15% of target, low-cost improvements may get you across the line. If you’re well below target, congratulations—document it and file.

Buildings that take the Prescriptive Pathway seriously (get accurate EUI calculations, understand their building type, know the targets) complete compliance in 6–9 months. Buildings that guess often find themselves scrambling in Q4 2026.

Know your EUI. Know your target. Know whether you qualify. Plan accordingly.