Program Requirements

For units in multifamily mid and high rise buildings to earn the ENERGY STAR, a new or substantially rehabilitated mid or high rise multifamily building must be designed to be at least 15% more energy efficient than a building built to code.

*Note: The national requirement is 15% above ASHRAE Standard 90.1-2007. See below for specific Performance Targets in states with energy codes such as ASHRAE 90.1-2010, 2012 IECC, ASHRAE 90.1-2013, and 2015 IECC.

The developer of a project participating in the program must provide EPA or its designated agent with program specific submittals. These submittals, which must be validated by a Licensed Professional, are used to demonstrate that the program’s requirements have been met, that all prerequisites are included, and that each energy conservation measure is installed to specification. Please visit the Certification Process page for more information on how to earn the ENERGY STAR.

Building performance is as much a function of proper building management as the energy conservation measures incorporated into the structure. Therefore, after units in a building earn the ENERGY STAR, the developer/owner must commit to benchmarking the building in Portfolio Manager for a period of two years. For more information please see the Benchmarking page.

Performance vs. Prescriptive Path

There are two paths available to meet ENERGY STAR’s MFHR requirements:

  • ENERGY STAR MFHR Performance Path PDF (376KB): An approach to meeting program requirements where software is used to model the building’s energy use to verify that it meets the Performance Target. (See notes below to determine the Performance Target in your state).
  • ENERGY STAR MFHR Prescriptive Path PDF (197KB): An approach where a developer constructs the project using a prescribed set of construction specifications that meet program requirements. (This path is not available in all states; see notes below).
  • California ENERGY STAR MFHR Performance Path PDF (121KB) For projects in California, EPA has modified its National Performance Path to align with the 2013 Title 24 Standards, instead of ASHRAE 90.1.

Please note that although the Performance Path allows for some trade-offs when selecting energy conservation measures for meeting the Performance Target, the program has set some minimum prerequisites for specific energy efficiency components. Although the prerequisite measures can be used to help the project meet the Performance Target, failure to meet the prerequisite requirements will result in the project not earning the ENERGY STAR. The prerequisites are found within the ENERGY STAR MFHR Performance Path document.

Both the Prescriptive Path and Performance Path require that partners comply with mandatory Testing & Verification Protocols available on the Guidance Documents page. All program documentation for both paths is available for download in a .zip file for convenience.

Performance Targets in States enforcing 2012 or 2015 IECC

To ensure that ENERGY STAR remains a mark of distinction and provides meaningful energy savings above code, MFHR projects pursuing ENERGY STAR certification in states that have adopted 2012 IECC, 2015 IECC, ASHRAE 90.1-2010 or ASHRAE 90.1-2013, will be required to meet a modified Performance Target, rather than the current national requirement of 15% over ASHRAE 90.1- 2007.

To provide a period of transition, all ENERGY STAR MFHR Project Applications submitted to EPA on or before December 31, 2014, will be allowed to meet a Performance Target of 15% savings over ASHRAE 90.1-2007, regardless of the current or future code for their state.

All Project Applications submitted on or after January 1, 2015 must pursue a Performance Target of 15% better than the energy code under which the building is permitted (unless otherwise noted below). Since EPA has not yet developed a Prescriptive Path based on these codes, only the ENERGY STAR MFHR Performance Path certification option will be available for projects in these states.

Notes and Exceptions:

  • Local Code Exception: While local city or town codes may differ from the state code, the determination for the ENERGY STAR program is based on the commercial code adopted by the state, not the local jurisdiction. In an instance where the building is permitted under a local code that is not the same as the state code, the Performance Target is based on the state code in place. The permit application or issue date will be used to determine what state code was in place in the state. To determine the code adopted by the state and its effective date, please visit (See example 4 below.)
  • State Code changes between ENERGY STAR MFHR Project Application and Permit: If the Project Application is submitted on or after January 1, 2015, and the state code changes between the ESMFHR Project Application date and the permit application date (or the reverse), the project’s Performance Target is based on the code the project is permitted to, and not based on the code in place at the time of the ESMFHR Project Application. (See examples 2 and 3 below. A copy of the permit may be requested.)
  • Modeling options: To reduce the burden of applying two different codes to a given project, a Policy Record has been established that would allow 20% savings over ASHRAE 90.1-2007 as equivalent to 15% over ASHRAE 90.1-2010. The Policy Record would also accept 25% savings over ASHRAE 90.1-2007 and 20% savings over ASHRAE 90.1-2010, as equivalent alternatives to 15% savings over ASHRAE 90.1-2013.
  • Addendum bm: Projects in states that have adopted ASHRAE 90.1-2013, regardless of whether Addendum bm has been adopted by the state, can demonstrate compliance with a Performance Target of 15% above ASHRAE 90.1-2013 using Appendix G, or Appendix G, as modified by Addendum bm. To determine if the project meets the 15% Performance Target, the approach outlined in the Guidance for using Addendum bm for Multifamily High Rise PDF (481KB) must be used.
Performance Target Options:  Savings (%) above varying ASHRAE 90.1 Baselines
State Code 90.1-2007 90.1-2010 90.1-2013
2009 IECC 15% NA NA
2012 IECC 20% 15% NA
2015 IECC 25% 20% 15%*

*Appendix G from ASHRAE 90.1-2010, 90.1-2013, or 90.1-2013 as modified by Addendum bm, may be used.

To further demonstrate this policy, some examples are provided below. Please contact if you have any questions about the Performance Target for your project.

  • Example 1: An ESMFHR Project Application submitted any date prior to 1/1/2015, regardless of the commercial code in effect at the time of permit requires 15% savings over ASHRAE 90.1-2007, using the transition period exemption.
  • Example 2: An ESMFHR Project Application submitted in February 2016 in a state where ASHRAE 90.1-2010 or 2012 IECC has already been adopted would require 15% savings over ASHRAE 90.1-2010, since the transition period deadline has passed. If that project was permitted while the state code was still 2009 IECC, it could meet the Performance Target of 15% over ASHRAE 90.1-2007.
  • Example 3: An ESMFHR Project Application was submitted in March 2015, while the state code was ASHRAE 90.1-2007 or 2009 IECC. The project has not yet been permitted, but targets 15% savings relative to ASHRAE 90.1-2007. The project experiences delays, and the state has since adopted and is enforcing ASHRAE 90.1-2010 (or 2012 IECC).  The ENERGY STAR Performance Target is based on the permit. If the project is permitted to the new code, the project must now demonstrate 15% savings relative to ASHRAE 90.1-2010.
  • Example 4: An ESMFHR Project Application submitted in July 2015 in a state where the state code is 2012 IECC, but the local code is still 2009 IECC or based on 2009 IECC (ex. stretch code). ENERGY STAR would require 15% savings over ASHRAE 90.1-2010, since the determination is based on the state code, not the local code. This applies even if the local code is more advanced than the current state code (ex. stretch code).

Policy Changes and Clarifications

EPA periodically revises the MFHR Program Requirements in response to partner questions and evolving standards (e.g., ENERGY STAR product specifications, NAECA standards, model energy codes). The purpose of this revision process is to be responsive to partner questions, to disseminate policy changes in a consistent manner, and to adapt the program as needed for success. Revisions will be made on an as needed basis; however, it is expected that the guidelines will not be updated more frequently than every six months.

  • Current Policy Record PDF (580KB) – This document contains policy issues that were received and have been resolved since the last revision of the program documents, sometimes resulting in modifications that will be incorporated into the next version of the program documents. It also contains unresolved issues pending resolution by EPA. This document was last updated on August 31, 2016. Licensed Professionals should review this document for clarifications and updates to the Program Requirements.


Please reference the MFHR FAQ page for answers to the questions most frequently asked by MFHR program participants. While these answers may also appear in our Policy Record, the most common questions and answers have been placed in the FAQ system for your convenience and are organized by categories (ie. Appliances, Lighting, T&V).

Revisions to Program Documents