Measure Identification
Code change proposals are sometimes referred to as measures. Measure ideas are submitted in either the Nonresidential, Multifamily, or Single Family sectors. If you have questions, contact the Statewide CASE Team at [email protected].
How are Code Change Proposals Selected?
At the beginning of each three-year cycle, there are many code change proposals in the Statewide CASE Team’s queue for consideration. These proposals are sourced from previous code cycles, conversations with industry experts or other stakeholders, or direct recommendations via our code change proposal form.
Many criteria are used to evaluate the initial CASE proposal list including but not limited to: energy savings, cost effectiveness, technical feasibility, enforceability, adoptability, market readiness, and alignment with other state policy goals and California Energy Commission (CEC) priorities.
The initial list may include over 500 proposals. The Statewide CASE Team, with input from the CEC, uses the evaluation criteria to develop the final measure list. In the past few code cycles, this has been between 50-100 proposals. Once the list is finalized, the CASE Authors get to work. CASE Reports require rigorous analysis and stakeholder engagement via public and individual meetings. On average, about two thirds of the Statewide CASE Team’s proposed measures were adopted by the CEC.
From Code Change Proposal Submissions to Current Status
The Statewide CASE Team considers several factors when screening submissions, including:
- Initial Screening: Preemption concerns, regulatory scope, software requirements, permit/compliance requirements, data requirements, ANSI/ASHRAE/IESNA Standard 90.1 or the International Energy Conservation Code (IECC) inclusion, and relevance to long-term state climate goals
- Prioritization: Greenhouse gas savings potential, electricity savings potential, natural gas savings potential, environmental and social justice impacts, non-energy benefits (such as water conservation), adoptability, code compliance and enforceability, cost-effectiveness, technical feasibility, and market readiness
- Development: When developing code change proposals and associated technical information, the Statewide CASE Team worked with many industry stakeholders including building officials, manufacturers, builders, utility incentive program managers, Title 24 energy analysts, and others involved in the code compliance process. The proposal incorporates feedback received during public stakeholder workshops that the Statewide CASE Team held between January 2023 and May 2023, as well as follow-up discussions with stakeholders at large.
2028 Code Change Proposals by Building Type
2028 code change proposals are currently being accepted. Proposals cover new construction, additions, and alterations in the nonresidential, multifamily, and single family sectors. Proposal system types include building envelope, HVAC, domestic hot water, lighting, electricity generation, energy storage, load management, industrial processes, existing buildings, and others.
New Measure Ideas
The following are energy saving measure ideas under consideration for the 2028 Energy Code cycle proposed by the Statewide CASE Team and other stakeholders. We welcome your new measure ideas. Submit your new measure ideas through our online form. Check back to follow the progress of these proposals.
Proposals are listed by Building Type (Nonresidential (NR), Multifamily (MF), Single Family (SF)), System Type, and Measure Description. Click on the column heading Building Type(s) to sort the list by building type. Contact [email protected] if you have any questions.
| Code Proposal under consideration | System Type(s) | Measure Description | |
|---|---|---|---|
| Air Infiltration Targets | ALL | Building Envelope | Adoption of Air Infiltration Targets (as being a mandatory requirement verified by blower door testing. |
| Heat recovery ventilators (HREVs) or energy recovery ventilators (ERVs) | SF | HVAC | HERVs in single-family homes within the prescriptive path in climate zones where cost effective. |
| Passive House Standard | ALL | Building Envelope | Integrate Passive House Standards as part of a performance approach. PH Standards incorporate tight building envelope, exterior insulation and ERV/HRV (climate dependent), high performance windows blower door testing to below 1 ACH@50. |
| DC Lighting Technologies | NR | Lighting | Consider off-grid lighting, including outdoor solar/battery lighting technologies and indoor DC lighting technologies that connect directly to a PV/battery source, as a lighting wattage exclusion or similar for the prescriptive requirements. |
| Improvements for Horticulture Lighting | NR | Covered Processes | Consider the use of monthly average “daily light integral” to better align with plant needs and best practices for horticulture lighting. A calculation method - based off of the buildings geographic location, bld. orientation, roof style and weather records. |
| Lumen Threshold Reduction | NR | Lighting | Consider the reduction of the lumen threshold from 6,200 to 3,500 initial luminaire lumens or less for luminaire shielding requirements to align with industry offerings and efficacy. (Section 130.2(b)) |
| Exterior Lighting Motion Sensors | NR | Lighting | Consider adding minimum performance requirements for outdoor motion sensors (i.e., coverage pattern, sensitivity, signal latency) to Section 110.9(b)6 and/or AT procedure. |
| Lighting Signage Updates | NR | Lighting | Consider the illuminance for On-premise Electronic Message Centers; Reduce LPD to alight with LEDs; Include message duration for traffic safety signs. |
| Quality Inspections for LED Light Sources and bad linear fluorescent | NR | Lighting | Consider the inclusion of quality specification for NR LED light sources (i.e., linear LED lamps, LED retrofit kits, LED luminaires) via Title 20 or Title 24. This could be similar to the res JA8. Support the ban on linear fluorescent. |
| Relamping Exception for Alterations and Retrofits | NR | Lighting | Consider adding an exception for alterations and retrofits to Section 130.0(c)1A Luminaire Classification and Power to address relamping of existing fixtures similar to ASHRAE 90.1 committee. |
| Exterior Lighting Shielding Requirements | MF, SF | Lighting | Consider the inclusion of shielding requirements for outdoor residential lighting (SF and MF), similar to the BUG requirements for nonresidential outdoor lighting. This would help address the contribution of RES outdoor lighting on light pollution in CA. |
| Solar Thermal Hot Water Heaters | ALL | Domestic hot water | Adding solar thermal hot water heaters to title 24With thoughts for the consumer, this will reduce their electrical bill and help them live a comfortable life. Solar thermal systems should be added to all new construction in CA. |
| Kitchen Ventilation Requirement in Alterations | MF, SF | HVAC | Add a mandatory requirement to provide kitchen ventilation in residential alterations that alter a "significant" portion of kitchen (definition TBD), AND where "significant" portion of envelope will be altered (definition TBD, but maybe ≥50% of dwelling unit wall area altered), thereby increasing risk of higher pollution unless they have ventilation. Continues "do no harm" philosophy of ensuring IAQ not worsened because of energy measures. |
| Heat Pumps that Work: Aligning Minimum Requirements with Model Assumptions | MF, SF | HVAC | Identify the measures needed to attain the performance that was assumed when justifying the Heat Pump Prescriptive. |
| Heat Pump Water Heater (HPWH) Location/Limit Resistance Water Heating | SF | Domestic hot water | Prescriptively allow for HPWHs located outside or in external closets for small units or units without an attached garage. Remove or restrict the current exception that allows electric resistance point of use systems for homes 500 sqft or less. |
| ECM Circulator Pump with Controls | NR, MF | Domestic hot water | This measure would prescriptively require circulator pumps to utilize internal or external controls to reduce energy use at the pump and/or water heater. Requirements could vary based on building size, application, water heating plant types, and distribution system designs. |
| Indoor Lighting Controls | NR, MF | Lighting | Revise the mandatory control requirements and clean up code language. Revised control requirements would include 1) adaptation compensation controls in the parking garage daylight adaptation zone, 2) adding partial or full off occupant sensing controls to more spaces that are allowed to have occupied standby (ASHRAE 90.1 alignment), and 3) reducing occupant sensing control time delay to 15 minutes (ASHRAE 90.1 alignment). |
| Blower Door Test & Reduced Infiltration | SF | Envelope | Introduce airtightness requirements for single family new construction. Mandatory or prescriptive blower door testing with 3 ACH50 target. |
| Remove or Limit Envelope Trade-Offs | ALL | Envelope | Proposal to limit the performance-based tradeoffs between envelope requirements and mechanical equipment efficiencies to prioritize envelope integrity. Including adjustment to the Proposed Design LSC efficiency value to limit the credit for mechanical system upgrades. |
| VRF Indoor Fan Control | NR, MF | HVAC | Requiring all VRF fan coils to automatically vary fan speed based on load will have huge fan energy savings. VRF fan coils typically have variable speed fans, but the fan speed is manually selected by the installer. Some VRF fan coils have controls that automatically modulate fan speed based on the cooling load. |
| ASHRAE Guideline 36 | NR | HVAC | Expand the ASHRAE Guideline 36 requirement and improve compliance by: 1) certifying libraries based on a defined method of test (in development) rather than the 2025 self-certification 2) covering additional sequences and system types. Expand to cover multi-zone and single-zone factory-mounted controllers that are configurable but not field-programmable. Cover additional equipment, including single zone VAV AHUs, exhaust fans, and fan coils. |
| Nonresidential Heat Pump RTU Alterations | NR | HVAC | Prescriptively require all packaged HVAC < 20 tons to be heat pumps upon replacement, or gaspack + efficiency measures, expanding beyond the current threshold of 5 tons. |
| Air to water heat pump (AWHP) Compliance Pathways and Requirements | MF, SF | Multiple | (1) Clarify and update the existing compliance path. Make it clear which existing requirements apply to residential AWHP systems, update forms, and improve software. (2) Institute basic essential mandatory requirements to ensure adequate performance. New requirements to consider could include system sizing (which is different from traditional HVAC sizing, as AWHP, tanks, and indoor heating/cooling delivery must be sized relative to each other, as well as considerations for when DHW load is also served by the same AWHP), pump sizing and efficacy, and glycol concentration limits. |
| Elevators | NR, MF | Other | 2025 cycle measure for regenerative drive for traction elevators with distances at and above 3 landings. Consider measures from other jurisdictions such as lightweighting elevator cabs and counterweights and requiring elevator electronics to go into deep standby when not in use. |
| Escalators and Moving Walkways | NR, MF | Other | Add to existing escalator and moving walkway requirements to have VFD start and stop operation. Add a regenerative drive option for downward travelling escalators to capture energy of descending riders. The measure would require the CA Department of Industrial Relations to complete a parallel rulemaking to update the Title 8 Escalator Safety Orders to allow escalators to start and stop while building is occupied. |
| Lighting Power Density Update | NR, MF | Lighting | Update the lighting power density requirements for indoor spaces to reflect the advancements in LED technologies so the stringency of Title 24 LPD requirements remains in line with or better than the national standards (2025 ASHRAE 90.1) and other model codes (2024 IECC). |
| Minimum Water Temperature Delta-T for Hydronic Cooling Coils in Variable Air Volume HVAC Systems | NR | HVAC | Require a 15⁰F minimum difference for the entering and leaving water temperatures (delta-T) for hydronic cooling coils in variable air volume HVAC systems. A minimum of 57⁰F leaving water temperature at design conditions will ensure energy is not wasted by using excessively low chiller water leaving temperatures. |
| Reducing Maximum Airflow During Deadband Operation for Variable Air Volume HVAC Systems | NR | HVAC | Modify prescriptive requirements for variable air volume HVAC systems in economizer and deadband operation to require the maximum airflow rate through an air handler not to exceed 15 percent of either design airflow or of the minimum requirements in 120.1(c)(3). |
| Thermal Energy Storage for Waste Heat Recovery | NR | HVAC | This measure would prescriptively require a thermal energy storage system in very large buildings. |
| Occupied Standby and VS DOAS requirement | NR | HVAC | This measure will add clarity to Section 120.2(e) which references ventilation and space conditioning systems but not DOAS. The intent is for DOAS systems to be made to required to comply with appropriate occupied standby requirements. If a DOAS system capacity includes conditioned thermal zone ventilation requirements, DOAS occupied standby controls for thermal zones shall be explicitly documented and verified. |
| Variable Speed DOAS | NR | HVAC | Change the 3-speed fan requirement to a VFD fan requirement in section 140.4(p)3. 1. Add requirements for DOAS systems to be capable of some amount of airside economizing, i.e., upsize the peak airflow capacity relative to the minimum ventilation airflow needs for the space. 2. Change supply air setpoint from 60°F in 140.4(p)4 in alignment with ASHRAE TC 1.4’s ongoing DOAS research RP-1865. |
| Expand Mechanical HR Requirements | NR | HVAC | Require mechanical heat recovery (i.e., HVAC equipment that usefully leverages both the cooling and heating effect of the vapor compression cycle) equipment in a wider array of buildings than what was required in Title 24 2025. Broaden code language to include more building types, particularly office buildings without process loads, but would require a smaller heat recovery system relative to buildings with process loads. |
| Solar Pool Heating for Existing Buildings | NR, MF | Other | Proposal that will require solar pool heating, a heat pump pool heater, or renewable energy and recovered heat to raise the baseline efficiency of pool heating process. |
Get Email Updates
The Statewide Codes and Standards Enhancement (CASE) Team periodically distributes email notifications that promote upcoming meetings, provide materials from past meetings, and update stakeholders on the progression of the California Energy Commission (CEC)’s rulemaking process. You can choose to receive measure-specific and/or general updates on these topics depending on your needs.
