2028 Code Change Proposal Ideas | Title 24 Stakeholders

The Statewide CASE Team compiled the following ideas for the 2028 code cycle.

A sincere thank you goes out to everybody who submitted 2028 code change proposal ideas including: academic institutions, energy consulting companies, non-profit energy efficiency advocates, product manufacturers and distributors, local governments, and design/build firms to name a few. We have compiled ideas from more than 40 individuals and organizations. Please review the list to confirm your proposal ideas are represented. If you submitted an idea that you do not see in the list below, please either resubmit your idea using our online form or email us at [email protected] by Friday, May 23, 2025. We received similar ideas from multiple sources and have consolidated similar ideas where appropriate.

Please see the 2028 Code Cycle Measure Identification page for a description of how the Statewide CASE Team is selecting proposals that we will support for the 2028 code cycle.

Check back to follow the progress as we select measures for the 2028 cycle.

Last updated 5/9/2025

Measure ID	Description of Code Proposal Under Consideration		System Type	Selection Status
1	Traction Elevators. Require all elevators with a rise of 33 and greater (three stories) to be a traction elevator with regenerative motors. Consider lightweighting elevator cabs and counterweights, and requiring elevator electronics to go into deep standby when not in use.	NR+MF	Covered Process	Proceeding
3	Demand Control Kitchen Ventilation. Move 140.9(b)2B(ii) prescriptive measure to mandatory requirement and lower the exhaust airflow rate requirement to 3,000 cfm. Eliminate remaining options in 140.9(b)2B.	NR	Covered Process	Proceeding
4	Pool heating. For additions and alterations, require solar pool heating, a heat pump pool heater, or renewable energy and recovered heat to raise the baseline efficiency of pool heating.	NR+MF	Covered Process	Proceeding
7	Air to Water Heat Pump (AWHP) Compliance Path: (1) Clarify and update the existing compliance path, making it clear which existing requirements apply to residential AWHP systems (for example, controls and pipe insulation requirements), update forms, and improve software; and (2) Add mandatory requirements to ensure adequate performance (likely including system sizing, component insulation, pump sizing and efficacy, and glycol concentration limits).	SF+MF	Multiple	Proceeding
9	Expand the ASHRAE Guideline 36 requirement and improve compliance by: 1) certifying libraries based on a defined method of test (in development), and 2) covering additional sequences and system types.	NR	HVAC	Proceeding
10	Pipe Insulation. Update mandatory insulation requirements for pipe supports and elbows in both new construction and additions and major alterations. Update nonresidential pipe insulation mandatory and prescriptive measures and insulation thickness table to ensure the heating plant and recirculation loop have continuous insulation, insulation is installed appropriately for fittings, appurtenances, and pipe supports and requirement for third party pipe insulation verification.	NR+MF	DHW	Proceeding
12	Central Heat Pump Water Heaters (HPWH). Develop prescriptive requirements for central HPWH DHW systems that: 1) limit electric resistance backup in certain climate zones; 2) ensure unitary heat pump / resistance hybrid heaters minimize electric resistance use when installed in central HPWH systems with recirculation; 3) establishing prescriptive alternatives for systems without recirculation; and 4) expanding ventilation requirements to commercial-sized unitary systems. The proposal would also revisit return to primary system requirements, investigating the compliance software's ability to simulate performance accurately and if so allowing these systems to receive compliance credit in the performance approach.	NR+MF	DHW	Proceeding
13	ECM Circulator Pumps with Controls. Prescriptively require circulator pumps to utilize internal or external controls to reduce energy use at the pump and/or water heater. Requirements will vary based on building size, application, water heating plant types, and distribution system designs. Single or multiple pump control methods in combination with other distribution system optimization techniques will be required based on system configuration including: pressure based variable speed control with thermal balancing valve(s), constant return temperature control, demand flow-based control, aquastat, and digital timeclocks. An energy penalty will be incurred if selecting performance path and opting out of pump controls based on the water heater and storage configuration selected based on the impact to water temperature stratification in the tank and additional pipe heat losses in the distribution loop.	NR+MF	DHW	Proceeding
16	Kitchen Ventilation Requirement in Alterations. Mandatory requirement to provide kitchen ventilation in residential alterations that alter a "significant" portion (definition TBD) of the kitchen, AND where "significant" portion of envelope (e.g., at least 50% of dwelling unit wall area) will be altered, thereby increasing risk of higher pollution unless they have ventilation	SF+MF	HVAC	Proceeding
18	Hotel / Motel Guestroom Envelope. Eliminate hotel/motel guest rooms as separate occupancy type for consideration of envelope requirements; incorporate all hotel/motel guest room requirements under NR requirements	NR	Envelope	Proceeding
22	Energy Efficiency Credits. Create options for achieving a set number of EE points in the prescriptive path to increase code stringency.	NR	Multiple	Proceeding
26	Revise Cold Water Inlet Temperatures and Hot Water Draw Schedules. Update cold water inlet temperature assumption in the compliance software and update hot water draw schedules.	NR	DHW	Proceeding
27	Update indoor lighting power density (LPD) requirements to align with advancements in LED technologies, ensuring Title 24 standards meet or exceed national standards (2025 ASHRAE 90.1) and model codes (2024 IECC). Emphasize luminaire efficacy and lamp lumen depreciation. Address lighting power requirements for data centers by developing new building and space types with associated LPD requirements.	NR	Lighting	Proceeding
29	Minimum Water Temperature Delta-T for Hydronic Cooling Coils in Variable Air Volume HVAC Systems. Require the use of a minimum difference for the water temperatures for hydronic cooling coils in variable air volume HVAC systems.	NR	HVAC	Proceeding
30	Reducing Maximum Airflow During Deadband Operation for Variable Air Volume HVAC Systems. 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). If more than the minimum is required for cooling during economizer operation, it will be permitted. The current requirements apply at the zone level, which allows the air handler to have a higher airflow when a bypass is used. Modify 2025 NA7.5.6.2 Step 2 to add a step for multiple zone systems. This measure only applies to additions where the addition is served by a new DX or hydronic unit, and to alterations where a new DX or hydronic unit is installed.	NR	HVAC	Proceeding
31	Blower door test & reduced infiltration. Introduce airtightness requirements for single-family new constructions with mandatory or prescriptive blower door testing targeting 3 ACH50.	SF	Envelope	Proceeding
32	Increased compliance for additions and alterations. Simplify energy code requirements for additions and alterations to increase compliance by reducing complexity and streamlining the compliance process. A few options: (1) Evaluate the necessity of some of the exceptions to new construction code, such as Section 150.2(b)I and J, (2) reduce the number of conditioned square foot categories (3) Remove repetitive text, such as Section 150.2(a)1A and B, and (4) spell out requirements and limit the use of references. In addition, this measure would aim to better streamline the compliance process to reduce the time needed for building officials to approve permits.	SF	Multiple	Proceeding
33	Minimum Envelope Performance. Limit the performance-based tradeoffs between envelope requirements and mechanical equipment efficiencies to prioritize envelope integrity. Maintain flexibility in tradeoffs across envelope measures. This recommended approach would not require additional annual simulations. (1) Calculate a prescriptive envelope performance target (similar to UA) within the software and require the Proposed Design value be no greater than x% over the Standard. (2) These alternative approaches would require additional annual simulations. (1) Create an LSC Envelope budget based on prescriptive envelope standards and require the Proposed Design envelope be no greater than x% over the budget. (2) Adjust the Proposed Design LSC efficiency value. (3) Weight energy use by component lifetime.	SF	Multiple	Proceeding
34	Heat pump control effectiveness. Add rigor to the requirements to configure controls optimally (on the unit or the thermostat) and verify that configuration. This includes controls for supplementary heating, defrost, variable capacity HVAC with third-party thermostats, and fan control. The requirements would include (depending on the functionality) some combination of generic methods for configuration, manufacturer-specific methods and instructions, and installer or verifier implemented inspections or functional tests. In some cases, this may also include required specific configuration settings or default settings.	SF+MF	HVAC	Proceeding
35	Heat Pumps that Work: Aligning Minimum Requirements with Model Assumptions. Bundle residential performance measures for heat pumps to create a cost-effective package that maximizes savings.	SF+MF	HVAC	Proceeding
36	Allow for Heat Pump Water Heaters (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.	SF+MF	DHW	Proceeding
37	Nonresidential HVAC Thermal Energy Storage (TES). Add language to Section 140.4(s) that would require TES in new construction for large buildings	NR	HVAC	Proceeding
38	Expand Nonresidential Mechanical Heat Recovery Use Cases. Identify and require mechanical heat recovery at additional sites with cost-effective simultaneous cooling & heating loads.	NR	HVAC	Proceeding
39	VRF Indoor Fan Control. Require all VRF fan coils to automatically vary fan speed based on load.	NR	HVAC	Proceeding
40	Occupied standby and variable speed DOAS requirement. If a DOAS system capacity includes conditioned thermal zone ventilation requirements and unconditioned ventilation requirements, occupied standby controls for thermal zones shall be documented and verified.	NR	HVAC	Proceeding
41	Expand Variable Speed DOAS. Change the 3-speed fan requirement to a VFD fan requirement. DOAS supply and exhaust fans shall have a minimum of three speeds to facilitate system balancing. Align with ASHRAE TC 1.4's current DOAS RP-1865. DOAS with mechanical cooling providing ventilation to multiple zones and operating in conjunction with zone heating and cooling systems shall not use heating or heat recovery to warm supply air above 60°F when representative building loads or outdoor air temperature indicates that the majority of zones require cooling.	NR	HVAC	Proceeding
42	Change MERV-13 to MERV-13A. Modify Section 120.1(c)(1)(B) "Air Filter Efficiency", substituting MERV13A for MERV13.	NR	HVAC	Proceeding
44	Improve Nonresidential Prescriptive Transfer Air Requirements for Toilet Rooms. Improve language at Section 140.4(o) to prohibit directly cooling/heating interior toilet rooms.	NR	HVAC	Proceeding
46	Didn't review - Chris	NR	Lighting	Proceeding
48	Integrate Part 11 CALGreen proposals for healthcare into Part 6. Remove specific exceptions for healthcare buildings from sections 120.2(e), 140.4(d), and 140.4(m) for new construction, and from section 141.0(b) for fenestration, insulation, lighting, and exterior doors for alterations and additions. Establish a performance pathway or credit for healthcare buildings.	NR	Multiple	Proceeding
52	Outdoor Motion Sensor Requirements. 1) Review and revise/remove the outdoor motion sensor exception wattage threshold. 2) 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.	NR+MF	Lighting	Proceeding
54	Nonresidential Lighting Performance Specification. Include quality specifications for nonresidential LED products to support the ban on linear fluorescent lights.	NR+MF	Lighting	Proceeding
55	Didn't review	NR	Covered Process	Proceeding
57	Nonresidential Chilled Water and Hot Water Reset. Revise Section 140.4(k)4 to reduce the capacity threshold to 300k, and eliminate Exceptions 1&2	NR	HVAC	Proceeding
58	Nonresidential HVAC Boiler plant turndown. Require boiler plant staging/modulation down to 5% (exact value determined with full proposal) of peak heating capacity.	NR	HVAC	Proceeding
59	Nonresidential Masonary Wall Assemblies. Update JA4 Table 4.3.5 for hallow masonry walls U-factors to be consistent with ASHRAE 90.1 rather than the current values based on 1986 Berkely Solar Group/Nevada Masonry council document/data	NR	Envelope	Proceeding
60	Nonresidential Steel Framed Wall Assemblies. Update JA4 Tables 4.3.3 and 4.3.4 based on calculation method which are not dependent on EZ Frame. ASHRAE 90.1 Addendum 'aw' and 'ch' based on linear thermal bridging factor and AISI S250 standard are being investigated to identify the best option.	NR	Envelope	Proceeding
62	Require efficient pre-rinse equipment in new buildings to reduce water and energy use in high-volume dish sanitation applications found in hotels, cafeterias, and large commercial kitchens. This measure addresses the inefficiencies of industrial hoses and common pre-rinse practices, promoting the use of scrapers, pulpers, and troughs.	NR	Covered Process	Proceeding
63	Need the prime to re-write.	NR	Covered Process	Proceeding
66	Revisit and streamline envelope alteration requirements across all categories, aligning with SF/NR standards. Increase roof insulation stringency for low-sloped roofs (R-14 to R-23 for most CZs, NR to R-17 for CZ6-8). Update cool roof and insulation tradeoff table accordingly. Assign U values based on JA4, aligning with nonresidential JA4 updates. Evaluate other cleanup opportunities to unify SF/MF/NR requirements.	NR+MF+SF	Envelope	Proceeding
67	Cool Walls. Introduce cool wall requirements as a performance credit, voluntary standard, or mandatory standard	NR+MF+SF	Envelope	Proceeding
70	Prescriptive Wall Insulation. Update prescriptive wall insulation requirements and align with nonresidential requirements when appropriate.	MF	Envelope	Proceeding
71	Metal Frame Wall Insulation. Update mandatory snf prescriptive residential metal framed wall requirements to reflect construction practices and improved energy performance, aligning with nonresidential requirements when appropriate. Align differences between two metal framed walls in JA4.	MF	Envelope	Proceeding
72	Luminaire Level Lighting Controls (LLLC). Require fixture-level controls for indoor and outdoor lighting in nonresidential buildings and apply to multifamily buildings as appropriate. Update control product specifications. This requirement would replace the power adjustment factors for indoor open office lighting and may only be applicable in some space types.	NR+MF	Lighting	Proceeding
73	Street Lighting Design Criteria. Add design criteria for street lighting for light level and uniformity, considering safety lighting. Use the IES streetlighting design criteria for the street classifications and performance minimums.	NR+MF+SF	Lighting	Proceeding
74	Street Lighting Adaptive Standards. Add adaptive lighting standards for street lighting with pre- and post-curfew light levels, following IES specifications.	NR+MF+SF	Lighting	Proceeding
77	Extend 2025 single family heat pump updates to multifamily buildings with appropriate revisions. It would include: 1. supplemental heat lockout temperature; 2. when heat pumps have electric resistance (ER) heat, high limit of the ER capacity and stage requirements; 3. requirements for thermostats that control heat pump with supplemental heating, such as capability to receive and display outdoor air temperature signal, indicator for supplemental heat lockout; 4. sizing and equipment selection requirement per recent Manual J and Manual S. All requirements would be evaluated for both single speed and variable capacity units	MF	HVAC	Proceeding
78	Nonresidential HVAC Performance Requirements. Enhance nonresidential HVAC codes to maximize energy efficiency by limiting setback, second-stage heating, and defrost cycles.	NR	HVAC	Proceeding
79	Include passive house envelope requirements in prescriptive requirements.	NR+MF+SF	Envelope	Proceeding
80	Central Plant Electric-Ready. Require that newly constructed central plants using gas equipment have the infrastructure to transition to electric systems in the future. This includes having appropriate electrification infrastructure and capacity, space for multiple heat pump systems and storage tanks, and adequate air volume or ventilation for heat pump installation.	NR	Multiple	Proceeding
81	Introduce new prescriptive requirements for AWHP in Section 140.4, including sizing and load factor calculations, a new efficiency metric for heat-recovery AWHPs that addresses part load efficiency, a minimum efficiency requirement under heat recovery mode, and buffer tanks for supply temperature stability. Add prescriptive commissioning and acceptance testing requirements. Requirements would apply to new construction, additions, and alterations.	NR	HVAC	Proceeding
82	Add requirements or compliance credits for heat recovery and/or planned ducting of heat pump cold air exhaust in interior installations to utilize cooling benefits and enhance heat pump performance.	NR+MF	Multiple	Proceeding
83	Need description of this from early January version of spreadsheet.	NR+MF+SF	DHW	Proceeding
84	Require master mixing valves (MMV) in nonresidential domestic hot water systems with recirculation, single family homes, and multifamily buildings. Allow unitary Heat Pump Water Heating (HPWH) with integrated MMV , and require digital MMV when peak hot water demand exceeds a defined threshold that will be established based on cost effectiveness. Consider making this mandatory in Section 110.3(c)4.	NR+MF+SF	DHW	Proceeding
85	Luminaire Classification and Power Exception for Alterations & Retrofits. Add an exception for alterations and retrofits to Section 130.0(c)1A Luminaire Classification and Power. Sample language, "EXCEPTION to Section 130.0(c)1A: For alterations and retrofits, maximum rated wattage or rewiring rated wattage of a luminaire shall be listed on permanent, preprinted, field-installed label supplied by the luminaire manufacturer."	NR+MF	Lighting	Proceeding
86	Whole Building Electric Ready . For new construction with gas equipment, plan for future electric upgrades without over-planning, ensuring flexibility for specific needs.	NR	Multiple	Proceeding
87	PV and Storage Alignment for Multifamily. Simplify PV and storage requirements for multifamily across building sizes. Align exceptions to PV requirements buildings with 3 stories or fewer and buildings with 4 stories or more. Establish threshold to require BESS for 3 stories or fewer.	MF	Generation / Storage	Proceeding
88	Gas Water Heater to Heat Pump Water Heater Prescriptive Path for Alterations. Similar to CALGreen Tier 1 residential AC to HP, but for domestic and service water heaters. The primary prescriptive path would be a heat pump water heater. The secondary path would be replacing gas like-for-like plus other water heater measures, such as a tank jacket, pipe insulation, low-flow fixtures, and if needed other efficiency measures in the building.	SF	DHW	Proceeding
89	Expand prescriptive heat pump baselines. SZHP baseline are currently prescriptively required for most occupancies. Expand prescriptive SZHP baseline for warehouses and restaurants, which are subject to California's new indoor heat protections for workplaces. MZHP baseline is currently prescriptively required for offices and schools. Expand prescriptive MZHP baseline to other large building types, such as Assembly, Hotel, or Laboratories, can be researched for having MZHP baselines.	NR	HVAC	Proceeding
90	Clean up JA13 to improve clarity. Expand JA 13 to include requirements for central HPWH systems and to encourage thermal energy storage as a load management asset.	NR+MF	DHW	Proceeding
92	Central DHW Compact Water Heating. Develops a combined heat loss metric (such as BTUH/Dwelling Unit) for central system distribution piping heat losses based on insulation level and piping compactness.	MF	DHW	Proceeding
95	HPWH distribution efficiency. Add prescriptive requirements for compact distribution and drain water heat recovery to the HPWH compliance path.	SF+MF	DHW	Proceeding
96	Require ducts to be upgraded with more insulation and better sealing if an HVAC system can only operate with fans running continuously. This offsets the inefficiency of systems like minisplit heat pumps and those with A2L refrigerant that cannot operate in "AUTO" mode.	SF+MF	HVAC	Proceeding
97	Heat Pump Water Heater (HPWH) Ventilation Clean Up. Adjust ventilation requirements for consumer sized HPWH system, which are new for the 2025 code, based on early feedback on compliance. Address issues noted during the 2025 cycle 15-day language period regarding potential negative impacts of some install methods. Harmonize with potential IECC HPWH ventilation requirements and align with plumbing and mechanical codes if appropriate.	NR+MF+SF	DHW	Proceeding
98	Heat Pump Water Heater (HPWH) Ventilation Performance-Based Option. Option to model performance of HPWH ventilation and allow install if performance is equivalent to that one of the ventilation options in 110.3(c)7.	NR+MF+SF	DHW	Proceeding
99	Prescriptive HRV Requirement. Require balanced ventilation with heat or energy recovery in select climate zones with higher heating loads. Consider balanced ventilation or supply only ventilation in all climate zones to complement well sealed homes and another proposed measure for reduced infiltration.	SF	HVAC	Proceeding
101	Maximum backup heat lockout temperature: When a heat pump is installed with backup heat, the 2025 code requires a lockout temperature of 35°F above which electric resistance backup heat is not allowed. The proposed change would require that the lockout temperature for all backup heat types be set to the heating design temperature, which is typically much lower than 35°F. The proposal would also require the heat pump be allowed to operate below the lockout temperature down to the minimum temperature of the heat pump's operating range.	SF+MF	HVAC	Proceeding
103	Energy Recovery for Indoor Pool Systems. Require dehumidification and exhaust air energy recovery for indoor pools over 400 square feet. If a dehumidifier is used, all dehumidifier condenser heat must be used for space heating and/or pool heating prior to using primary heating. Exhaust air energy recovery is required if design outdoor airflow is in excess of TBD cfm. The minimum energy recovery shall be 50% when calculated at design conditions.	NR+MF	HVAC	Proceeding
104	Process Boiler #1 Non-condensing Stack Economizer Requirement. Require boiler stack (non-condensing) economizers on new boilers.	NR	Covered Process	Proceeding
105	Process Boiler #2 Conductivity-Based Blowdown and Deaerator Settings. Require acceptance testing on newly installed boilers to ensure that 1) automatic blowdown is programmed to be controlled by conductivity and 2) if site uses steam header to pressurize deaerator, deaerator pressure is within 2-8 psig; otherwise deaerator pressure is at least 2 psig at the deaerator. Exception to (1) for condensate return above 90% (plan review for new construction; for existing systems, can be calculated from conductivity measurements). Scope: Newly installed boilers (including replacement). Boilers larger than 5 MMBTU.	NR	Covered Process	Proceeding
106	Process Boiler #3 Submetering and Monitoring. Require newly installed steam boilers to automatically monitor and log such that data can be accessed in a centralized location: boiler water conductivity, stack temperature, discharge steam pressure, steam flow, feedwater flow, and makeup water flow. When a steam blowoff valve (vent valve, not safety relief valve) is present, require the valve to have automatic leak detection, and monitor vented steam capacity in lbs./hr via a steam flow meter or calculation from vent orifice and valve position. Require newly installed hot water boilers to automatically monitor and log boiler water conductivity, stack temperature, inlet water temperature, discharge hot water temperature, feedwater flow, and makeup water flow. Both steam and hot water boilers must submeter natural gas. Acceptance testing: set alarm for stack temperature > 1.2 times the stack temp at lowest fire. Revise O2 trim acceptance test from 3% O2 to align with current practices to meet air quality regulations by local Air Districts: ultra low NOx burners 7% excess O2, high performance ULNOx 5%, and mesh 11%. Scope: Newly installed boilers, including replacement boilers. Boilers larger than 5 MMBTU.	NR	Covered Process	Proceeding
107	Process Steam #1 Flash Steam. For newly constructed steam systems with design boiler operating pressures ≧100 psig, require at least 50% of flash steam to be recovered (via engineering calculation review) using one or more of the following approaches: 1. Makeup water preheating 2. Deaerator heating with flash steam recovered from boiler blowdown 3. Low-pressure loads served with flash steam from high-pressure condensate 4. Medium-pressure loads served with flash steam boosted in pressure by TVR or MVR 5. Pressurized condensate return system 6. Steam-to-hot-water heat exchanger preheating 7. By other documented means verified through design review Exceptions TBD: scoping exceptions based on plant characteristics (linear ft, number of steam operating pressures, number of high and low pressure users, subsectors) Require design review (similar to 120.8.(c), and/or included in Covered Process 120.6.) Scope: Steam systems with operating pressure above 100psi. New construction or new building at existing site.	NR	Covered Process	Proceeding
108	Process Steam #2 Condensate Return. Require condensate return for new construction where the steam is not in contact with a process. Exception: Where the addition is not adding a new boiler or condensate tank, and distance from the furthest point of the new condensate system to the nearest existing boiler or condensate return tank exceeds 1000 equivalent linear feet. Note to Exception: If existing condensate return tank(s) within 1000 equivalent linear feet are not sized to accept the new quantity of condensate, consider the next nearest condensate return tank or boiler for evaluating this exception. Must show an engineering calculation indicating that existing infrastructure which cannot be changed does not support these requirements. Scope: New construction or new building at existing site. Hydraulic plans will have equivalent feet (equivalent ft. accounts for the effective linear length of fittings). Require design review (similar to 120.8.(c), and/or included in Covered Process 120.6).	NR	Covered Process	Proceeding
110	Compressed Air #1 Air Drying. Require that all desiccant dryers have dew point controls that reduce regeneration based on load. Air compressor systems without air pre-cooling, with a target dewpoint ≧ -100F, should use a heated desiccant dryer (including heated blower purge dryers). Where plan dewpoints are >=40F, a cycling or non-cycling refrigerated dryer shall be specified. Require external reading of dew point or min performance. Air dryer acceptance testing: check air dryer schedule for overlap with plant and air compressor schedule. Desiccant air dryer acceptance testing: set point, and having demand-based regeneration enabled. Refrigerated cycling dryer acceptance testing: ensure that inlet air condition following controls are enabled and that demand-based refrigeration is enabled. Scope: New or replacement air dryers; or new or replacement compressed air plant systems where air dryer replaced or added. Potential exemption for extreme low compressed air usage for winery sector.	NR	Covered Process	Proceeding
112	Covered Process Refrigeration #1 Expand Scope to Include Process Refrigeration. Expand refrigeration scope to refrigeration systems providing design refrigeration capacity ≧20% to process loads ≧240 BTUhr/sf or process loads with no associated square footage, including field-erected, skid-mounted, and unitary packaged refrigeration (UPR) serving spaces >3000 sqft. Require expanded scope to be subject to existing 2025 T24 P6 code: condenser design & control requirements (SCT, approach vs. SCT, condenser sizing, condenser efficiency), evaporator design & control requirements, evaporator specific efficiency, floating head pressure controls, and compressor requirements. Evaluate process load types for exemptions for application or operating hours. Require insulation on outdoor liquid cold storage tanks. Design review: move non-controls acceptance tests to Design Review. Exemption for select advanced controls. Specific to UPR: acceptance test for defrost controls to use liquid run time, except production freezers, advanced defrost, and variable speed.	NR	Covered Process	Proceeding
114	Covered Process Refrigeration #3 Monitoring. Require monitoring for supermarkets, refrigerated spaces and processes, and UPR. Logging required. For refrigerated spaces and processes: For refrigeration systems, monitor suction pressures, condensing pressure, ambient temperature, ambient RH. For compressors: suction pressure, discharge pressure, motor current, slide valve position, cylinder loading, volume index, VFD speed, power (from VFD). For evaporators: actual temperature, liquid solenoid position, fan status and speed, hot gas solenoid position, electric heat status. For condensers: pump status, fan status and speed, condensed liquid temperature. Monitoring data must be reported as actionable intelligence to >= 1 operator console via any combination of local and remote hardware and software. For underfloor heat: underfloor temperatures and on/off status. For glycol: glycol supply and return temperature, pump on/off status, floor or glycol temperature setpoint. Require acceptance testing to ensure monitoring is enabled.	NR	Covered Process	Proceeding
115	Controlled Environment Horticulture HVAC/D #1 Design Review. Require design review of CEH HVAC/D system and require submission of certificate of compliance signed by reviewing party that indicates completion of the design review. Require development of a plan to verify, test, and balance HVAC/D system and control settings. Design review would include review of equipment specification and schedules, load calculations, and HVAC/D system sizing for peak & partial latent and sensible loads. This can be accomplished by removing covered process exemption in 120.8 (and exempting CEH spaces from certain provisions) or requiring design review in 120.6(h). Reviewing party can be engineer of record, engineer with no project involvement, or licensed professional per 10-103, depending on facility size. Scope: Conditioned greenhouses and indoor growing facilities (may limit to CEH facilities with certain size of HVAC/D system).	NR	Covered Process	Proceeding
116	Controlled Environment Horticulture HVAC/D #2 Adding Prescriptive/Performance Approaches. Establish prescriptive HVAC/D requirements in CEH spaces. Provide two or more energy-equivalent prescriptive packages based on HVAC/D system size. At least one package would include federally pre-empted standalone dehumidifiers combined with efficient cooling equipment, and/or rooftop PV requirements (for opaque roofs), and/or circulation fan efficiency. Allow compliance using performance approach (assuming CBECC compliance capability will be developed in time for the 2028 code cycle). Scope: Indoor growing facilities (may limit to CEH facilities with certain size of HVAC/D system). Note: If measure #116 moves forward, it will capture the intent and savings of Measure #61.	NR	Covered Process	Proceeding
117	Outdoor Lighting Requirements Revision. Review and revise hardscape lighting power requirements in Tables 140.7-A and 140.7-B and BUG ratings requirements in 130.2(b). Review the following factors and ensure alignment with most recent ANSI/IES Standards. - The average footcandles for the zone and for the functional area. - The uniformity of illumination within each illuminated hardscape area. - The proportion of lumens that fall within the illuminated hardscape area. - Additional footcandles within a subsection of an illuminated area if needed. - The BUG ratings of Luminaires and exemption (lumen output threshold). - Exempt off-grid lighting from lighting power requirements.	NR+MF	Lighting	Proceeding
121	Add prescriptive HVAC requirements to large hotels. Currently, both hotels and motels must comply with ACM Reference Manual System 1 "Single-phase single-zone system with constant volume fan, no economizer, direct expansion cooling, and gas furnace heating." This measure would separate larger hotels that are more likely to install efficient central systems from System 1 to improve their baseline EE level in the standard design. A prescriptive measure that steers larger hotels away from PTAC/PTHP and toward a more efficient central plant-type system would ensure the standard design matches. It is possible that this measure could also require heat pump PTHP rather than PTAC.	NR	HVAC	Proceeding
123	For Controlled Environment Horticulture facilities update minimum photosynthetic photon efficacy (PPE) requirement from 2.3 to 2.5 micromoles per joule.	NR	Covered Process	Proceeding
125	Add Requirements for Gas/Propane Instantaneous Water Heating. Remove section 170.2 (d) 1. Exception 1 allowing gas or propane instantaneous water heaters in multifamily buildings. Alternatively, require buildings that do this to be Heat Pump Water Heater (HPWH) ready and have enough electrical capacity and space to be converted to HPWH systems. Specifications on what is required for HPWH ready need to be defined.	MF	DHW	Proceeding
127	Allow single and multi pass Heat Pump Water Heaters (HPWHs). Delete Section 170.2 (d) 2. i).	NR+MF	DHW	Proceeding
128	Allow for all configurations listed in the Northwest Energy Efficiency Alliance's Advanced Water Heating Specification (NEEA AWHS). Revise Section 170.2 (d) 2. ii) to read "Heat Pump Water Heating Systems must be installed in accordance with one of the system configurations listed in the NEEA AWHS". This section should be moved where it is mandatory and required in multifamily and nonresidential.	NR+MF	DHW	Proceeding
130	Revise primary storage setpoint temperature. Revise Section 170.2 (d) 2. iv). Set primary storage to at least 140°F or whatever is listed in the systems Product Assessment Data Sheet linked to the NEEA AWHS QPL. This section should be required for multifamily and nonresidential	NR+MF	DHW	Proceeding
131	Recirculation Loop Tank Setpoint: Revise Section 170.2 (d) 2. (v) Recirulation loop tank shall be set to a maximum 130F. This section should be mandatory for MF and NR.	NR+MF	DHW	Proceeding
132	Heat Pump Water Heater (HPWH) Compressor Cut Off Temperature. Revise Section 170.2 (d) 2. (vi). Instead of a compressor shut off temperature, establish a temperature at which the heat pump capacity must be equal to or exceed electric resistance or gas heating in the water heating system. This temperature should be related to either the ASHRAE heating design dry-bulb temperature or a table new table that establishes temperatures for each California climate zone. Colder climates should be required to have heat pump operation down to lower temperatures. This section should be moved where it is mandatory and required in SF, MF, and NR buildings.	NR+MF	DHW	Proceeding
142	Acceptance test procedure improvement for luminaire level lighting controls. Revise the acceptance test procedure to allow more efficient and cost-effective testing for luminaire-level lighting controls when used as a control solution to meet the mandatory lighting control requirements.	NR	Lighting	Proceeding
145	Acceptance Test for Multilevel Lighting Controls. Create an additional acceptance test procedure for multilevel lighting controls.	NR	Lighting	Proceeding
146	Improve Shut-off Controls Acceptance Tests. Add construction inspection to shut-off controls acceptance test procedure to confirm partial-on or vacancy occupant sensing is installed and programmed accordingly as required.	NR	Lighting	Proceeding
147	Lighting Controls Acceptance Test Compliance Forms Improvement. Modify acceptance test compliance form (NRCA) to focus on installation requirements. Specifically, update so questions are based on when devices are required to be installed instead of testing the controls themselves.	NR	Lighting	Proceeding
148	Fan Power Budget Cleanup. Review calculations and adjust values based on experience complying with the 2022 code requirements. Consider editorial adjustments to the tables to improve clarity.	NR+MF	HVAC	Proceeding
150	Make changes to language currently geared toward chillers and boilers to factor in AWHP/WWHP considerations. For example, chiller/boiler isolation language at 140.4(k)2 and 3 would be modified to call out AWHP/WWHP. Though the intent is to focus on prescriptive language, this measure could also investigate mandatory language at 120.9.	NR	HVAC	Proceeding
153	Limit electric resistance use for split and unitary HPWH. Where split system HPWH include electric resistance heating, establish new prescriptive limitations for the size of electric resistance heating and add requirements for controls that limit activation of electric resistance when the heat pump can meet the load alone. Establish requirements for fault detection. Include a performance option to give credit if electric resistance (ER) is not used for supplemental heating or for redundancy/back up for split and unitary HPWH. To receive credit, 1.) Heating plants would not have electric resistance internal or external to the split or unitary HP, and 2.) Projects would meet requirements of a new reference appendix that may include design, installation, start up, and operation considerations.	NR+MF	DHW	Proceeding
154	Requirement for unitary HP/ER hybrid heaters used in centralized applications. Ensure unitary HP/resistance hybrid heaters installed in a centralized Heat Pump Water Heater (HPWH) system with recirculation are specified, installed and commissioned in a way that minimizes electric resistance use. Accounting for climate zone, facility type, application, refrigerant type, equipment and room ventilation options.	NR+MF	DHW	Proceeding
155	Update multifamily prescriptive pathway for R-134a HPWH systems from requiring swing tank configuration to requiring return to primary configuration. When there is a higher performing and reliable baseline HP system configuration that reduces upfront heating plant costs and takes up less space and leads to energy savings, it is worth changing the base case configuration that was allowed when split HPs were emerging and reliability was an unknown or a concern in previous code cycles. Add multifamily prescriptive requirements for alteration/retrofit applications: Develop prescriptive requirements when central HPWH is used to replace a gas system. Mandate data reporting as mandatory requirement. Data reporting would include conditions for defrost and complete range of operation (choose specific parts of NEEA document). Need data collection of relevant operating parameters (i.e. when does electric resistance kick on for each mode, defrost). Include JA 14 clean-up to support this, and making data reporting as mandatory requirements.	NR+MF+SF	DHW	Proceeding
156	Develop an alternative prescriptive pathway for hot water systems without recirculation to reduce losses and inefficiencies associated with the recirculation system, to improve water temperature stratification, to promote clustered systems for large buildings, and to reduce the need for electric resistance swing tanks. Develop a new reference appendix section that may include considerations for acceptable hot water delivery times for all applications.	NR+MF	DHW	Proceeding
158	FEI updates. (1) Update the 2025 FEI provision for 2028 to reference the CFR instead of AMCA 208. (2) Add a requirement that FEI ratings for specified fans be included in appropriate project documentation to help with enforceability. (3) Expand the provision to include circulating fans based on the DOE test procedure (in the CFR). (4) Add a requirement that specified circulating fan data be included in appropriate project documentation to help with enforceability.	NR+MF	HVAC	Proceeding
159	Elevators, Hydraulic VFD pump improvement. Mandatory requirement to place a variable frequency drive so that the hydraulic pump can modulate speed of the pump as the speed (acceleration, deceleration) or the cab rather than a pump running at constant speed and excess flow going through a bleed valve.	NR+MF	Covered Process	Proceeding
160	Add data centers/computer rooms to the lighting power tables in 140.6 (prescriptive requirements for indoor lighting).. Update 130.1 (mandatory indoor lighting controls) to include requirements for lighting in data centers	NR	Covered Process	Proceeding
161	Data center part-load operation. This measure proposes prescriptive requirements to improve mechanical system efficiency in data centers at both full and partial loads. It would mandate variable speed chiller compressors, enhanced variable speed fan controls, and controls for staging equipment based on cooling loads.	NR	Covered Process	Proceeding
162	Data center backup generator heating. This measure would introduce requirements to a) correct supply water port placement and b) forced circulation of liquid throughout the jacket. It would apply to all (over x size, permanently installed) nonresidential diesel backup generators (data centers, hospitals, etc.)	NR	Covered Process	Proceeding
167	Controlled Environment Horticulture Lighting Controls Code Cleanup: Code clarification to indoor lighting control requirement. Excising non-relevant controls. Adding definitions. Impacts 100.1 and 120.6	NR	Covered Process	Proceeding
168	Data center efficiency improvements. 1) Raise the outside air drybulb threshold from 65F to 75F, 2) Raise the outside air wetbulb threshold from 45F to 60F, 3) Delete the requirement that the thresholds be met at 65°F to 80.6°F supply air temperature, 4) Meet ASHRAE 90.4 requirements similar to the National Model Codes and a few other State codes (example Oregon, Washington).	NR	HVAC	Proceeding
169	Residential Cool Roofs. Reassess solar reflectance requirements for roofs and evaluate potential energy savings for implementing a requirement in all climate zones that currently lack one. Define solar reflectance requirement based on the weight of the roof material.	SF+MF	Envelope	Proceeding
170	Electric panel upgrades. For new single family buildings: require a minimum of 32 circuit breaker slots; review BESS-ready requirements and consider whether revisions are necessary to ensure island able capabilities; consider smart panels or breakers for battery installations (or compliance credit); and confirm that the California Electrical Code meets the latest National Electrical Code safety regulations.	SF	Other	Proceeding
171	Require Load Calculations. Require submission of load calculation report to achieve full savings from design measures approved in 2025.	SF+MF	HVAC	Proceeding
174	Heat Pump Water Heating (HPWH) Sizing. Require HPWH sizing based on the First Hour Rating (FHR) of the HPWH with only the heat pump, not the resistive heater, to reduce peak demand and use less resistive heating.	SF	DHW	Proceeding
175	Greenhouse Envelope. Make R-14 the minimum envelope insulation requirement for greenhouses. Require dry hazing agent and auto darkening glazing or shade cloth for greenhouses.	NR	Covered Process	Proceeding
176	Update thermostat requirements, including Sections 110.12 and JA5, after the California Energy Commission completes the flexible demand appliance standards rulemaking that is likely to establish Title 20 requirements for thermostats.	NR+MF+SF	HVAC	Proceeding
177	Improve U-factors for high-rise multifamily buildings to match values used for multifamily buildings. See IECC Proposal CE43.	MF	Envelope	Proceeding
180	Simplified envelope component packages tables. Break table 170.2-A into separate tables by component, reducing fenestration table to U-factors varying by climate zone. For fenestration, reduce table to U-factors (vary by climate zone). Include all other fenestration requirements (no variation by climate zone) in code language, without reference to a table.	MF	Envelope	Proceeding
181	Multifamily Roof Alignment. Align multifamily fenestration requirements with nonresidential requirements for streamlined compliance in mixed use buildings. Potential changes to U-factor and SHGC requirements in climate zones 9 and 11-15. Multifamily Architectural Windows based on weighted average of fixed and operable (per 2022 analysis collapsing these categories). No changes to cool roof requirements.	MF	Envelope	Proceeding
182	Align multifamily and nonresidential roof insulation requirements for streamlined compliance in mixed use buildings. Update U-factors for wood framed roofs in climate zone 3 and 5. Update U-factors for metal buildings in all climate zones.	MF	Envelope	Proceeding
183	Acceptance Testing Update. 1) Require a CEC owned and operated Statewide Acceptance Testing Database; 2) Require CEC owned and operated Statewide Permitting Database; 3) Require CEC to collect all Acceptance Testing forms from any California state owned, leased, or operated building; 4) Increase responsibilities of Acceptance Test Technicians (ATTs) per 2016 code and increase enforcement and data collection.	NR	Lighting	Proceeding
184	Fenestration improvements. Require new construction U-factors for window replacements when certain thresholds are met. Improve U-factors for fixed and operable windows in some climate zones to align with IECC requirements. Provide detailed requirements for air-sealing and insulating around window units in punched openings. Clarify language requiring interlocks for operable windows due to high non-compliance.	NR	Envelope	Proceeding
186	Indoor Air Quality Procedure. Amend Section 403.1 of California Mechanical Code (CMC) to include ASHRAE 62.1 Section 6.3 IAQP as an optional compliance method. The primary focus for the code change will be healthcare facilities and multifamily buildings.	NR+MF	HVAC	Proceeding
187	Humidity control for residential bathroom exhaust fans. Require one of the following: (1) Smart bathroom exhaust fans with built-in humidity sensors and occupancy sensors, or (2) Exhaust Fan Timer Switch that automatically turns the bathroom’s exhaust fan on and off after a set period of time has passed. This requirement is already in Title 24, Part 11 and would move from Part 11 to Part 6.	NR+MF+SF	HVAC	Proceeding
188	Resilient Electrical Infrastructure. Require all new buildings to have electrical wiring and infrastructure that can withstand natural disasters, such as earthquakes and floods.	NR+MF+SF	Other	Proceeding
189	Fire and Water Resistant Service Equipment and Electrical Rooms. (No further description was provided by submitter.)	NR+MF+SF	Other	Proceeding
190	Smart Electric Vehicle Charging. Require buildings to install Smart Chargers for bidirectional energy flow such as V2G (Vehicle to Grid), V2H (Vehicle to Home), and V2X (Vehicle to Everything i.e. any grid connected devices). This change could provide an emergency backup power supply and improve resilience.	NR+MF+SF	Other	Proceeding
191	Temper resistant (TR) Receptacles with Arc-fault circuit interrupters (AFCIs) and Ground fault circuit interrupters (GFCIs) Protection. It could be included in Title 24, Part 6 or Title 24, Part 11.	NR+MF+SF	Other	Proceeding
192	Develop and require a set of metrics and benchmarks to measure and compare the resilience of buildings, similar to energy credit requirements.	NR+MF+SF	Other	Proceeding
193	Resilience Score/Metrics and Benchmarking Credits. Develop tools to benchmark resilience against industry standards and best practices.	NR+MF+SF	Other	Proceeding
194	Residential Lighting Controls. Require a control at the main entry or from remote locations outside of the home (e.g., phone app) for turning off all permanently installed lighting with exceptions for lighting controlled with occupancy sensors. This would apply to large homes for over 5,000 SF and align with ASHRAE 90.2 and ASHRAE 90.1 Energy Credit.	SF+MF	Lighting	Proceeding
195	Energy Monitoring Requirements. Revise Section 130.5(b) to require electric submeters (rather than just separation of electrical circuits) to the specified circuits to align with the International Energy Conservation Code (IECC), ASHRAE Standard 90.1, and Washington State’s energy code. Would not change power distribution requirements. It would only add energy monitoring equipment as described in Table 130.5-B, to: 1) Ensure metering standards support demand management and define acceptable accuracy for tracking peak building kW demand; 2) Allow energy metering and load separation to improve energy awareness and the ability to properly manage energy usage within a building; and 3) Easily identify where electrical energy is being wasted.	NR	Other	Proceeding
196	HVAC Fault Detection and Diagnostics (FDD). Establish mandatory FDD requirements in HVAC systems in newly constructed buildings over 100,000 square feet. Key Requirements: - Continuous Monitoring: Uses permanently installed sensors to track HVAC components, including motors, valves, and dampers. - Frequent Sampling: Collects performance data at least every 15 minutes. - Automated Fault Detection: Identifies issues such as simultaneous heating and cooling, leaking valves, and stuck dampers using algorithmic-based diagnostics. - Real-Time Alerts: Notifies authorized personnel and provides prioritized repair recommendations. - Remote Access & Tracking: Enables fault history tracking and remote transmission of repair actions. - Exception: Applies to R1 and R2 occupancies.	NR	HVAC	Proceeding
197	Automated shades. Update Sections 140.3, 170.2, and 150.1 of Title 24, Part 6 to require that permanently installed automated shading, including but not limited to interior or exterior window shades, blinds, louvers, drapes, or integrated shades be permitted to contribute to meeting the Solar Heat Gain Coefficient (SHGC) requirements, similar to how chromogenic glazing is applied. Reference Attachment Energy Rating Council (AERC) 1 Procedures for Determining Energy Performance Properties of Fenestration Attachments for how to calculate the combined SHCG of the windows. For Title 24, Part 11 (CALGreen), implement automated window shading/dynamic glazing in new commercial buildings with large glass facades to reduce heat gain and cooling loads; includes manual override features for occupant comfort and flexibility. Require automated shading, similar to what is required in ASHRAE Standard 189.1 and IGCC. This would require a new section under Environmental Quality and/or Energy Efficiency.	NR+MF+SF	Envelope	Proceeding
198	Allow campuses to comply with existing solar and solar requirements in Title 24, Part 6 using systems that are not located on the building itself or the building site. Rather, the solar and storage systems can be located on the same campus as the building that is being permitted. Under certain circumstances, the solar and storage system can be located outside of the campus in another location.	NR+MF	Generation / Storage	Proceeding
199	Flood-Resistant Mechanical Systems: HVAC and plumbing systems shall be designed to withstand exposure to saltwater and flooding, utilizing corrosion-resistant materials in coastal areas.	NR+MF+SF	Multiple	Proceeding
200	Passive House Alternative. If a building is certified by the Passive House Institute or the Passive House Institute US (PHIUS), then the building also complies with Titel 24, Part 6.	NR+MF+SF	Envelope	Proceeding
201	Clarify electric ready cooking requirements. 1) Either revise 160.9(c) and 150.0(u) to refer to "cooktop and range", or clarify via definition that the term "cooktop" includes ranges.(2) Consider reducing circuit size to either 50A 240v if no range/cooktop is installed, or if the unit is installed then the circuit may be sized per manufacturer's instructions. (3) Extend the electric-ready requirement in (2) above to alterations where kitchen cabinets are replaced or the remodel scope of work includes rewiring the kitchen/cooking area.	SF+MF	Other	Proceeding
202	Require all pools to be insulated	NR+MF+SF	Other	Proceeding

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