Controlled Environment Horticulture: Space Conditioning Systems for Indoor CEH
Measure Overview
This proposed measure would establish new mandatory sizing, functional, equipment, and controls requirements for space conditioning systems serving Indoor Growing spaces in Controlled Environment Horticulture (CEH) facilities. These systems provide cooling, heating, dehumidification, reheat, heat recovery, heat rejection, and airflow control to support plant growth.
The proposal applies to Indoor Growing spaces, a subtype of CEH space where actively growing plants are cultivated, not to greenhouse cultivation spaces or to non-cultivation spaces within a CEH facility. Other facility spaces, such as drying rooms, processing rooms, packaging rooms, offices, corridors, restrooms, break rooms, storage rooms, and support spaces, would continue to be subject to applicable nonresidential requirements based on occupancy and space type.
The new high-intensity Indoor Growing HVAC/D requirements would apply to facilities with at least 5,000 square feet of indoor plant canopy area served by horticultural lighting with power density greater than or equal to 30 watts per square foot of plant canopy area. The proposal would establish mandatory requirements only, clarify that Indoor Growing spaces are not subject to nonresidential prescriptive HVAC or envelope requirements, and would not allow performance-based HVAC/envelope tradeoffs for Indoor Growing. The proposal also establishes a California rating, test, and certification pathway for commercial dehumidifiers used in Indoor Growing spaces.
Table 1 summarizes the scope of the proposed code change. Note that this proposal includes acceptance testing performed by a field technician. Because the field technician is typically a member if the installation team, this acceptance testing is not considered “third party verification.”
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Scope of Proposed Code Change
| Building Type(s) | Construction Type(s) | Type of Change | Updates to Compliance Software | Third Party Verification |
| Nonresidential | New construction, additions, alterations | Mandatory | no updates | No changes to third party verification |
Justification for Proposed Change
CEH facilities with high lighting power density are among the most energy-intensive building types in California. Lighting and space conditioning systems make up about 80 percent of energy consumption, split roughly evenly between the two systems. For indoor cannabis facilities, flower rooms contribute roughly 86 percent of facility energy use, and a field study of two California indoor growing facilities found an average flower-room Energy Use Intensity of 760 kBtu/yr-ft².
Space conditioning systems serving Indoor Growing must adapt to highly variable latent and sensible loads, requiring different controls, sizing methods, equipment configurations, and design assumptions than comfort-conditioning systems. The proposal would improve performance for integrated and coordinated decoupled systems by establishing enforceable requirements for sizing, controls, equipment qualification, heat recovery, and acceptance testing. It would also address a regulatory gap for commercial dehumidifiers. Statewide CASE Team modeling indicates that annual HVAC/D energy use can be reduced by approximately 25 percent compared with a fully decoupled, code-minimum system, while more precise temperature and humidity control can support higher yields, reduce mold risk, and help avoid crop loss.
Relevant Documents
CASE Reports
Round Two Utility-Sponsored Stakeholder Meeting Materials
Round One Utility-Sponsored Stakeholder Meeting Materials
- Controlled Environment Horticulture: Space Conditioning Systems for Indoor CEH– Proposal Summary
- September 24, 2025 – Meeting Notes
- September 24, 2025 – Presentation Slides
Other Resources
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Give Us Your Feedback
The Statewide CASE Team values input from all stakeholders engaged in the Title 24, Part 6 code change process. We encourage the open exchange of code change comments and concerns.