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Measure Description

The focus of the nonresidential grid integration CASE Report is to adjust the demand response control requirements so buildings that comply with Title 24, Part 6 are more likely to use their controls to participate in demand response events, including pricing events. This will help ensure that newly constructed nonresidential buildings are contributing to grid reliability in a positive way, which is critical as California aims to achieve its renewable portfolio goals.

Demand Responsive Lighting Systems

This measure reevaluates the cost-effectiveness threshold of requiring automated demand responsive controls on nonresidential indoor lighting loads. In the 2019 Title 24, Part 6 Standards, demand responsive lighting is a mandatory requirement that impacts all nonresidential facilities, except spaces where health and safety statue, ordinances, or regulations do not permit the lighting to be reduced, such as hospitals or other healthcare applications. All new construction facilities greater than 10,000 square feet, excluding spaces that have an LPD less than or equal to 0.5 watts per square foot and are subject to the aforementioned safety statues, must install demand responsive controls. This submeasure proposes to replace the 10,000 square foot thresholds with a cost-effective wattage threshold to better capture the demand responsive savings of nonresidential facilities. Alterations and additions are subject to the same thresholds but include additional exemptions, as listed in 2019 Title 24, Part 6 Section 141.0 (b)2.I.iii.c., that would not be changed. 

The proposed measure would change the language in Section 110.12(c) Demand Responsive Lighting Controls. Adjusting the exemption language based on the results of the cost-effectiveness analysis which would replace the 10,000 square foot delineation with a cost effective total designed wattage and tie the current 0.5 watts per square foot delineation with the 0.5 watts per square foot exemption of the multi-level lighting controls in Section 130.1(b).  

Total designed wattage, as defined in the Section 140.6(a) of Title 24, Part 6, was chosen to replace square footage as the primary demand responsive threshold as this metric more effectively captures the direct saving potential of demand responsive lighting. While square footage has historically been the exemption of choice, this shift would allow a more direct relationship between the exemption and the cost effectiveness of the measure.  

No changes to the compliance software would be made.  

Clarifications to the acceptance test are included in the proposed change to better elucidate the acceptance test requirements, such as removing the 50 percent illuminance threshold of the full output test that was stipulated in the acceptance test but not in the Energy Efficiency Standards. A third acceptance test method is introduced that can be conducted at the full building level for qualified buildings with disaggregated circuits by end-use, introducing this third method should expedite acceptance testing when this method is applicable. Finally, the term “non-habitable” is removed from the demand responsive lighting power allowance factor (PAF) requirements along with additional clarifications to the demand responsive lighting PAF section to allow the PAF to be applicable to facilities and spaces that were not required to implement demand responsive lighting. This term is not applicable to the nonresidential measure and its counterpart in the mandatory requirements was removed in the 2016 Title 24, Part 6 code cycle.  

Heat Pump Water Heaters

This CASE Report discusses proposed code changes for HPWHs systems installed in nonresidential buildings. Nonresidential HPWH systems include both integrated (with tank) HPWH units and central HPWH systems commonly configured as split systems, with separate storage tank and pump. Nonresidential buildings include all building types currently modeled in CBECC-Com, including hotels/motels and high-rise multifamily. The proposed changes extend compliance credit to these systems, which can store thermal energy and allow occupants to shift overall building electric consumption with limited impact on comfort. The Statewide CASE Team proposes to add scheduling control in the California Building Energy Code Compliance for Commercial (CBECC-Com) modeling software to enable operation with utility time-of-use or critical peak pricing rates, and to enhance the ability to participate in DR events. The proposals are to help newly constructed nonresidential buildings contribute positively to grid stability, which is critical as California aims to achieve its renewable portfolio goals and building zero net energy goals.  

Thermal Energy Storage Systems

To enable load shifting, the Statewide CASE Team proposes allowing compliance credit for TES technologies beyond the existing chilled water systems by adding features to the compliance software for these additional systems. TES including phase change materials and ice storage enable a building to shift electricity use across hours of the day based on time-of-use or critical peak pricing rates and grid needs. The specific compliance options being considered include modifications to TES algorithms and compliance software updates for HPWH with grid connectivity.  

Communication Protocol Cleanup

Amend Section 110.12(a)2 to allow for any bi-directional communication protocols instead of limiting the allowable communication methods to only Wi-Fi, ZigBee, BACnet, Ethernet, or hard-wiring as 2019 Title 24, Part 6 requires. Additionally, remove Section 110.12(a)3 and 110.12(a)4 as they either describe additional features a product can have aside from those required in a minimally compliant facility (110.12[a]3) or provide superfluous language that only adds to the complexity of the standard (110.12[a]4). 

Submeasures Moved to Future Code Cycles

The Statewide CASE Team is no longer pursuing the proposed changes listed below.

Outdoor Lighting Demand Management

The demand management control requirements for lighting systems only addresses indoor lighting. This measure review would explore the cost-effectiveness of including mandatory requirements for outdoor lighting demand management.

Alternative HVAC Control Strategies: Compressor Control

The focus of the nonresidential grid integration CASE initiative is to adjust the demand response control requirements so buildings that comply with Title 24, Part 6 are more likely to use their controls to implement load management on a day to day basis, as well as participate in reliability or economic demand response events. This will help newly constructed nonresidential buildings contribute to grid reliability in a positive way, which is critical as California aims to achieve its energy and climate goals.

Currently, demand responsive controls for HVAC must be capable of increasing or decreasing temperature setpoints by four degrees. This requirement would remain in place, so at a minimum DR controls would be required to enable temperature adjustments to non-critical zones and this temperature adjustment strategy is verified through acceptance testing.

Temperature setpoint adjustments are the most common load management strategy for nonresidential buildings, but other control strategies focusing on specific HVAC equipment exist that offer more direct and focused load management.The current code requires that building have the capability of automatically adjusting temperature setpoints when a Demand Response (DR) Signal is received and that a specific temperature adjustment strategy be programmed into the control system at the time that acceptance testing is conducted.This measure aims to add an alternative pathway to comply with the HVAC DR control requirements to allow a load management strategy that limits the capacity of variable speed compressors. Adding this alternative control strategy enables a building to implement HVAC DR controls that best fits the buildings capabilities.Allowing for successful participation in DR programs at the time that the controls are installed and minimizing a need for reprogramming after the Title 24, Part 6 acceptance tests are complete.

The alternative control strategy will be designed such that the temperature change in the zone will remain within a comfortable range.

In addition to adding an alternative control strategy, this measure aims to realign Title 24, Part 6 language so it is more consistent with how HVAC controls commonly manage loads in nonresidential buildings. Specifically, the Statewide CASE Team is making the following recommendations:

  • Revise language to clarify that the demand responsive controls for HVAC systems can either be controlled through the energy management control system (EMCS) or directly through the HVAC system zone controller.
  • Revise the term “demand shed control” to reflect the new reality that load management does not always call for load to be reduced or shed

Materials that the Statewide CASE Team developed when investigating this code change for the 2022 code cycle will be moved to the Future Code Cycles section of this website. Follow this link to find materials on

Relevant Documents

Measure proposals, supporting documents, and other outside references will be made public as they become available.

Round Two Utility-Sponsored Stakeholder Meeting Materials

Round One Utility-Sponsored Stakeholder Meeting Materials

Provide Feedback

Draft CASE Report Now Available (Comments accepted until June 19, 2020)

This measure description will be updated as research is developed to support the 2022 code cycle. For questions or suggestions, email Include the measure name in the subject line.


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.

  • Use the form above to provide feedback on this measure.