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Nonresidential High Performance Envelope

Measure Description

This CASE Report  for high performance envelope consists of fourth different submeasures: opaque envelope performance, roof alterations, cool roofs, and high performance windows. A fifth submeasure, thermal bridging, was investigated and then moved to a future code cycle. Each is described in more detail below.

High Performance Windows

This measure proposal considers updates to the U-factor and solar heat gain coefficient (SHGC), for windows in nonresidential buildings while recognizing that updates are most critical in heating and cooling dominated climate zones. 

The structural, thermal, and optical characteristics of fenestration influence total energy performance in buildings. The California Energy Code already sets requirements for U-factors, SHGCs, visible transmittance (VT) and air leakage for fenestration products and exterior doors in Section 110.6(a) of Title 24, Part 6. This measure proposal evaluates improvements to the requirements of this key envelope component.  

This submeasure would also revise the relative solar heat gain coefficient (RSHGC) requirement to offer credit for both fixed exterior horizontal slats (louvers) and overhangs based on an equation derived from updated Time-Dependent Valuation (TDV) energy values. This revision will also eliminate unexpected characteristics of the current formula and create consistent terms between the RSHGC equation, overhang exception and Daylighting Design Power Adjustment Factors. This portion of the submeasure was formerly known as “Refine Prescriptive Exterior Shading Reflective Solar Heat Gain Coefficient Requirements” under the 2022 Daylighting measure proposed by the Statewide CASE Team. 

Improving the performance of windows could improve daylighting, occupant comfort, and overall envelope efficiency. 

Opaque Envelope Performance

Opaque envelope is a prescriptive measure that would require changes to compliance software but would not require new field verification tests. This proposal looks at modifying Table 140.3-B, 140.3-C of Title 24, Part 6. This measure re-evaluates existing assembly U-factor requirements for the 2022 code cycle using the latest cost parameters. This re-evaluation includes all components of the opaque envelope, including walls, roofs, floors, and opaque doors, using nonresidential building prototypes to determine if cost-effective reductions in U-factor are justified in all climate zones. 

Roof Alterations

This proposal would update the prescriptive insulation requirements for roof alterations in the following ways: 

  • Require U-0.049 for Climate Zones 6-8 and U-0.034 for Climate Zones 1-5, & 9-16 to align with new construction requirements; 
  • Require insulation of at least R-8 for roof recovers if the U-factors above are not met; 
  • Modify the exception for limited base flashing height for mechanical equipment to only apply in Climate Zones 3-9 if it is not practical to install insulation below deck; 
  • Strike exception for limiting the amount of insulation at penthouse and parapet walls due to base flashing height; and 
  • Add a field inspection to verify existing insulation and the installment of new insulation.  

In 2018, it became possible to fully deduct the expense of roof replacements in the year completed, rather than over a 39-year period, which makes it significantly more affordable to replace roofs and add insulation. Adequate insulation levels increase the effectiveness of the building envelope and reduce the energy required to maintain the temperature in conditioned space. Adding insulation during a roof replacement is the most cost-effective time to do so and is a key component for California to achieve its carbon reduction goals. 

Cool Roofs

The cool roof measure proposes updates to the existing prescriptive cool roof requirements for nonresidential buildings. This initiative would evaluate requirements for both low-slope roofs (ratio of rise to run of less than 2:12; 9.5 degrees from horizontal) and steep-slope roofs (ratio of rise to run of greater than or equal to 2:12; 9.5 degrees from horizontal) for new construction, additions, and alterations.  

For low-slope roofs, the Statewide CASE Team is proposing raising the minimum aged solar reflectance from 0.63 to 0.70, raising the aged Solar Reflectance Index (SRI) from 75 to 85 and keeping the thermal emittance level at 0.75. For steep-slope roofs, the Statewide CASE team is proposing raising the minimum aged solar reflectance from 0.20 to 0.25, aged SRI from 16 to 23, and the minimum thermal emittance from 0.75 to 0.80.  

The Statewide CASE Team has determined that these more stringent requirements are appropriate and cost-effective given updated product availability and product costs. Stricter reflectance, emittance, and/or SRI standards will reduce the energy needed to heat and cool non-residential buildings which in turn will allow building proprietors and occupants to save money and reduce their carbon emission footprint. 

Submeasures Moved to Future Code Cycles

The Statewide CASE Team is no longer pursuing the proposed changes listed below as it was determined that they did not meet the Energy Commission’s requirements for market readiness, technical feasibility, cost-effectiveness, or enforceability at the time they were considered.

Thermal Bridging

Nonresidential thermal bridging was considered because of the potential for significant energy use reductions. Thermal bridging energy impacts are not currently considered in CBECC-Com or Title 24, Part 6.

The Statewide CASE Team is not pursuing this measure due to significant concerns about the absence of a nonresidential registry or third-party entity ready to perform field inspection and verification by 2022 nor an established format for professionals to sign off that calculations had been properly performed.

This measure could harmonize the Energy Code with an addendum under development by ASHRAE 90.1, but the relevant proceedings are not expected to be available in time to leverage them.

To support ongoing research and future code cycle consideration, additional information on nonresidential thermal bridging can be submitted to the Statewide CASE Team through This measure may be pursued through CalGreen (Title 24, Part 11).

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 thermal bridging.

Relevant Documents

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

CASE Report

Round Two Utility-Sponsored Stakeholder Meeting Materials

Submeasure Summaries

Round One Utility-Sponsored Stakeholder Meeting Materials

Submeasure Summaries

Provide Feedback

Draft CASE Report Now Available (Comments accepted until August 21, 2020)

Complete a 20 minute survey about this measure and receive a $10 check or donation to Habitat for Humanity.

Click here to take the survey.

Most questions in this survey seek to understand what roofing products are most popular in the California commercial market. The survey also asks respondents to provide cost estimates for roofing products at different reflectance levels. There are additional questions in the survey asking about insulation levels in existing buildings, as well as other concerns related to the high performance windows and opaque envelope proposals.


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.