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Existing Buildings – No Longer Being Considered for the 2025 Code Cycle

Proposal Description

Increasing efficiency for new construction is important, but the number of existing buildings dwarfs new construction; to meet statewide emissions reduction goals, the efficiency of existing buildings must be improved. The Statewide CASE Team recognizes this and aims to address existing buildings as part of the 2025 code cycle. Different exceptions have been added throughout the code over multiple code cycles for various reasons. Some of those exceptions are no longer appropriate and simply limit possible energy savings. This proposal addresses one primary exception; all other exceptions were reviewed and reserved for the next code cycle.

Aligning with requirements in ASHRAE 90.1, this proposal would impose a commissioning requirement for both additions and alterations. Whole building commissioning for new construction is already identified in the code; this measure would expand this requirement to existing buildings, but only system-wide commissioning for mechanical, plumbing and electrical systems, and envelope when more than 50% of the roof or wall assembly is altered.

Data Needs/Stakeholder Information Requests

The Statewide CASE Team would appreciate information and data from stakeholders on the following topics:

  • Technical Feasibility
    1. Are there issues with adding system commissioning requirements for alterations or additions
    2. What potential non-compliance measures are common in CA?
    3. Do you have any resources, or can you provide reliable savings information to prescreen the non-compliance measures?
    4. Are there any technical difficulties in implementing current code new construction compliant technologies in existing buildings?
  • Market Readiness
    1. Is system commissioning new to the market?
    2. How can we leverage the existing building commissioning process (such as retro-commissioning, re-commissioning, monitor-based commissioning, ongoing commissioning) to this proposal?
  • Non-energy Benefits
    1. Do you know of any studies or data on improved health benefits of this measure (in terms of improved air quality, removed health hazards, increased productivity, enhanced thermal comfort, reduced water consumption etc)?
    2. Do you know of any resources on increased revenue (direct or indirect) due to enhanced performance?
  • Costs
    1. What is the prevailing cost/sq.ft. for each type of existing building commissioning process?
    2. What are the key factors that impact the commissioning cost (building size, system type, capacity and size, controls, interaction between the systems, replacement of existing outdated technologies, training the facility personnel, hiring Cx agents, project management costs)?

Data may be provided anonymously. To participate or provide information, please email Maureen Guttman, [email protected], directly and CC [email protected].

Relevant Documents

CASE Report

Round Two Utility-Sponsored Stakeholder Meeting Materials

Round One Utility-Sponsored Stakeholder Meeting Materials

Provide Feedback

Submit feedback and view the Energy Commission's proceedings and available proposed code language by visiting their 2025 Building Energy Efficiency Standards page.

This measure page will be updated as the 2025 code cycle progresses. For questions or suggestions, email [email protected]. Please 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.

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