DOCKETED  
Docket Number:  24-BSTD -01 
Project Title:  2025 Energy Code Rulemaking  
TN #:  255315 -4 
Document Title:  Initial Statement of Reasons for the proposed changes to the 
2025 Building Energy Efficiency Standards  
Description:  Initial Statement of Reasons for the proposed changes to the 
2025 Building Energy Efficiency Standards.  
Filer:  Javier Perez  
Organization:  California Energy Commission  
Submitter Role:  Commission Staff   
Submission Date:  3/28/2024 12:28:36 PM  
Docketed Date:  3/28/2024  
 STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY  Gavin Newsom, Governor  
 
CALIFORNIA ENERGY COMMISSION   
715 P Street  
Sacramento, California 95814  
 
energy.ca.gov  
 
CEC -057 (Revised 1 /21)
INITIAL STATEMENT OF REASONS  
 
PROPOSED REVISIONS TO THE CALIFORNIA  
BUILDING ENERGY EFFICIENCY STANDARDS  
 
2025 CALIFORNIA ADMINISTRATIVE CODE  
2025 BUILDING ENERGY EFFICIENCY STANDARDS  
CALIFORNIA CODE OF REGULATIONS, TITLE 24,  
PART 1 , CHAPTER 10,  and PART 6  
(2025 CALIFORNIA ENERGY CODE)  
 
Docket No. 24-BSTD -01 
 
INTRODUCTION  
Notice is hereby given that the California Energy Commission (CEC) proposes to adopt 
changes to the Building Energy Efficiency Standards  contained in the California Code of 
Regulations (CCR), Title 24, Part 6 (also known as the California Energy Code ) and  
associated administrative regulations in Title 24, Part 1, Chapter 10 , after considering all 
recommendations, comments, and objections regarding the proposed action. A 
description of the proposed standards is provided in the Informative Digest below.  
 
INFORMATIVE DIGEST  
The Warren -Alquist Act (California Pub lic Resources  Code Sections 25001 et seq.) 
establishes the CEC  as California’s primary energy policy and planning agency. Public 
Resource Code Sections 25213, 25402, 25402.1, 25402.4, 25402.5, 25402.8, 25910, 
25942, and 25943 mandate and/or authorize that the CEC adopt rules and regulations, 
as necessary, to reduce the inefficient consumption of energy and water in newly 
constructed buildings and certain additions and alterations to existing buildings.  
  
One of the ways the CEC satisfies this requirement is through the California Energy 
Code (California Code of Regulations, Title 24, Part 6) found in the California Building 
Standards Code, which are adopted pursuant to Health and Safety Code Sections 
18930 , 18934, and 18935 and, where applicable, the California Environmental Quality 
Act, California Public Resources Code Sections 21000 et seq . The Energy Code 
includes all the energy efficiency requirements applicable to newly constructed buildings 
and additi ons and alterations to existing buildings. As a portion of the California Building 
Code (Title 24), the Energy Code (Title 24 , Part 6) follows the same three -year update 
cycle.  
  
 
 The CEC is initiating its next triennial rulemaking proceeding for updat ing the Energy 
Code, and the CEC proposes to adopt amendments for publication in 2024 with an 
effective date of January 1, 2026.   
 
The proposed amendments to the 2025 Energy Code would:  
 
• Introduce prescriptive  heat pump requirements  for select nonresidential existing 
building types.  
• Update  prescriptive heat pump requirements  for newly constructed single -family, 
multifamily, and select nonresidential building types.  
• Update  solar  photovoltaic system standards for residential, nonresidential and 
hotel and motel buildings.  
• Update  energy storage standards for high -rise residential, nonresidential, and 
hotel and motel buildings.  
• Increase  envelope efficiency standards for residential and nonresidential 
buildings.  
• Increase  space conditioning system efficiency and control standards for 
residential and nonresidential buildings.  
• Improve indoor air quality requirements for multifamily buildings  by requiring 
balanced or supply -only ventilation systems and compartmentalization leakage 
testing, as well as a prescriptive standard for energy/heat recovery ventilation 
systems with a fault indicatory display.   
•  Introduce prescriptive  heat pump requirements for individual domestic water 
heating systems  serving individual dwelling units  in low rise multifamily buildings .  
• Establish  electric -ready requirements for multifamily domestic water heating 
systems.  
• Simplif y standards for multifamily buildings.  
•  Introduce options for improving efficiency of pool and spa water heating 
systems.  
• Increase  daylighting control requirements for nonresidential buildings.  
• Increase  efficiency standards for laboratories.  
• Increase  efficiency requirements for controlled environment horticulture buildings.  
• Increase  efficiency requirements for nonresidential refrigeration systems.  
• Establish industrial pipe insulation requirements.  
• Establish  electric -ready requirements for commercial kitchens. Make general 
improvements to the clarity and consistency of existing provisions.  
• Relocate  portions of the Alternative Calculation Method Approval Manual 
pertaining to the application, approval, updates, expiration, and decertification of 
third-party compliance software to Title 24, Part 1.  
• Relocate field verification and diagnostic testing requirements from Title 20 to 
Title 24, Part 1.  
• Make general improvements to the clarity and consistency of existing provisions.   
 These amendments are significant to the State of California in that they support State 
clean energy goals, policies, and legislation. These amendments will increase the 
deployment and grid benefits of on -site renewable energy generation, increase flexibility 
of energy demand, reduce carbon emissions from new buildings (building 
decarbonization), reduce growth in energy demand, and ensure  that California buildings 
are as energy efficient as possible while also being technically feasibl e and cost -
effectiv e.  
 
STATEMENT OF SPECIFIC PURPOSE, PROBLEM, RATIONALE and BENEFITS  
Government Code Section 11346.2(b)(1) requires “a statement of the specific purpose 
of each adoption, amendment, or repeal, the problem the agency intends to address, 
and the rationale for the determination by the agency that each adoption, amendment, 
or repeal is necessary to carry out the purpose and address the problem for which it is 
proposed. The statement shall enumerate the benefits anticipated from the regulatory 
action, including the benefits or goals provided in the authorizing statute.”  
 
The problem that the CEC seeks to address in adopting building energy efficiency 
standards is enumerated in its enabling statute. The legislative findings in the Warren -
Alquist Act includes, in part, the following:  
 
§ 25000.1(a) The Legislature further finds and declares that, in addition to their other 
ratepayer protection objectives, a principal goal of electric and natural gas utilities' 
resource planning and investment shall be to minimize the cost to society of the reliable 
energy services that are provided by natural gas and electricity, and to improve the 
environment and to encourage the diversity of energy sources through improvements in 
energy efficiency and development of renewable energy resources, such as w ind, solar, 
and geothermal energy.  
 
§ 25001. The Legislature hereby finds and declares that electrical energy is essential to 
the health, safety and welfare of the people of this state and to the state economy, and 
that it is the responsibility of state government to ensure that a reliable supply of 
electrical energy is maintained at a level consistent with the need for such energy for 
protection of public health and safety, for promotion of the general welfare, and for 
environmental quality protection.  
 
§ 25002. The Legislature further finds and declares that the present rapid rate of growth 
in demand for electric energy is in part due to wasteful, uneconomic, inefficient, and 
unnecessary uses of power and a continuation of this trend will result in serious 
deplet ion or irreversible commitment of energy, land and water resources, and potential 
threats to the state's environmental quality.  
 
§ 25007. It is further the policy of the state and the intent of the Legislature to employ a 
range of measures to reduce wasteful, uneconomical, and unnecessary uses of energy, 
thereby reducing the rate of growth of energy consumption, prudently conserve energy 
resources, and assure statewide environmental, public safety, and land use goals.  
  
 § 25008. It is further the policy of the state and the intent of the Legislature to promote 
all feasible means of energy and water conservation and all feasible uses of alternative 
energy and water supply sources.  
 
While the specific purposes of individual amendments are described below, the overall 
purpose of the adoption of new amendments to the Energy Code is “to reduce the 
wasteful, uneconomic, inefficient, or unnecessary consumption of energy, including the 
energy associated with the use of water, and to manage energy loads to help maintain 
electrical grid reliability” consistent with the express statutory authority and direction in 
§25402, which benefits the state by slowing demand growth, reducing depletion of 
resources, improving reliability, minimizing costs, and mitigating threats to the state’s 
environmental quality – that is, by directly addressing the problems the legislature 
observed when creating the CEC. Based on the evidence in the record, the CEC has 
determined that the proposed changes are necessary to provide these benefits by 
establishing or improving standards for building energy efficiency and improving the 
likelihood of successful deployment of building design and construction measures that 
direc tly cause or indirectly enable improved efficiency during occupancy and operation.  
 
Evidence in the record further shows the proposed efficiency standards to be technically 
feasible for buildings in California, cost effective where they are proposed to be 
required, and will save significant energy on an annual statewide basis.  
 
GENERAL PURPOSE AND NECESSITY STATEMENT  
 
Sections:  Part 1 and Part 6 (Including Reference Appendices)  
Specific Purpose: The purpose of this change is to help clarify the implementation of 
the new section in the Energy Code, Title 24, Part 1, Section 10 -103.3. This is 
accomplished by replacing "HERS" with "ECC -" or "field verification and diagnostic 
testing" where appropriat e and replacing the reference to the HERS regulations (Title 
20) with a reference to Title 24, Part 1, Section 10 -103.3. These changes appear 
throughout the Parts 1 and 6 (including the Reference Appendices: Joint Reference 
Appendix, Residential Reference Appendix, and Nonresidential Reference Appendix) of 
the Energy Code and this is intended to identify the purpose and necessity as a 
consolidated grouping.  
 
Necessity:  This change is necessary to maintain a clear intention and implementation 
of the Energy Code with the new section, Title 24, Part 1, Section 10 -103.3. This 
change is consistent with the requirements of California Government Code 11349 and 
11349.1 and Calif ornia Code of Regulations title 1, Section 16.  
 
Sections :  Part 1 and Part 6 (Including Reference Appendices)  
 
Specific Purpose : The purpose of this change is to help clarify the implementation of 
the Energy Code. There are proposed changes throughout Part 1 and Part 6 that make 
non-substantive changes, for example: formatting changes, comma changes,  
 connective phrases, and other grammatical alterations. These changes appear 
throughout Parts 1 and 6 (including the Reference Appendices: Joint Reference 
Appendix, Residential Reference Appendix, and Nonresidential Reference Appendix) of 
the Energy Code , this is intended to identify the purpose and necessity as a 
consolidated grouping.  
  
Necessity : This change is necessary to maintain a clear intention and implementation 
of the Energy Code  
 
Sections :  Part 1 and Part 6 (Including Reference Appendices)  
 
Specific Purpose : The purpose of this change is to help clarify the implementation of 
the Energy Code. There are proposed changes throughout Part 1 and Part 6 that make 
non-substantive changes, for example: rewording the edits in the entire code from 
“exemptions, ” “exempt ,” and “ exempted ” being replaced by “not required. ” These 
changes appear throughout Parts 1 and 6 (including the Reference Appendices: Joint 
Reference Appendix, Residential Reference Appendix, and Nonresidential Reference 
Appendix) of the Energy Code, this is intended to identify the purpose and necessity a s 
a consolidated grouping.  
  
Necessity : This change is necessary to maintain a clear intention and implementation 
of the Energy Code  
 
TITLE 24, PART 1, CHAPTER 10 PROPOSED AMENDMENTS  
 
Section:  Section 10 -102 
Specific Purpose: Update definition of Alternative Calculation Method to add reference 
to 10 -116.  
Necessity : This definition was updated due to the addition of Section 10 -116 Third 
Party Alternative Calculation Method Compliance Software, which was moved from the 
ACM Approval Manual to the Energy Code. The definition now includes references to 
Section 10 -109 an d 10-116. 
Section:  Section 10 -102 
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by adding several new definitions.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The new definitions (Energy Code Com pliance  (ECC), ECC -
Provider, ECC -Rater, and  ECC -Rater  Company ) assign separate responsibilities and 
requirements to each ECC participant, increasing the robustness of the overall program 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
Section:  Section 10 -102  
 Specific Purpose : The purpose of this change is to remove definitions associated with 
the Home Energy Rating System (HERS) program from within the Energy Code.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The change clarifies the ECC Program is separate from the 
previous program. The name clarification may improve the reputation of the program 
and encourage widespread program adoption . Widespread adoption and broad use of 
the program would help to  accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
Section:  Section 10 -102 
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by adding a new definition.  
Necessity : This change (adding a definition of the Triennial Code Cycle) is necessary 
to help implement an improved Energy Code Compliance program. The ECC -Provider 
may submit an updated application that responds to a newly adopted Energy Code 
during the triennial code cycle. This definition helps to allow a more streamline  
application process for existing ECC -Providers. This benefits the  CEC  in accomplishing 
its responsibility under Statute 25402.  
Section:  10-102 Energy Budget  
Specific Purpose:  Add new definition for Energy Budget.  
Necessity:  Compliance manager requirements from the ACM Approval manual were 
moved into sections 10 -109 and 10 -116 of the Energy Code. These requirements 
included references to the Energy Budget. The definition w as copied from the Energy 
Code Part 6 to ensure that the terms were defined when used on 10 -109 and 10 -116. 
Section:  10-102 Long -Term System Cost  
Specific Purpose:  Add new definitions for Long -Term System Cost.  
Necessity: Compliance manager requirements from the ACM Approval manual were 
moved into sections 10 -109 and 10 -116 of the Energy Code. These requirements 
included references to the Long -Term System Cost . The definition w as copied from the 
Energy Code Part 6 to ensure that the terms were defined when used on 10 -109 and  
10-116. 
Section:  10-102 Source Energy  
Specific Purpose:  Add new definitions for Source Energy.  
Necessity: Compliance manager requirements from the ACM Approval manual were 
moved into sections 10 -109 and 10 -116 of the Energy Code. These requirements 
included references to the Source Energy. The definition was copied from the Energy 
Code Part 6 to ensure that th e terms were defined when used on 10 -109 and 10 -116. 
  
 Section: 10-103(a)3Avi  
Purpose:  The specific purpose of this change is to correct a minor grammatical error. 
Where we previously said “included” language should have read “including.”  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
 
Section: 10-103.1( c)3Bim 
Purpose:  The specific purpose of this change is to update the referenced publication . 
Where we previously said “ IES Lighting Handbook, 10th Edition, 2011 ” is updated to  
“IES Lighting Library .” 
Necessity: This change is necessary to ensure the referenced publication is up  to date 
with the Energy Code.  
 
Section : 10-103.1(c)3F  
Purpose : The purpose of the change is to correct a typographical error, remove minor 
criteria for Acceptance Test Technician Certification Program (ATTCP) Provider building 
department surveys, and add an alternative to allow ATTCP shadow audits of 
Acceptance Test  Technicians (ATTs) to occur at ATTCP training facilities.  
Necessity : These changes are necessary to ensure that the provisions are clear of 
errors and the language matches the intent. The change to remove the criteria that 
ATTCP must perform building department surveys is because this is out of scope of 
ATTCP responsibili ties and is not enforceable. An alternative was added to the ATTCP 
quality assurance shadow audit requirements which allows the ATTCP to perform 
shadow audits at their training facilities. This was in response to comments received by 
the ATTCP com munity where they mentioned that performing shadow audits at the job 
site is not always practical and an alternative to provide flexibility is needed.  
 
Section : 10-103.2(c)3F  
Purpose : The purpose of the change is to correct a typographical error, remove minor 
criteria for Acceptance Test Technician Certification Program (ATTCP) Provider building 
department surveys, and add an alternative to allow ATTCP shadow audits of 
Acceptance Test  Technicians (ATTs) to occur at ATTCP training facilities.  
Necessity : These changes are necessary to ensure that the provisions are clear of 
errors and the language matches the intent. The change to remove the criteria that 
ATTCP must perform building department surveys is because this is out of scope of 
ATTCP responsibili ties and is not enforceable. An alternative was added to the ATTCP 
quality assurance shadow audit requirements which allows the ATTCP to perform 
shadow audits at their training facilities. This was in response to comments received by  
 the ATTCP community where they mentioned that performing shadow audits at the job 
site is not always practical and an alternative to provide flexibility is needed.  
 
Section:  10-103.3(a)  
Specific Purpose:  The purpose of this addition is to establish the scope of the Energy 
Code Compliance (ECC) program as it applies to ECC -Providers, ECC -Raters, and 
ECC -Rater Companies within Title 24 of the Energy Code. As the primary regulated 
entities within the FV&DT th e entities must be specifically mentioned,  and roles 
distinguished to properly regulate the conduct and expectations of each.  
Necessity:  This addition is necessary to encapsulate the ECC program within the 
Energy Code to better manage issues and address necessary changes to code on a 
triennial basis. Previous regulations did not include rater companies as a regulated 
entity, rater companies  have emerged as an important party in the FV&DT program,  
therefore should be included in updated regulations. Frequent stakeholder engagement 
and changing building energy efficiency requirements have direct bearing on the 
FV&DT program, therefo re regular updates within the triennial Energy Code updates 
would ensure the FV&DT program is up to date with current regulations while 
responding to stakeholder concerns on how best to implement the program. A robust  
and up to date  ECC Program is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
 
Section:  10-103.3(b)  
Specific Purpose:  The purpose of this addition is to provide a means for the CEC  to 
take disciplinary action against ECC -Providers, ECC -Raters and ECC -Rater Companies 
by establishing the general provisions for conflict of interest and prohibitions as a trigger 
to take prescribed actions.  
Necessity:  This addition is necessary to identify the prohibited actions under the ECC 
program for all parties: the CEC , ECC -Providers, ECC -Raters, and ECC -Rater 
Companies. A disciplinary system is necessary to ensure integrity within the FV&DT 
program and maintain the CEC’s reputation as a fair body to the public. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance  so that wasteful energy 
consumption  is reduce d, as directed by PRC 25402.   
 
Section:  10-103.3(b)1  
Specific Purpose:  The purpose of this addition is to identify the conflicts of interest as 
they pertain to ECC -Providers, ECC -Raters, and ECC -Rater Companies, as well as 
address this issue of conflicted data being entered into the ECC -Provider data 
registries.   
 Necessity:  This addition is necessary to provide clear limits and remedies to all parties: 
the CEC , ECC -Providers, ECC -Raters, and ECC -Rater Companies. Clear limits and 
remedies encourage FV&DT parties to conduct and report accurate field verification and 
diagnostic tests free from bias from outside parties or other FV&DT parties. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consu mption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1A  
Specific Purpose:  The purpose of this addition is to specify the conflicts of interest as 
they pertain to ECC -Providers, ECC -Raters, and ECC -Rater Companies.  
Necessity:  This addition is necessary to provide clear limits to all parties: the CEC , 
ECC -Providers, ECC -Raters, and ECC -Rater Companies.  
  
Section:  10-103.3(b)1Ai  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Providers from 
applying undue influence on ECC -Raters or ECC -Rater Companies.  
Necessity:  This addition is necessary to ensure that the ECC -Raters provide a true and 
unbiased field verification and diagnostic test regardless of pressure from the ECC -
Provider. Providers are responsible for auditing and verifying data submitted by ECC 
Raters and companies, therefore they must be completely independent from the data 
produced. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy c onsumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Aii  
Specific Purpose:  The purpose of this addition is to prevent builders, designers and 
subcontractors from influencing the field verification and diagnostic testing performed by 
the ECC -Rater.  
Necessity:  This addition is necessary because in most cases the ECC -Rater is hired by 
the builder or subcontractor and not the homeowner and thus undue influence can 
otherwise be applied. The influence could result in an inaccurate field verification test, 
but also a voids the appearance of partiality. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed  by PRC 25402.   
  
Section:  10-103.3(b)1Aiii, 10 -103.3(b)1Aiiia, 10 -103.3(b)1Aiiib  
Specific Purpose:  The purpose of this addition is to make clear to all parties ( CEC , 
ECC -Providers, ECC -Raters, and ECC -Rater Companies) what is meant by financial  
 interest as used in Section 10 -103.3(b)1Aii. These additions set an investment and 
ownership limit on an ECC -Rater in a business for purposes of determining a financial 
interest. The purpose of these additions is to keep ECC -Rater and ECC -Rater 
Companies f rom being controlled by other business interests needing field verifications 
or diagnostic testing services through ownership structures or debt agreements.  
Necessity:  This addition is necessary to create a fair and level playing field for all 
affected parties (ECC -Providers, ECC -Raters, and ECC -Rater Companies). No affected 
party should benefit or be influenced by a financial interest that requires field verification 
or diagnostic testing. The proposed changes are necessary to document past inquiries 
regarding this limit and to allow some minor investments by ECC -Raters and ECC -Rater 
Companies. These additions are necessary to ensure that complex (or simple) 
ownership structures, debt agreements, or employee relationships are not used as 
undue influence over an ECC -Rater. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
 
Section:  10-103.3(b)1Aiv  
Specific Purpose:  The purpose of this addition is to restrict ECC -Raters from 
performing field verification and diagnostic testing services for close family or relatives.  
Necessity:  This addition is necessary to prevent close family relationships of any kind 
to be used  to influence an ECC -Rater providing filed verification and diagnostic testing 
services. ECC raters are more likely to provide a biased verification result if they have a 
close relationship with an individual, limiting commonly bias producing relationships  
captures a potentially large source of bias. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(b)1Av  
Specific Purpose:  The purpose of this addition is to ensure that ECC -Providers, ECC -
Raters or ECC -Rater Companies remain as third -party, independent entities on a 
project site and do not contribute to the actual construction activities.  
Necessity:  This addition is necessary to help the ECC -Rater maintain their status as an 
independent agent on the project site. Independent agents would be more likely to 
produce unbiased, accurate field verification results. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
 
Section:  10-103.3(b)1Avi   
 Specific Purpose:  The purpose of this addition is to address issues regarding the lack 
of understanding on the part of the consumer and builder regarding the services 
provided by the ECC -Rater and ECC -Rater Company.  
Necessity:  This addition is necessary to provide a report to the building owner that 
includes actionable information regarding the field verifications and diagnostic tests 
performed by the ECC -Rater. A well -understood ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
 
Section:  10-103.3(b)1Avia  
Specific Purpose:  The purpose of this addition is to mandate the minimum 
identification information that must appear of the consumer report required by Section 
10-103.3(b)1Avi.  
Necessity:  This addition is necessary to create a standard consumer report that clearly 
identifies the ECC -Rater and ECC -Rater Company as well as providing a simple means 
of advertisement. A well -understood ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
 
Section:  10-103.3(b)1Avib  
Specific Purpose:  The purpose of this addition is to mandate the minimum information 
regarding the ECC -Provider used by the ECC -Rater to document the field verification 
and diagnostic testing results for the project on the report required by Section 10 -
103.3(b)1Avi.  
Necessity:  This addition is necessary to provide the consumer with a link to the correct 
ECC -Provider for further documentation (as needed) or to submit a complaint. A well -
understood ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Avic  
Specific Purpose:  The purpose of this addition is to help prevent over -charging or 
other consumer fraud by documenting the performance, results, and cost (charged to 
the subcontractor) regarding the field verifications and diagnostic tests performed at the 
project site.  
Necessity:  This addition is necessary to provide the consumer with sufficient 
information to verify the itemized bill from the subcontractor or builder. A well-
understood ECC Program is necessary to encourage widespread program adoption and  
 accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
 
Section:  10-103.3(b)1Avii  
Specific Purpose:  The purpose of this addition is to register the contact information of 
the building or homeowner where field verification and diagnostic testing are being 
performed by an ECC -Rater for possible later contact by the ECC -Provider as part of its 
ongoing quali ty assurance activities. Disciplinary consequences are also included to 
ensure compliance. Some projects may not have a homeowner in the residence, 
therefore additional consenting owners are also identified.  
Necessity:  This addition is necessary to assist the ECC -Provider in its performance of 
the quality assurance requirements as well as an opportunity to educate the general 
public on the ECC program. The requirement is burnished by creating a disciplinary 
measure if the completed form is not registered with an ECC -Provider . A reputable ECC 
Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, a s directed by PRC 25402.   
 
Section:  10-103.3(b)1Aviii  
Specific Purpose:  The purpose of this addition is to help prevent ECC -Raters from 
losing field verification and diagnostic testing services jobs to a second (less 
scrupulous) ECC -Rater when they must fail a project.  
Necessity:  This addition is necessary to help prevent ECC -Raters from undermining 
the integrity of the ECC program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
 
Section:  10-103.3(b)1Aviiia  
Specific Purpose:  The purpose of this addition is to control the circumstances under 
which an ECC -Rater that has failed a project can allow another ECC -Rater to retest that 
project.  
Necessity:  This addition is necessary to allow for a new ECC -Rater to retest a failed 
project without undermining the ECC program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
 
Section:  10-103.3(b)1Aviiia(i)   
 Specific Purpose:  The purpose of this addition is to allow the ECC -Rater to release a 
project that has failed to a new ECC -Rater.  
Necessity:  This addition is necessary to allow for the condition that an ECC -Rater may 
wish to move on to other jobs and not retest the failed project. A functioning ECC 
Program must be able to continue ensuring compliance with the building energy 
efficiency standards of a project in the case the original ECC -Rater cannot do so, so 
that the program may continue to reduce wasteful energy consumption as dir ected by 
PRC 25402.  
Section:  10-103.3(b)1Aviiia(ii)  
Specific Purpose:  The purpose of this addition is to account for an ECC -Rater that has 
been injured and is unable to retest a failed project.  
Necessity:  This addition is necessary to allow the project to proceed in the event that 
the original ECC -Rater is unable to proceed. A functioning ECC Program must be able 
to continue ensuring compliance with the building energy efficiency standards of a 
project in the case the original ECC -Rater cannot do so, so that the program may 
continue to reduce wasteful energy consumption as dir ected by PRC 25402.  
  
Section:  10-103.3(b)1Aviiia(iii)  
Specific Purpose:  The purpose of this addition is to account for an ECC -Rater that is 
unable to retest a failed project due to suspension or decertification.  
Necessity:  This addition is necessary to allow the project to proceed in the event that 
the original ECC -Rater is not eligible to perform the retest required. A functioning ECC 
Program must be able to continue ensuring compliance with the building energy 
efficiency standards of a project in the case the original ECC -Rater cannot do so, so 
that the program may continue to reduce wasteful energy consumption as dir ected by 
PRC 25402.  
  
Section:  10-103.3(b)1Aviiia(iv)  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Rater from using 
Section 10 -103.3(b)1Aviii to hold a project hostage by refusing to perform the retest or 
relapsing the project.  
Necessity:  This addition is necessary to maintain a balance of power between the 
builder, subcontractor or homeowner and the ECC -Rater. A functioning ECC Program 
must be able to continue ensuring compliance with the building energy efficiency 
standards  of a project in the case the original ECC -Rater cannot do so, so that the 
program may continue to reduce wasteful energy consumption  as directed by PRC 
25402.   
  
Section:  10-103.3(b)1Aviiib   
 Specific Purpose:  The purpose of this addition is to use the ECC -Provider data registry 
to support the requirements of Section 10 -103.3(b)1Aviii. The compliance 
documentation is intended to help prevent verification tampering.  
Necessity:  This addition is necessary to ensure that all ECC -Providers are required to 
support the requirements of Section 10 -103.3(b)1Aviii consistently. The data addition is 
necessary to ensure the correct project is identified and is not tampered with. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
 
Section:  10-103.3(b)1Aviiic  
Specific Purpose:  The purpose of this addition is to help prevent an ECC -Rater from 
undermining the requirements of Section 10 -103.3(b)1Aviii by entering the project into a 
different ECC -Provider data registry or an active failed field verification.  
Necessity:  This addition is necessary to help protect consumer from poor installation 
and false documentation. The addition ensures the integrity of compliance documents 
are maintained, no failed verification is replaced, and the provider registry remains 
accurate.  A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Aviiic(i)  
Specific Purpose:  The purpose of this addition is to require ECC -Providers to be 
vigilant regarding its data registry being used to undermine the requirements of Section 
10-103.3(b)1Aviii.  
Necessity:  This addition is necessary to encourage ECC -Provider to be responsible 
stakeholder in promoting the efficacy of the requirements in Section 10 -103.3(b)1Aviii. 
The addition creates an affirmative duty on the provider to ensure suspected violations 
are promp tly investigated. The affirmative duty creates increased incentive for the 
provider to be a responsible quality assurance enforcer. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building e nergy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Aviiic(ii)  
Specific Purpose:  The purpose of this addition is to give the CEC  the clear authority 
and specific actions needed to enforce the requirements of Section 10 -103.3(b)1Aviii.  
Necessity:  This addition is necessary to enable the CEC  to investigate and exact 
disciplinary measures as warranted regarding the enforcement of Section 10 -
103.3(b)1Aviii. A reputable ECC Program is necessary to encourage widespread  
 program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Aix  
Specific Purpose:  The purpose of this addition is to allow for the legitimate off -purpose 
use of registered compliance documentation while maintaining the integrity of the ECC 
program.  
Necessity:  This addition is necessary to prevent entities from submitting falsified 
registered compliance documents to programs outside of the ECC program and thus 
diminishing the reputation of the ECC program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(b)1B  
Specific Purpose:  The purpose of this addition is to prevent or at least address data 
being entered into the ECC -Provider data registry by ECC -Raters that have an existing 
conflict of interest.  
Necessity:  This addition is necessary to address the circumstance where ECC -Raters 
have a conflict of interest but perform the field verification and diagnostic testing and 
enter those results into the ECC -Provider data registry. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Bi  
Specific Purpose:  The purpose of this addition is to establish that the ECC -Provider 
has the responsibility of first defense against conflicted data.  
Necessity:  This addition is necessary to require the ECC -Provider to defend its data 
registry as the Provider is the entity in control of the data registry. An accurate data 
registry is essential to a functioning ECC -program and buttresses trust in completed 
field ve rifications. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Bia  
Specific Purpose:  The purpose of this addition is to provide a means of compliance for 
the ECC -Provider for Section 10 -103.3(b)1Bi. It serves as an example for ECC -
Providers on how to comply with Section 10 -103.3(b)1Bi but is not the exclusive means.  
 It also makes clear that a Provider may accept data that was conflicted at the time but 
has received approval from the Executive Director.  
Necessity:  This addition is necessary to not overburden the ECC -Provider in its efforts 
to comply by providing a reasonable compliance path. This addition is necessary to 
provide an example of compliance while making clear a Provider may accept conflicted 
data if it was approved by the Executive Director. A well understood  ECC Program 
among ECC Providers is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consu mption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Bib  
Specific Purpose:  The purpose of this addition is to provide an alternative means of 
compliance for the ECC -Provider for Section 10 -103.3(b)1Bi, if the ECC -Provider can 
devise one that the CEC approves.  
Necessity:  This addition is necessary to avoid overburdening the ECC -Provider in its 
efforts to comply with Section 10 -103.3(b)1Bi by allowing for an alternative compliance 
path if one can be developed by the ECC -Provider and approved by the CEC. A well 
understood ECC Program among ECC Providers is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(b)1Bii  
Specific Purpose:  The purpose of this addition is to require that the ECC -Provider 
routinely takes reasonable steps to confirm that its data registry does not contain 
conflicted data (i.e., the second line of defense).  
Necessity:  This addition is necessary so that ECC -Providers as the entity in control of 
the data registry take all reasonable steps to defend the data registry.  An accurate data 
registry is essential to a functioning ECC -program and buttresses trust in completed 
field verifications. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Biia  
Specific Purpose:  The purpose of this addition is to offer an example to ECC -Providers 
on how to deter ECC -Raters from entering conflicted data by ensuring that ECC -
Providers explain and educate ECC -Raters regarding the new conflicted data 
requirements.  
Necessity:  This addition is necessary so that ECC -Raters cannot claim that they were 
not aware of the new conflicted data requirements and can take the appropriate actions 
to comply. A well understood ECC Program among ECC Providers is necessary to  
 encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(b)1Biib  
Specific Purpose:  The purpose of this addition is to establish a means for the ECC -
Provider to actively search out its data registry for non -compliant entries.  
Necessity:  This addition is necessary to motivate the ECC -Providers to take 
appropriate actions in guarding its data registry from conflicted data. A well understood 
ECC Program among ECC Providers is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
 
Section:  10-103.3(b)1Biic  
Specific Purpose:  The purpose of this addition is to require ECC -Providers to take the 
next step in the discovery of conflicted data in its data registry by requiring the ECC -
Provider to launch an investigation. The purpose of this addition is to mandate ECC -
Providers take affi rmative steps to investigate suspected conflicted data, and if 
discovered to act upon such a discovery. Discovering conflicted data would have limited 
use without further actions.  
Necessity:  This addition is necessary to aid the ECC -Provider in constructing a 
defensible case when declaring that an ECC -Rater has violated the conflicted data 
regulations. Identifying conflicted data could become the basis for a progressive 
discipline action, ther efore creating a clear record is necessary to discipline an ECC -
Rater. A well understood ECC Program among ECC Providers is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that w asteful energy consumption is reduced, as 
directed by PRC 25402.    
  
Section:  10-103.3(b)1Biid  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to develop 
alternative processes that the CEC  can determine are at least equivalent to the 
proposed processes.  
Necessity:  This addition is necessary to allow for innovation on the part of the ECC -
Provider. A well understood ECC Program among ECC Providers is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(b)1Biii   
 Specific Purpose:  The purpose of this addition is to prevent the ECC -Provider from 
disseminating conflicted data.  
Necessity:  This addition is necessary because ECC -Providers routinely sell reports 
from its data registry, typically to other California state agencies. Conflicted data is more 
likely to be inaccurate, potentially skewing legitimate data, thereby polluting data sets.  A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(b)1Biv  
Specific Purpose:  The purpose of this requirement is to make ECC -Raters and ECC -
Rater Companies responsible for compliance with the conflicted data requirements. The 
Executive Director may give ECC -Raters or Companies approval to submit conflicted 
data,  but ECC -Raters and Companies should only submit unconflicted data unless 
otherwise approved.  
Necessity:  This addition is necessary to ensure that the ECC -Rater and ECC -Rater 
Company are culpable for noncompliance with the conflicted data requirements. The 
Executive Director may give ECC -Raters or Companies approval to submit conflicted 
data,  but ECC -Raters and Companies should only submit unconflicted data unless 
otherwise approved. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consu mption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Biva  
Specific Purpose:  The purpose of this addition is to require that the ECC -Rater either 
positively declare that they do not have a conflict of interest or have permission from the 
CEC  to enter conflicted data into the ECC -Provider data registry.  
Necessity:  This addition is necessary to remind the ECC -Rater that they are 
responsible for avoiding conflicts of interest when entering data into the EC -Provider 
data registry. A well understood ECC Program among ECC Raters and Rater 
Companies  is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(b)1Bivb  
Specific Purpose:  The purpose of this addition is to allow for innovation in complying 
with the conflicted data requirements.  
Necessity:  This addition is necessary to develop alternative processes as situations 
arise, while ensuring the process is reviewed by the CEC . A well understood ECC 
Program among ECC Raters and Rater Companies is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency  
 standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(b)1Bv  
Specific Purpose:  The purpose of this addition is to provide for the unlikely instances 
where it is necessary to accept conflicted data into the ECC -Provider data registry.  
Necessity:  This addition is necessary to provide a reasonable remedy when an 
unforeseen circumstance occurs that may require accepting conflicted data into a data 
registry. A dynamic ECC program is necessary to adapt to changing conditions, 
allowing the E CC program to  continue accurately determining building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(b)1Bva  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements for the unlikely event that the CEC  needs to grant an ECC -Rater 
permission to enter conflicted data into an ECC -Provider data registry.  
Necessity:  This addition is necessary to provide a reasonable and public means for the 
CEC  to grant an ECC -Rater permission to use conflicted data. A dynamic ECC program 
is necessary to adapt to changing conditions, allowing the ECC program to continue 
accurately determining building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Bvb  
Specific Purpose:  The purpose of this addition is to give the Executive Director of the 
CEC  a basis on which to grant an ECC -Rater permission to use conflicted data.  
Necessity:  This addition is necessary to restrict the evidence that can be considered by 
the Executive Director to be compelling and persuasive. A dynamic ECC program is 
necessary to adapt to changing conditions, allowing the ECC program to continue 
accurately determining building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Bvc  
Specific Purpose:  The purpose of this addition is to require a high bar for determining 
is an argument is compelling and persuasive for the CEC  to grant an ECC -Rater to use 
conflicted data.  
Necessity:  This addition is necessary to prevent trivial or general assertions from being 
considered as compelling or persuasive. A dynamic ECC program is necessary to adapt 
to changing conditions, allowing the ECC program to continue accurately determining  
 building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Bv, 10 -103.3(b)1Bva, 10 -103.3(b)1Bvb, 10 -103.3(b)1Bvc, 10 -
103.3(b)1Bvd  
Specific Purpose:  The purpose of these additions is to provide the Executive Director 
of the CEC  with several types of approvals to allow an ECC -Rater to use conflicted data 
and a reasonable time limit for the Director to respond. The additions make clear what 
type of applications the Executive Director may grant approval to.  
Necessity:  this addition is necessary to allow the Executive Director a reasonable time 
frame to issue a decision that is within the scope of the request. The additions also 
communicate to potential applicants under what grounds they should seek approval 
from the Executive Director w hen attempting to enter conflicted data. Finally, the 
additions allow the Executive Director to request additional information so they may gain 
a more complete understanding of the application’s circumstances when deciding 
whether to grant, conditionally a pprove, or reject the application.  A dynamic ECC 
program is necessary to adapt to changing conditions, allowing the ECC program to 
continue accurately determining building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Bvi  
Specific Purpose:  The purpose of this addition is to require specific actions of the 
ECC -Provider upon discovery of suspected conflicted data that work toward building a 
case against the ECC -Rater and ECC -Rater Company so as to proceed toward 
disciplinary action.  
Necessity:  This addition is necessary to ensure that all ECC -Provider respond in a 
similar manner to conflicted data and ECC -Rater and ECC -Rater Company disciplinary 
actions. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)1Bvii  
Specific Purpose:  The purpose of this addition is to identify conflicted data within the 
ECC -Provider data registry without deleting it and notifying all affected parties of the 
issue.  
Necessity:  This addition is necessary to prevent conflicted data from undermining the 
integrity of the ECC program while identifying responsible or notifying affected parties. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
   
 Section:  10-103.3(b)2  
Specific Purpose:  The purpose of this addition is to establish the requirements that 
ECC -Raters may not submit false, inaccurate, or incomplete data into the ECC -Provider 
data registry.  
Necessity:  This addition is necessary to help ensure that ECC -Provider, ECC -Rater 
and ECC -Rater Companies are responsible for the accuracy of the data entered into the 
ECC -Provider data registry. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(b)2A  
Specific Purpose:  The purpose of this addition is to identify the responsibility of ECC -
Providers to be vigilant regarding the data entered into its data registry by all authorized 
users.  
Necessity:  This addition is necessary to ensure that the ECC -Provider understands 
and takes reasonable steps to ensure only accept, store, and disseminate accurate 
information. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)2B  
Specific Purpose:  The purpose of this addition is to remove the monetary incentive for 
ECC -Providers to accept data into its data registry that is out of compliance with these 
requirements.  
Necessity:  This addition is necessary to dissuade ECC -Providers from accepting 
money or other considerations that could influence ECC -Providers to mishandle data 
registries or appear to remove impartiality from data registries.  A reputable ECC 
Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)2C  
Specific Purpose:  The purpose of this addition is to address the issue of ECC -Raters 
allowing their passwords to be used by laypersons to enter in data and validate that 
data into an ECC -Provider data registry.  
Necessity:  This addition is necessary because untrained and uncertified laypersons do 
not have the knowledge needed to verify that the data is accurate prior to registering the 
compliance documents. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency  
 standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(b)2Ci  
Specific Purpose:  The purpose of this addition is to allow but limit the use of 
uncertified trainees working under an ECC -Rater.  
Necessity:  This addition is necessary because several ECC -Raters have been allowing 
their trainees to perform field verifications and diagnostic tests without proper training or 
supervision. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(b)2Cii  
Specific Purpose:  The purpose of this addition is to make plain that the only person 
qualified to sign the field verification and diagnostic test compliance document and 
verify that the data entered is accurate is the ECC -Rater who performed these tests on 
the project site.  
Necessity:  The addition is necessary because the use of an uncertified layperson 
signing for the ECC -Rater has been witnessed. Assigning the verification to a single 
rater also increases accountability by signaling who conducted the verification. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)  
Specific Purpose:  The purpose of this addition is to describe the review process and 
requirements for an ECC -Provider application.  
Necessity:  This addition is necessary to provide a basis for various types of ECC -
Provider applications as well as the review and potential approval processes. A well -
understood ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)1  
Specific Purpose:  The purpose of this addition is to list the types of ECC -Provider 
applications that the CEC  will review and consider for approval.  
Necessity:  This addition is necessary to outline not only the types of ECC -Provider 
applications but also the CEC 's review and potential approval process. Providers are 
given the benefit of what to expect if they seek certification and recertification. A well -
understood ECC Program is necessary to encourage widespread program adoption and  
 accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(c)2  
Specific Purpose:  The purpose of this addition is to allow ECC -Providers to submit 
confidential information as part of its application.  
Necessity:  This addition is necessary to allow the CEC  to consider confidential 
information in an ECC -Provider application in a public application process. Allowing 
confidential data to be submitted allows the applicant and CEC to fully consider the 
application. The public may receive a non -confidential summa ry of the confidential 
documents submitted, encouraging transparent governance while preserving applicant 
transparency with the CEC. A robust and up to date ECC Program is necessary to 
accurately determ ine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)3  
Specific Purpose:  The purpose of this addition is to describe the application 
requirements for a new ECC -Provider (full application).  
Necessity:  This addition is necessary to provide the ECC -Provider applicant with the 
minimum requirements for a full application to be considered by the CEC . A robust and 
up to date ECC Program is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(c)3A  
Specific Purpose:  The purpose of this addition is to describe the required evidence 
needed to demonstrate that the ECC -Provider applicant can satisfy the application 
requirements.  
Necessity:  This addition is necessary to set the minimum requirement to demonstrate 
that an ECC -Provider applicant can satisfy all the regulatory requirements in Section 10 -
103.3(c)1. A robust and up to date ECC Program is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)3Ai  
Specific Purpose:  The purpose of this addition is to allow a new ECC -Provider to 
demonstrate that its untested proposed processes and systems are capable of being 
approved by the CEC . 
Necessity:  This addition is necessary because a new ECC -Provider applicant has not 
had the opportunity to prove its processes and system are capable of sufficient  
 operation in the real world. The alternative pathway allows them to show they may be a 
viable ECC -Provider. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)3Aii  
Specific Purpose:  The purpose of this addition is to allow the CEC  to consider both 
nonspecific complaints against the ECC -Provider applicant and actual evidence 
provided by a third party in an application review.  
Necessity:  This addition is necessary because the CEC  uses a public process to 
review and potentially approve any ECC -Provider application which requires the 
Commission to consider all comments. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(c)3B  
Specific Purpose:  The purpose of this addition is to include the actual legal company 
name of the ECC -Provider applicant in the application.  
Necessity:  This addition is necessary to limit the eventual powers granted by the CEC  
to an approved ECC -Provider to only that approved provider and not a parent or 
subsidiary. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)3C  
Specific Purpose:  The purpose of this addition is to identify all persons with an 
influence over the ECC -Provider applicant.  
Necessity:  This addition is necessary to publicly reveal all individuals who might hold 
sway over the actions of an ECC -Provider applicant. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)3D  
Specific Purpose:  The purpose of this addition is to identify any other entities that may 
have an influence other the ECC -Provider applicant.  
Necessity:  This addition is necessary to publicly reveal all entities that might hold sway 
over the actions of an ECC -Provider applicant. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy  
 efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(c)3E  
Specific Purpose:  The purposed of this addition is to identify which Energy Code 
cycle(s) that an ECC -Provider applicant is applying to operate in.  
Necessity:  This addition is necessary because all ECC -Providers are limited to a 
specific code cycle of the Energy Code. They must reapply during each Energy code 
cycle to be a certified ECC -Provider.  A robust and up to date ECC Program is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)3F  
Specific Purpose:  The purpose of this addition is to identify a point of contact for the 
ECC -Provider applicant.  
Necessity:  This addition is necessary because ECC -Providers are typically operated by 
a group of executives and not a single individual. Assigning specific points of contact 
increases efficiency and accountability if an issue arises, the person may be contacted 
direc tly instead of going through several intermediaries. A robust and up to date ECC 
Program is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402 .   
  
Section:  10-103.3(c)3G  
Specific Purpose:  The purpose of this addition is to allow the CEC  to accept any other 
information necessary in the ECC -Provider application.  
Necessity:  This addition is necessary to allow the ECC -Provider applicant the flexibility 
to submit relevant information for CEC  consideration within its application. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)4  
Specific Purpose:  The purpose of this addition is to formally recognize that an ECC -
Provider approved to operate under one code cycle of the Energy Code is only required 
to update its applicant pursuant to changes within the new code cycle,  
Necessity:  This addition is necessary because the CEC  has functionally had to 
consider each ECC -Provider as a new provider which is time -consuming and 
unnecessary. Allowing the CEC to focus on changes and amendments saves the CEC 
resources while saving the applicant time. A robust and up to date ECC Program is  
 necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(c)4A  
Specific Purpose:  The purpose of this addition is to identify the original application as 
well as application amendments and the new updates to the application.  
Necessity:  This addition is necessary to conserve employee resources for the ECC -
Provider applicant and the CEC . Using previously approved applications and 
amendments allows the Commission to save resources when re -analyzing previously 
approved materials. Identifying previously scrutinized materials could reduce duplicative 
review. A robust and up to date ECC Program is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25 402.   
  
Section:  10-103.3(c)4B  
Specific Purpose:  The purpose of this addition is to identify what past code cycles the 
CEC  has approved for the ECC -Provider applicant.  
Necessity:  This addition is necessary to reduce unneeded workload  for the ECC -
Provider applicant and the CEC . Identifying previously scrutinized materials could 
reduce duplicative review. A robust and up to date ECC Program is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(c)4C  
Specific Purpose:  The purpose of this addition is to accept all new evidence submitted 
by the ECC -Provider applicant for the new code cycle of the Energy Code.  
Necessity:  This addition is necessary to reduce unneeded workload  for the ECC -
Provider applicant and the CEC . Identifying previously scrutinized materials could 
reduce duplicative review. A robust and up to date ECC Program is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)4D  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider applicant 
the option to submit a full application regardless of its prior application approvals.  
Necessity:  This addition is necessary in the event that an ECC -Provider applicant 
foresees that the updated application will be so significant that there is no labor or time -
saving advantage to using the Triennial Reapproval Application process. A robust and 
up to date ECC Program is necessary to accurately determine building energy efficiency  
 standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(c)5  
Specific Purpose:  The purpose of this addition is to allow an ECC -Provider that has 
been decertified by the CEC  to make a one -time application for remediation.  
Necessity:  This addition is necessary to give the decertified ECC -Provider a 
reasonable opportunity to regain its CEC  approval status. A previously decertified  ECC 
provider must show they will not tarnish the ECC p rogram . A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5A  
Specific Purpose:  The purpose of this addition is to limit the ECC -Provider application 
for remediation to one.  
Necessity:  This addition is necessary to limit the effort and time spent by the CEC  on 
reviewing an application from an ECC -Provider that has already gone through the full 
decertification process. A previously decertified ECC provider must show they will not 
tarnish the ECC program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful en ergy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(c)5B  
Specific Purpose:  The purpose of this addition is to limit the ECC -Provider remediation 
application to only the salient points.  
Necessity:  This addition is necessary to keep the ECC -Provider focused on the issues 
that lead to its decertification. Extraneous materials would increase review time for CEC 
staff while adding little information on whether to grant remediation. A previously 
decertified ECC provider must show they will not tarnish the ECC program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful en ergy 
consu mption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)5Bi  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to enter 
into the record all past approved applications.  
Necessity:  This addition is necessary to limit the ECC -Provider to only those 
applications that were approved by the CEC  as a historic record. A previously  
 decertified ECC provider must show they will not tarnish the ECC program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumpt ion is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5Bii  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to enter 
into the record all correspondence regarding the decertification process between the 
applicant and the CEC . 
Necessity:  This addition is necessary to limit the ECC -Provider to only those 
correspondence that are relevant to its decertification. A previously decertified ECC 
provider must show they will not tarnish the ECC program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful en ergy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)5Biii  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to explain 
how it will remedy all violations as identified by the CEC . 
Necessity:  This addition is necessary to limit the ECC -Provider to addressing only 
those issues that are relevant to its decertification. A previously decertified ECC 
provider must show they will not tarnish the ECC program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful en ergy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5Biv  
Specific Purpose:  The purpose of this addition is to provide a clear and concise record 
of the new ECC -Provider application as it incorporates all remedies identified as 
necessary by the CEC . 
Necessity:  This addition is necessary to maintain a clear ECC -Provider application on 
file with the CEC . A previously decertified ECC provider must show they will not tarnish 
the ECC program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful en ergy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5C  
Specific Purpose:  The purpose of this addition is to establish a clear and concise 
approval process for the CEC  by making specific findings.   
 Necessity:  This addition is necessary to allow the CEC  to make consistent approvals of 
ECC -Provider remediation applications. A previously decertified ECC provider must 
show they will not tarnish the ECC program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful en ergy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(c)5Ci  
Specific Purpose:  The purpose of this addition is to ensure that the CEC  believes the 
amendments made to the ECC -Provider’s application are credible and will be 
implemented.  
Necessity:  This addition is necessary to allow the CEC  to question the authenticity of 
the ECC -Provider. A previously decertified ECC provider must show they will not tarnish 
the ECC program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful en ergy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5Cii  
Specific Purpose:  The purpose of this addition is to allow the CEC  to endorse the 
remediation plan presented by the ECC -Provider.  
Necessity:  This addition is necessary to allow the CEC  to focus any investigation 
necessary to make this finding. A previously decertified ECC provider must show they 
will not tarnish the ECC program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful en ergy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(c)5Ciii  
Specific Purpose:  The purpose of this addition is to allow the CEC  to endorse the 
ECC -Provider ability to implement the proposed remediation plan.  
Necessity:  This addition is necessary to allow the CEC  to evaluate the abilities of the 
ECC -Provider. A previously decertified ECC provider must show they will not tarnish the 
ECC program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5D  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to submit 
a full application after the CEC  approves its application for remediation.   
 Necessity:  This addition is necessary to allow the CEC  to reconsider the remediation 
application in the full application and address any additional issues as needed. A 
previously decertified ECC provider must show they will not tarnish the ECC program. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)5E  
Specific Purpose:  The purpose of this addition is to allow the possibility that the ECC -
Provider with a rejected (one -time) application for remediation might deserve another 
opportunity for remediation.  
Necessity:  This addition is necessary to allow the CEC  to consider all options before 
banning an ECC -Provider applicant from ever submitting another application. A 
previously decertified ECC provider must show they will not tarnish the ECC program. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)6  
Specific Purpose:  The purpose of this addition is to formally allow an ECC -Provider 
the option to halt the application review process and update its application with further 
information.  
Necessity:  This addition is necessary to address such midstream application changes 
that were so significant that they described a substantially new application. An up to 
date ECC Provider application is necessary to ensure the Provider meets all 
regulations . Doing so ensu res building energy efficiency standa rd compliance can be 
accurately determined and wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(c)6A  
Specific Purpose:  The purpose of this addition is to allow a full public review of any 
updated application.  
Necessity:  This addition is necessary to protect the CEC 's dedication to public review 
of applications. Public participation may spotlight issues the Commission may not be 
aware of while increasing transparency.  A robust publicly  vetted application will help 
ensure that building energy efficiency standards  compliance is accurately determined  
and wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(c)6B   
 Specific Purpose:  The purpose of this addition is to allow the CEC  the authority to 
direct an ECC -Provider applicant to update its application to address specific 
shortcomings.  
Necessity:  This addition is necessary to allow the CEC  to respond to public comments 
either through an update to the application or a condition of approval.  A robust and up to 
date ECC Pr ovider application  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(c)6C  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to 
withdraw its application and resubmit it at a later time.  
Necessity:  This addition is necessary to allow the ECC -Provider applicant the option to 
consider extensive changes to its application that might be too significant for an update. 
A robust and up to date ECC Pr ovider application  is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)7  
Specific Purpose:  The purpose of this addition is to allow the approved ECC -Provider 
to make changes to its original application to reflect necessary operational changes. 
This requirement captures changes made outside regular code cycle updates.  
Necessity:  This addition is necessary to allow the ECC -Provider to make changes to its 
operations as challenges arise. A robust and up to date ECC Provider application is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)7A  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to 
differentiate between substantive and non-substantive  operational changes that 
necessitate an amendment to its application. The determination has an effect on how an 
amendment is processed and is therefore important to decide when the amendment is 
submitted, the two processes are reviewed and approved at dif ferent speeds.  
Necessity:  This addition is necessary to allow minor changes to be addressed by an 
executive approval process and significant changes to be approved by a more formal 
process. A robust and up to date ECC Pr ovider application  is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)7B   
 Specific Purpose:  The purpose of this addition is to identify what the CEC  would 
consider to be a substantive change to the ECC -Provider application and the review 
and approval process that must be followed.  
Necessity:  This addition is necessary to ensure that substantive changes go through 
the same public review and approval process as a full application. Changes requiring 
full Commission must go before a regularly scheduled business meeting. A robust and 
up to date ECC Pr ovider application  is necessary to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.   
  
Section:  10-103.3(c)7C  
Specific Purpose:  The purpose of this addition is to identify minor changes to the ECC -
Provider application and to allow the CEC  to use an executive approval process to 
review and approve the application.  
Necessity:  This addition is necessary to avoid long and unneeded delays in approving 
minor changes to the ECC -Provider application. Changes that can be approved by the 
Executive Director do not need to go before a business meeting and can be approved 
more quickly. A robust and up to date ECC Pr ovider application  is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(c)8  
Specific Purpose:  The purpose of this addition is to formally recognize that the CEC  
may, at its discretion, approve any ECC -Provider application with conditions of 
approval. Conditions of approval allow the CEC to maintain higher operating standards 
as it deems necessary.  
Necessity:  This addition is necessary to codify a long -standing practice of the CEC . To 
meet the directive of PRC 25402, which includes reducing wasteful energy 
consumption, the CEC  must be able to apply additional conditions of approval to ECC 
Provider applications.  
  
Section:  10-103.3(c)9  
Specific Purpose:  The purpose of this addition is to prevent a decertified ECC -Provider 
from reapplying to the CEC . 
Necessity:  This addition is necessary to prevent a disgruntled decertified ECC -Provider 
from wasting the CEC 's time in an unnecessary application review. A previously 
decertified ECC -Provider may increase the risk of tarnishing the ECC program.  
Declining to reconsider a previously decertified  ECC -Provider may avoid damaging  the 
ECC program reputation . A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency  
 standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(c)9A  
Specific Purpose:  The purpose of this addition is to allow the Executive Director of the 
CEC  to reject an application from a decertified ECC -Provider if they have not completed 
the required remediation process.  
Necessity:  This addition is necessary to allow the Executive Director to reject the ECC -
Provider application as opposed to the CEC  so as not to waste time and resources. A 
previously decertified ECC -Provider may increase the risk of tarnishing the ECC 
program. Declining to reconsider a previously decertified ECC -Provider may avoid 
damaging the ECC program reputation . A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard com pliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(c)9B  
Specific Purpose:  The purpose of this addition is to allow the decertified ECC -Provider 
applicant to appeal the Executive Director's decision to the CEC  if it can show it is not 
related to a decertified ECC -Provider.  
Necessity:  This addition is necessary to allow for a formal and final decision from the 
CEC . A previously decertified ECC -Provider may increase the risk of tarnishing the ECC 
program. Declining to reconsider a previously decertified ECC -Provider may avoid 
damaging the ECC program reputation . A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(c)9C  
Specific Purpose:  The purpose of this addition is to establish the minimum evidentiary 
requirements for the ECC -Provider applicant to proceed.  
Necessity:  This addition is necessary to focus the evidence to be considered by either 
the Executive Director or the CEC  on the pertinent issues. A previously decertified ECC -
Provider may increase the risk of tarnishing the ECC program. The ECC -Provider’s 
application must meet minimum standards to maintain the ECC program’s reputation.  A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption  is reduced, as directed by PRC 25402.   
   
 Section:  10-103.3(c)9D  
Specific Purpose:  The purpose of this addition is to allow the CEC  to permanently bar 
the decertified ECC -Provider who has already exhausted remedies from submitting any 
further applications.  
Necessity:  This is necessary to prevent a decertified ECC -Provider from reapplication 
or re-entry into the marketplace to further degrade the reputation of the ECC program. A 
previously decertified ECC -Provider may increase the risk of tarnishing the ECC 
program. Declining to reconsider a previously decertified ECC -Provider may avoid 
damaging the ECC program’s reputation . A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)  
Specific Purpose:  The purpose of this addition is to identify ECC -Provider 
responsibilities in the ECC program.  
Necessity:  This addition is necessary to delineate responsibilities between the ECC -
Provider, ECC -Rater, and the CEC  for purposes of oversight. Clear responsibilities 
ensure accountability when an issue arises. A robust and clear  ECC Program is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1  
Specific Purpose:  The purpose of this addition is to identify the requirements for the 
ECC -Provider when providing training for the ECC -Rater.  
Necessity:  This addition is necessary to clearly lay out what is required of ECC -
Providers when designing, accrediting, and certifying ECC -Raters. The Commission 
must approve all training materials prior to use to ensure requirements are met and 
reviewed.  A robust  ECC Program training curriculum  is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1A  
Specific Purpose:  The purpose of this addition is to establish the minimum required 
training and testing curriculum for ECC -Raters (as provided by ECC -Providers).  
Necessity:  This addition is necessary to ensure that every ECC -Rater receives at least 
the minimum required training. A robust  ECC Program training curriculum  is necessary 
to accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
   
 Section:  10-103.3(d)1Ai  
Specific Purpose:  The purpose of this addition is to include the field verification and 
diagnostic testing procedures as part of the training requirements for ECC -Raters.  
Necessity:  This addition is necessary to ensure that every ECC -Rater receives at least 
the minimum required training. Normalizing the training for all ECC -Raters across all 
ECC -Providers is needed to help ensure that each ECC -Rater (and ECC -Rater 
Company) can produce consistent field verifications and diagnostic testing. Inconsistent 
verifications across ECC -Raters have been a long-term issue within the ECC -Program. 
Field verification and diagnostic testing are the core services performed by the ECC -
Rater, including them is crucial to the ECC program objectives. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)1Aia, 10 -103.3(d)1Aib, 10 -103.3(d)1Aic, 10 -103.3(d)1Aid, 10 -
103.3(d)1Aie, and 10 -103.3(d)1Aif  
Specific Purpose:  The purpose of this addition is to include each Field Verification and 
Diagnostic Testing Protocol in the Reference Appendices RA1, RA2, RA3, RA4, NA1, 
and NA2.  
Necessity:  This addition is necessary to ensure that every ECC -Rater receives at least 
the minimum required training. This addition addresses long standing issues regarding 
the consistency across ECC -Raters in the performance of the field verification and 
diagnostic testing, which is the core services performed by the ECC -Rater.  A robust  
ECC Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
 
Section:  10-103.3(d)1Aii  
Specific Purpose:  The purpose of this addition is to include non -field verification and 
diagnostic testing training materials as they pertain to the activities of the ECC -Rater.  
Necessity:  This addition is necessary to address shortcomings in ECC -Rater testing 
that may be resolved by further training. It is necessary to train ECC -Raters in more 
general building energy efficiency science so that they can more easily remedy issues 
in the field  that may make testing difficult. A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiia  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
the roles and responsibilities of all entities regulated in Section 10 -103.3   
 Necessity:  This addition is necessary because many of the roles and responsibilities 
covered in Section 10 -103.3 will be new to the ECC -Rater. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)1Aiib  
Specific Purpose:  The purpose of this addition is to include standard nomenclature 
used in the construction industry that is pertinent to the ECC -Rater.  
Necessity:  This addition is necessary to ensure that the ECC -Rater understands the 
nomenclature as it pertains to their activities. A robust  ECC Program training curriculum  
is necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic  
Specific Purpose:  The purpose of this addition is to include basic building science in 
the training for ECC -Raters.  
Necessity:  This addition is necessary to address basic errors that some ECC -Raters 
make during the field verification and diagnostic testing procedures. These errors are 
indicative of building practices that may not have been taken into consideration when 
the field v erification and diagnostic testing procedures were developed. It is therefore 
necessary that ECC -Rater be educated in basic building science to aid in a consistent 
and reliable testing result. A robust  ECC Program training curriculum  is necessary to 
accura tely determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(i)  
Specific Purpose:  The purpose of this addition is to include principles of heat transfer 
training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic errors that the ECC -Raters 
make during the field verification and diagnostic testing. Heat transfer is a major 
indicator of a buildings ability to be cooled or heated. ECC -Raters need to be 
cognoscente of how hea t transfer can impact field verification and diagnostic testing. A 
robust  ECC Program training curriculum  is necessary to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as dire cted by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(ii)  
Specific Purpose:  The purpose of this addition is to include energy conservation 
features training as it pertains to the ECC -Rater activities.   
 Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. The energy efficiency features are 
constantly being improved over time and may be installed slightly differently across 
contract ors. It is necessary for the ECC -Rater to be educated on these issues to 
properly perform the field verification and diagnostic testing services. A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(iii)  
Specific Purpose:  The purpose of this addition is to include framing, fenestration, 
insulation, and other built or installed features training as it pertains to the ECC -Rater 
activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. These building features can greatly 
affect the outcome of a field verification and diagnostic test. Therefore,  the ECC -Rater 
must be educated on these features and how to compensate for them. A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(iv)  
Specific Purpose:  The purpose of this addition is to include energy consuming 
appliances training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. Energy consuming appliances can 
affect the outcome of a field verification and diagnostic test. Therefore, an ECC -Rater 
must be educated on how these effects can be compensated while testing. A robust  
ECC Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
direc ted by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(v)  
Specific Purpose:  The purpose of this addition is to include types of space conditioning 
and ventilating systems training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. Heating, ventilating and air 
conditioning (HVAC) systems are the most energy intensive equipment in most homes. 
The ECC -Rater mu st be made aware of the various types of HVAC equipment and how 
they are to be tested. A robust  ECC Program training curriculum  is necessary to  
 accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(vi)  
Specific Purpose:  The purpose of this addition is to include types of water heating 
training subject as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. Water heating for domestic hot water 
(DHW) is a significant energy use in most homes. There are several field verification 
and d iagnostic tests that must be performed when installing new DHW equipment. 
ECC -Raters must be knowledgeable regarding the various types of DHW equipment as 
well as their installations. A robust  ECC Program training curriculum  is necessary to 
accu rately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(vii)  
Specific Purpose:  The purpose of this addition is to include categories of lighting 
systems and lighting controls training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. Lighting consumes the second most 
power in electricity (after HVAC systems). It is critical for ECC -Raters to understand 
how lighting systems are  to work and how they can affect the outcome of a field 
verification and diagnostic test.  A robust  ECC Program training curriculum  is necessary 
to accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is re duced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiic(viii)  
Specific Purpose:  The purpose of this addition is to include energy generating and 
storage systems training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. The, relatively new, solar and battery 
system are constantly changing based on the manufacturer’s directions. Yet, they still 
need to pass field verification and diagnostic testing by the ECC -Raters. Therefore, it is 
important for the ECC -Raters to be educated on the varieties of energy producing and 
storage systems available on the market today. A robust  ECC Program tra ining 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
   
 Section:  10-103.3(d)1Aiic(ix)  
Specific Purpose:  The purpose of this addition is to include energy efficiency effects of 
building characteristics training as it pertains to the ECC -Rater activities.  
Necessity:  This addition is necessary to address basic error that the ECC -Rater make 
during the field verification and diagnostic testing. Building characteristics can have a 
significant impact on field verification and diagnostic testing, typically during the outsid e 
air infiltration tests (or air -tightness tests). ECC -Raters need to understand the impact of 
building characteristics on testing and how to compensate for it. A robust  ECC Program 
training curriculum  is necessary to accurately determine buildi ng energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
 
Section:  10-103.3(d)1Aiid  
Specific Purpose:  The purpose of this addition is to help address worker safety issues 
for the ECC -Rater while on the project site.  
Necessity:  This addition is necessary to help protect the ECC -Rater while performing 
field verification and diagnostic testing.  A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiid(i)  
Specific Purpose:  The purpose of this addition is to add personal protective equipment 
and appropriate dress training to help ensure the safety of the ECC -Rater while on the 
project site.  
Necessity:  This addition is necessary to ensure worker safety while carrying out 
verification and testing. Inappropriate attire or protective equipment may result in injury. 
A robust  ECC Program training curriculum  is necessary to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiid(ii)  
Specific Purpose:  The purpose of this addition is to add communication with site 
management personnel training to help ensure the safety of the ECC -Rater while on the 
project site.  
Necessity:  Project site safety management is critical when performing field verification 
and diagnostic testing. Avoiding injury to the ECC -Rater, as well as others, is a critical 
piece of the performance of these tests. The risk of bodily injury as well as equipment  
damage is sufficient reason to provide this training.  A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PR C 25402.    
   
Section:  10-103.3(d)1Aiid(iii)  
Specific Purpose:  The purpose of this addition is to add awareness of site hazards, 
occupants in the dwelling unit, and escape route training to help ensure the safety of the 
ECC -Rater while on the project site.  
Necessity:  This addition is necessary to help ensure the safe working environment for 
the ECC -Rater. These working environments are typically people’s homes where safe 
storage of hazardous materials is not strictly regulated. Training the ECC -Rater to 
evaluate the sa fety of the home for their own protection is essential. A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiid(iv)  
Specific Purpose:  The purpose of this addition is to add site security training to help 
ensure the safety of the ECC -Rater while on the project site.  
Necessity:  This addition is necessary to help ensure that the working environment is 
well secured for the ECC -Rater. The working environments are typically people’s homes 
and may not include reasonable safety measures, which could be an unreasonable risk 
for the ECC -Rater. A robust  ECC Program training curriculum  is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiid(v)  
Specific Purpose:  The purpose of this addition is to make available additional worker 
safety practices, not limited to the ECC program.  
Necessity:  This addition is necessary educate the ECC -Rater on a variety of safe 
worker practices that they should follow when entering the work site. The ECC -Rater 
working environment may include active construction sites in multistory building. These 
additional pra ctices will help the ECC -Rater complete their tasks while reducing their 
risk of injury. A robust  ECC Program training curriculum  is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consump tion is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiie  
Specific Purpose:  The purpose of this addition is to verify that ECC -Rater understands 
how to maintain the specialized equipment used to perform field verifications and 
diagnostic testing.  
Necessity:  This addition is necessary to address fundamental failures of ECC -Raters to 
maintain and calibrate their instrumentations. A robust  ECC Program training curriculum   
 is necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiie(i)  
Specific Purpose:  The purpose of this addition is to verify that ECC -Raters properly 
maintain diagnostic devices used to perform field verifications and diagnostic testing.  
Necessity:  This addition is necessary to address fundamental failures of ECC -Raters to 
maintain and calibrate their instrumentations. There have been several complaints and 
investigations indicating that a minority of ECC -Raters do not routinely calibrate their 
devic es. This can cause false positive readings as well as contribute to a negative 
impression of the ECC Program as a whole. A robust  ECC Program training curriculum  
is necessary to accurately determine building energy efficiency standard compliance  so 
that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiie(ii)  
Specific Purpose:  The purpose of this addition is to verify that ECC -Raters maintain 
the accuracy and tolerance limits of the specialized equipment used to perform field 
verifications and diagnostic testing.  
Necessity:  This addition is necessary to address fundamental failures of ECC -Raters to 
maintain and calibrate their instrumentations. There have been instances of ECC -
Raters operating the field verification and diagnostic testing equipment in the wrong 
range (or outs ide of the intended range entirely) which resulted in several erroneous 
failures. This impacts the integrity of the ECC -Rater as well as the program as a whole. 
A robust  ECC Program training curriculum  is necessary to accurately determine building 
energy e fficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiie(iii)  
Specific Purpose:  The purpose of this addition is to verify that ECC -Raters properly 
calibrate the specialized equipment used to perform field verifications and diagnostic 
testing.  
Necessity:  This addition is necessary to address fundamental failures of ECC -Raters to 
maintain and calibrate their instrumentations. This equipment needs to be calibrated on 
an annual or semi -annual basis to be relied upon to produce accurate results. Proper 
calibra tion is essential to producing accurate field verification and diagnostic testing 
results.  A robust  ECC Program training curriculum  is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiif   
 Specific Purpose:  The purpose of this addition is to instruct ECC -Raters regarding the 
manufacturers’ certifications consolidated at the CEC  web as required by the Energy 
Code.  
Necessity:  This addition is necessary to ensure that the ECC -Rater understands when 
and how to access the CEC  manufacturer equipment certifications.  A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiif(i)  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater knows 
the overall scope of equipment that may (or must) be certified to the CEC . 
Necessity:  This addition is necessary to educate the ECC -Rater regarding what 
equipment may be certificated by the CEC . A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiif(ii)  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
when equipment certification is required and what impact it has on the overall 
construction implementation.  
Necessity:  This addition is necessary to ensure that the ECC -Rater enforces the 
Energy Code requirement appropriately. Equipment certification (from the manufacturer 
or certified repair facility) is periodically necessary to ensure its continued safe 
operation. Equip ment that has fallen out of certification can cause false reading as well 
as unnecessary delay of projects. A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy  consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiif(iii)  
Specific Purpose:  The purpose of this addition is to inform the ECC -Rater on exactly 
how to access the CEC  manufacturers’ certified equipment lists and how to find specific 
equipment.  
Necessity:  This addition is necessary because the CEC  updates the point of access for 
the manufacturers’ certified equipment lists and how they are organized. Raters must 
know how to access these lists as they are subject to change. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
   
 Section:  10-103.3(d)1Aiig  
Specific Purpose:  The purpose of this addition is to verify that the ECC -Rater 
understands how to use the ECC -Provider data registry system.  
Necessity:  This addition is necessary because the ECC -Providers must update its data 
registry system with each Energy Code cycle as well as in -between when necessary. 
The data registry system is a critical step in documenting the field verification and 
diagnostic tes ting. The ECC -Rater must understand completely how to use the data 
registry interface and how to resolve issues if they should arise. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standa rd compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.    
  
Section:  10-103.3(d)1Aiig(i)  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater with the 
necessary information regarding the changes to the Energy Code at each code cycle, 
including building energy efficiency standards regulations, associated testing protocols, 
and the correspon ding forms for data entry.  
Necessity:  This addition is necessary because the Energy Code requirements for field 
verification and diagnostic testing change in both significant and subtle ways in virtually 
all code cycles for the Energy Code. A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiig(ii)  
Specific Purpose:  The purpose of this addition is to properly train an ECC -Rater on 
how to properly document workflows and input data.  A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
Necessity:  This addition is necessary to ensure that the ECC -Rater understands what 
compliance documentation they should and from whom. The data registry is a complex 
system the ECC -Rater must understand so as to take appropriate actions when 
necessary to resolve iss ues. A robust  ECC Program training curriculum  is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiig(iii)  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
the automated form logic and validation process.  
Necessity:  This addition is necessary to help the ECC -Rater avoid data entry issues in 
the field and diagnose issues when they do arise. A robust  ECC Program training  
 curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiig(iv)  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
understands the group sampling process as well as the roles and responsibilities of 
other responsible persons.  
Necessity:  This addition is necessary to address consistent errors made by ECC -
Raters as well as other responsible persons on the project site. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)1Aiih  
Specific Purpose:  The purpose of this addition is to create a foundation of professional 
behavior for ECC -Rater who deal with the public and represent the ECC program.  
Necessity:  This addition is necessary to address several incidences that have resulted 
in complaints as well as disciplinary actions . A robust  ECC Program training curriculum  
is necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aii i  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater is 
familiar with the resources available through the CEC  website that are useful to aid in 
the performance of the field verification and diagnostic testing on a project site.  
Necessity:  This addition is necessary to address a slight deficiency that some ECC -
Raters have encountered regarding an unusual field verification and diagnostic test in a 
real-world application. Resources on the Commission’s website may assist the ECC -
Rater and resu lt in a more accurate field verification test. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)1Aiij  
Specific Purpose:  The purpose of this addition is to educate all ECC -Raters regarding 
the new progressive discipline requirements in Section 10 -103.3.  A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.    
 Necessity:  This addition is necessary to ensure that ECC -Raters understand their 
rights under the new progressive discipline regulations.  A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiik  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
the new quality assurance requirements and how they are associated with the 
progressive discipline requirements.  
Necessity:  This addition is necessary to ensure that the ECC -Rater understands the 
responsibilities of the ECC -Provider as well as their own responsibilities to ensure that 
the Quality assurance procedures are complied with. A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiil  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
the changes in the conflict -of-interest requirements.  
Necessity:  This addition is necessary to address a fundamental misunderstanding of 
the ECC -Rater regarding conflict of interest and the impacts this can have on the 
reputation of the ECC program. The clear conflict -of-interest restrictions are made clear 
to ECC -Rater s so that the reputation of the ECC program may be improved. A robust  
ECC Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed  by PRC 25402.   
  
Section:  10-103.3(d)1Aiim  
Specific Purpose:  The purpose of this addition is to educate the ECC -Rater regarding 
the ongoing prohibition on false, inaccurate, and incomplete data entry into the ECC -
Provider data registry.  
Necessity:  This addition is necessary to ensure that any falsification on the part of the 
ECC -Rater can be used to implement the progressive discipline requirements, thereby 
increasing the accuracy and reputation of the ECC -Program . A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.    
  
Section:  10-103.3(d)1Aiii  
Specific Purpose:  The purpose of the addition is to describe the minimum 
requirements for classroom ECC -Rater training.   
 Necessity:  This addition is necessary to ensure that all ECC -Providers have 
comparable classroom training,  and that ECC -Raters are consistently trained regardless 
of what ECC -Provider trained them. A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiiia  
Specific Purpose:  The purpose of this addition is to allow for both in -person and 
remote training options, as well as allowing for automated training options.  
Necessity:  This addition is necessary to address the need for various options for 
classroom training in light of catastrophic events such as the COVID pandemic. As a 
result of the pandemic, remote training has improved dramatically and is a viable and 
convenient opti on to in -person classroom training. A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Aiiib  
Specific Purpose:  The purpose of this addition is to ensure proper trainee interaction 
with the online classroom system.  
Necessity:  This addition is necessary to prevent inappropriate trainee activities during 
the classroom session. A robust  ECC Program training curriculum  is necessary to 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiiic  
Specific Purpose:  The purpose of this addition is to allow for optional pre -recorded 
training instruction but to ensure that it is not the only training for a particular module.  
Necessity:  This addition is necessary to allow for economy of scale when producing 
training materials, and only where appropriate, and with limitations. Pre -recorded 
trainings have both advantages and disadvantages and therefore must be used only 
with limitations. A robust  ECC Program training curriculum  is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiiid  
Specific Purpose:  The purpose of this addition is to allow the use of tests and exams 
as a training method, with limitations.  
Necessity:  This addition is necessary to allow a proven test -anxiety remedy as well as 
a common practical training method. A robust  ECC Program training curriculum  is  
 necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aiv  
Specific Purpose:  The purpose of this addition is to require a minimum level of 
instructional materials for each ECC -Raters being trained.  
Necessity:   This addition is necessary to ensure that all ECC -Raters have a similar 
level of training materials regardless of the ECC -Provider. A robust  ECC Program 
training curriculum  is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)1Aiva  
Specific Purpose:  The purpose of this addition is to establish the scope of the training 
materials to be developed by the ECC -Provider, they must meet the requirements laid 
out in Section 10 -103.3(d)1Ai and Section 10 -103(d)1Aii.  
Necessity:  This addition is necessary to ensure that all ECC -Raters have a similar level 
of training materials regardless of t he ECC -Provider. A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aivb  
Specific Purpose:  Slideshow materials must have an accompanying script or detailed 
outline that explains the purpose of each visual used. The purpose of this addition is to 
ensure that the CEC  has a full understanding of the slide presentation materials.  
Necessity:  This addition is necessary to address shortcomings of previous ECC -
Provider applications that included slide decks of indecipherable context. A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)1Aivc  
Specific Purpose:  Each slide text and graphic must be legible;  the purpose of this 
addition is to ensure that the slide deck used for training purposes is understandable.  
Necessity:  This addition is necessary to ensure that ECC -Providers use high quality 
training materials whenever possible to provide clear training instructions. A robust  ECC 
Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.    
   
Section:  10-103.3(d)1Aivd  
Specific Purpose:  Government logos may not appear on class materials without 
permission, the purpose of this addition is to ensure that training materials are not 
mistaken for governmental materials on the same subject.  
Necessity:  This addition is necessary to maintain a strict control over governmental 
logos such as the CEC  logo. Allowing unsanctioned use of government logos may 
confuse the public on what the government’s role in the project is.  
  
Section:  10-103.3(d)1Av  
Specific Purpose:  The purpose of this addition is to require a minimum laboratory (or 
hands -on) training for ECC -Raters to make sure that they are accustomed to the 
procedures and measurement tools needed to perform field verification and diagnostic 
testing.  
Necessity:  This addition is necessary because the laboratory training used by ECC -
Providers currently is inconsistent. A robust  ECC Program training curriculum  is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Ava  
Specific Purpose:  The purpose of this addition is to require a repeatable laboratory 
training environment that has been approved by the Commission for ECC -Raters.  
Necessity:  This addition is necessary to ensure that each ECC -Rater has a similar 
opportunity to experience field verification and diagnostic training. More consistent 
training will likely result in more consistent test results. A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Avb  
Specific Purpose:  The purpose of this addition is to ensure Laboratory training is 
conducted in a controlled space with appropriate safety measures to guarantee the 
safety of ECC -Raters and instructors.  
Necessity:  This addition is necessary to prevent substandard training spaces from 
being utilized by ECC -Providers, avoiding risks to both ECC -Raters and their 
instructors. A robust  ECC Program training curriculum  is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Avc   
 Specific Purpose:  The purpose of this addition is to require no more than ten students 
to one instructor to ensure a reasonable instructor -to-student ratio for a safe and 
effective laboratory experience.  
Necessity:  This addition is necessary to prevent the ECC -Provider from overwhelming 
an instructor in a laboratory setting with an unreasonable number of students. A robust  
ECC Program training curriculum  is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)1Avd  
Specific Purpose:  The purpose of this addition is to require ECC -Providers to provide 
at least one test equipment per five students, allowing for an economy of laboratory 
setups without devaluing the training for each ECC -Rater.  
Necessity:  This addition is necessary to address the natural tendency of ECC -
Providers to reduce laboratory expenses at the disservice of ECC -Raters. One test 
equipment is likely sufficient for ECC -Raters to train with while allowing ECC -Providers 
to avoid having to purchase a surplus of test equipment. A robust  ECC Program training 
curriculum  is necessary to accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)1Avi  
Specific Purpose:  The purpose of this addition is to establish the requirements for a 
written test for ECC -Raters based on the training provided by the ECC -Provider.  
Necessity:  This addition is necessary to ensure that the written test for ECC -Raters is 
similar regardless of the ECC -Provider. A rigorous  testing curriculum is necessary to 
ensure each ECC -Rater is able to accurately determine building standards compliance, 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Avia  
Specific Purpose:  The purpose of this addition is to allow the required written test to be 
online (or in person) with the appropriate proctoring.  
Necessity:  This addition is necessary to allow for online testing for ease of providing 
the test statewide. A rigorous testing curriculum is necessary to ensure each ECC -Rater 
is able to accurately determine building standards compliance, so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Avib  
Specific Purpose:  The purpose of this addition is to require between 10 and 100 
questions per subject area at a level of difficulty commensurate with the training 
supplied by the ECC -Provider.   
 Necessity:  This addition is necessary to ensure that the number of questions per 
subject captures the required knowledge while the level of difficulty is similar regardless 
of the ECC -Provider. A rigorous testing curriculum is necessary to ensure each ECC -
Rater is able to accurately determine building standards compliance, so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Avic  
Specific Purpose:  The purpose of this addition is to establish a minimum passing 
score of 70% for the test.  
Necessity:  This addition is necessary to ensure that the required expertise for a 
passing score is similar regardless of the ECC -Provider. A rigorous testing curriculum is 
necessary to ensure each ECC -Rater is able to accurately determine building standards 
compliance, so that wasteful energy consumption is reduced, as directed by PRC 
25402.  
  
Section:  10-103.3(d)1Avid  
Specific Purpose:  The purpose of this addition is to ensure that the CEC  is fully 
informed and approves the ECC -Rater tests proposed by each ECC -Provider.  
Necessity:  This addition is necessary to ensure that the CEC  can verify that the ECC -
Rater tests are consistent regardless of the ECC -Provider. A rigorous testing curriculum 
is necessary to ensure each ECC -Rater is able to accurately determine building 
standards compliance, so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)1Avii  
Specific Purpose:  The purpose of this addition is to ensure that ECC -Raters take a 
laboratory (practical) test as a requirement of certification. These additions also ensure 
that the ECC -Provider retains a copy of the results for five years from the test date.  
Necessity:  This addition is necessary to ensure that the practical test for ECC -Raters is 
consistent regardless of the ECC -Provider. The practical training and testing have  been 
a proven technique to better engrain the field verification and diagnostic testing 
procedures into ECC -Raters. Maintaining the testing records for five years is helpful 
when reviewing the training and certification of an ECC -Rater. A rigorous testing 
curriculum is necessary to ensure each ECC -Rater is able to accurately determine 
building stan dards compliance, so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviia  
Specific Purpose:  The purpose of this addition is to ensure that the laboratory tests are 
performed in a Commission approved facility.   
 Necessity:  This addition is necessary to encourage consistent application of learned 
material. A rigorous testing curriculum is necessary to ensure each ECC -Rater is able to 
accurately determine building standards compliance, so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviib  
Specific Purpose:  The purpose of this addition is to establish a maximum proctor -
student ratio (1:5) during practical testing.  
Necessity:  This addition is necessary to combat the economic pressure on ECC -
Providers to reduce practical testing costs at the expense of ECC -Raters (by increasing 
the proctor -student ratio). A smaller proctor -to-student ratio is also likely to reduce 
potential chea ting. A rigorous testing curriculum is necessary to ensure each ECC -Rater 
is able to accurately determine building standards compliance, so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviic  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater has 
access to test equipment and works alone during the test. These requirements ensure 
the ECC -Rater will be able to complete an accurate field verification and diagnostic test   
Necessity:  This addition is necessary ensure that the ECC -Rater can complete the test 
and can do it alone. A rigorous testing curriculum is necessary to ensure each ECC -
Rater is able to accurately determine building standards compliance, so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviid  
Specific Purpose:  The purpose of this addition is to require that all practical tests are 
reviewed and approved by the CEC  during the ECC -Provider application review process 
prior to use.  
Necessity:  This addition is necessary to ensure that both the facility and test 
procedures are adequate under these regulations and give the Commission the 
required oversight to ensure a program will increase energy efficiency and reduce waste 
through adequate testin g. A rigorous testing curriculum is necessary to ensure each 
ECC -Rater is able to accurately determine building standards compliance, so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviii  
Specific Purpose:  The purpose of this addition is to define acceptable features of 
proctoring software and give the Commission final approval of the proctoring software.  
Necessity:  This addition is necessary to allow the ECC -Providers to augment its online 
learning systems (if necessary) or provide alternative proctoring software. The  
 proctoring software will help ensure Raters are fairly tested and will be able to replicate 
field verification outside of the test format. These changes will increase testing 
accuracy, thereby increasing energy efficiency and reduce waste. Rigorous testing 
standards are necessary to ensure each ECC -Rater is able to accurately determine 
building standards compliance, so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)1Aviiia  
Specific Purpose:  The purpose of this addition is to require a time -limiting feature for 
proctoring software.  
Necessity:  This addition is necessary to limit both the training and testing portion of the 
ECC -Rater certification process. A reasonable amount of time simulates how much time 
will be available during field verification testing. Time -limited testing will prepare rat ers 
for field testing, thereby increasing the number of sites that can be tested for energy 
efficiency. Rigorous testing standards are necessary to ensure each ECC -Rater is able 
to accurately determine building standards compliance, so that wasteful energy  
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)1Aviiib  
Specific Purpose:  The purpose of this addition is to establish the minimum monitoring 
system for the proctoring software.  
Necessity:  This addition is necessary to ensure that the ECC -Rater is taking the 
training or testing and is not accessing restricted materials. The proctoring software will 
help ensure Raters are fairly tested and will be able to replicate field verification outside 
of the test format. These changes will increase testing accuracy, thereby increasing 
energy efficiency and reducing waste. Rigorous testing standards are necessary to 
ensure each ECC -Rater is able to accurately determine building standards compl iance 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1B  
Specific Purpose:  The purpose of this addition is to provide for a challenge test to 
indoctrinate a certified ECC -Rater into a new ECC -Provider system. The challenge test 
must meet certain requirements to ensure it meets the covered subject material.  
Necessity:  This addition is necessary so as not to waste time and resources training an 
already certified ECC -Rater when it is not necessary. A thorough challenge test ensures 
an ECC -Rater will be able to accurately determine building standards compliance, so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
   
  
Section:  10-103.3(d)1Bi   
 Specific Purpose:  The purpose of this addition is to restrict the challenge test to 
certified ECC -Raters.  
Necessity:  This addition is necessary to restrict access to the ECC -Rater certification to 
only those individuals that have been trained and certified by CEC -approved ECC -
Providers. A thorough challenge test ensures an ECC -Rater will be able to accurately 
determine building standards compliance, so that wasteful energy consumption is 
reduced, as directed by PRC 25402, while also ensuring the ECC -Rater is eligible to sit 
for the test . 
  
Section:  10-103.3(d)1Bii  
Specific Purpose:  The purpose of this addition is to restrict the challenge test to live 
proctored testing only.  
Necessity:  This addition is necessary to ensure that the ECC -Rater is the person taking 
the challenge test. A thorough challenge test ensures an ECC -Rater will be able to 
accurately determine building standards compliance, so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Biii  
Specific Purpose:  The purpose of this addition is to limit the difficulty of the challenge 
test to only the training materials.  
Necessity:  This addition is necessary to ensure that the difficulty of the challenge test is 
consistent regardless of the ECC -Provider. A thorough challenge test ensures an ECC -
Rater will be able to accurately determine building standards compliance, so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1Biv  
Specific Purpose:  The purpose of this addition is to ensure the challenge test covers 
all of the training materials.  
Necessity:  This addition is necessary to ensure that the subject of the challenge test is 
consistent regardless of the ECC -Provider. A thorough challenge test ensures an ECC -
Rater will be able to accurately determine building standards compliance, so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)1C  
Specific Purpose:  The purpose of this addition is to allow abbreviated training and 
testing for ECC -Raters certified for the previous Energy Code that will focus on only the 
changes in the new Energy Code.  
Necessity:  This addition is necessary to reduce the training and testing time for 
experienced ECC -Raters. A rigorous testing curriculum is necessary to ensure each  
 ECC -Rater is able to accurately determine building standards compliance, so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)2  
Specific Purpose:  The purpose of this addition is to establish the requirements for 
ECC -Rater certification as well as the responsibilities of the ECC -Provider upon 
certification.  
Necessity:  This addition is necessary to ensure that the certification process is similar 
regardless of the ECC -Provider. Rigorous consistent training requirements among ECC -
Raters are necessary to ensure they are able to accurately and consistently determine 
building standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)2A  
Specific Purpose:  The purpose of this addition is to establish both the limits (a single 
code cycle) and requirements (required training and passing tests) to certify an ECC -
Rater.  
Necessity:  This addition is necessary to make ECC -Rater training required for 
certification. Certification is limited to each code cycle, therefore regular training or 
testing is necessary to ensure ECC -Raters are able to accurately conduct field 
verifications and en sure energy efficiency or reduce energy waste. The certification 
ensures the training requirements are enforceable, which ensure ECC -Raters are able 
to accurately and consistently determine building standard compliance  which in turn 
reduce waste ful energy consumption , as directed by PRC 25402.  
  
Section:  10-103.3(d)2B  
Specific Purpose:  The purpose of this addition is to provide and require a written 
agreement of conduct and rights between the ECC -Provider and ECC -Rater.  
Necessity:  This addition is necessary to help establish the roles, responsibilities, and 
rights of the ECC -Rater. The certification ensures the training requirements are 
enforceable, which ensure ECC -Raters are able to accurately and consistently 
determine building standard compliance which in turn reduce wasteful energy 
consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)2C  
Specific Purpose:  The purpose of this addition is to prevent ineligible ECC -Raters from 
being certified.  
Necessity:  This addition is necessary to protect the reputation of the ECC program. 
Certified ECC -Raters will help maintain the accuracy of field verification, thereby 
increasing energy efficiency and reducing waste. A reputable ECC Program is  
 necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.    
  
Section:  10-103.3(d)2D  
Specific Purpose:  The purpose of this addition is to create a publicly accessible list of 
certified ECC -Raters.  
Necessity:  This addition is necessary to track ECC -Raters and their current certification 
status while giving the public access to ensure they are working with a certified ECC -
Rater. Certified ECC -Raters will carry out field verification testing to ensure energy 
efficiency and reduce waste. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)2Di  
Specific Purpose:  The purpose of this addition is to identify, by first and last name, the 
certified ECC -Rater in the list of certified ECC -Raters.  
Necessity:  This addition is necessary to allow the public to independently verify the 
name of the certified ECC -Rater. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)2Dii  
Specific Purpose:  The purpose of this addition is to identify the business (not personal) 
contact information of the certified ECC -Rater within the list of certified ECC -Raters.  
Necessity:  This addition is necessary to protect the personal information of the ECC -
Rater while allowing the public to identify the Rater by their contact information. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)2Diia  
Specific Purpose:  The purpose of this addition is to identify the business (not personal) 
contact information of the certified ECC -Rater.  
Necessity:  This addition is necessary to protect the personal information of the ECC -
Rater while allowing the public to identify the Rater by their contact information. A 
reputable ECC Program is necessary to encourage widespread program adoption and  
 accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)2Diib  
Specific Purpose:  The purpose of this addition is to identify the business (not personal) 
contact information of the certified ECC -Rater.  
Necessity:  This addition is necessary to protect the personal information of the ECC -
Rater while allowing the public to identify the Rater by their contact information. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)2Diic  
Specific Purpose:  The purpose of this addition is to identify the business (not personal) 
contact information of the certified ECC -Rater.  
Necessity:  This addition is necessary to protect the personal information of the ECC -
Rater while allowing the public to identify the Rater by their contact information. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)2Diii  
Specific Purpose:  The purpose of this addition is to make public the certification status 
of the ECC -Rater, allowing the public to independently verify that the ECC -Rater they 
hire is eligible to perform field verification and diagnostic testing.  
Necessity:  This addition is necessary not only for the public but also for the CEC ’s 
investigation into ECC -Rater misconduct. The main purpose of this requirement is to 
help consumers to find or verify an ECC -Rater. However, this is also helpful for 
investigations regarding an ECC -Rater or ECC -Rater Company.  A reputable ECC 
Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)3  
Specific Purpose:  The purpose of this addition is to identify the requirements for the 
ECC -Provider when providing training for the ECC -Rater Company. The ECC -Provider 
training may not exceed 8 hours in duration and must have its materials approved by 
the Commission as part  of the ECC -Provider’s training curriculum.  
Necessity:  This addition is necessary to allow the ECC -Provider to understand the 
scope and expectations of the CEC  pertaining to ECC -Rater Company training. These  
 requirements must be met for the Commission to approve the ECC -Provider’s 
application materials. A rigorous t raining  curriculum is necessary to ensure each ECC -
Rater Company is able to  adhere to its responsibilities  which  assist in reducing wasteful 
energy consumption , as directed by PRC 25402.    
  
Section:  10-103.3(d)3A  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater Company 
with a basic understanding of the responsibilities of the ECC -Rater.  
Necessity:  This addition is necessary to help ensure that the ECC -Rater Company 
does not inadvertently order the ECC -Rater to perform a task outside of their role. A 
rigorous training curriculum is necessary to ensure each ECC -Rater Company is able to 
adhere to its responsibilities which assist in reducing wasteful energy consumption, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)3B  
Specific Purpose:  The purpose of this addition is to establish the minimum training for 
the ECC -Rater Company.  
Necessity:  This addition is necessary to ensure that the training is consistent 
regardless of the ECC -Provider. The training provides the necessary knowledge set for 
ECC -Raters to participate in the ECC program and accurately conduct field verification 
and testing to  increase energy efficiency and reduce waste. A rigorous training 
curriculum is necessary to ensure each ECC -Rater Company is able to adhere to its 
responsibilities which assist in reducing wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)3Bi  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company understands the roles and responsibilities of entities involved in the project.  
Necessity:  This addition is necessary to address several instances of overstepping by 
ECC -Rater Companies when working with builders and contractors. The addition 
ensures ECC -Raters do not go beyond the purview of the ECC program. A rigorous 
training curriculum is necessary to ensure each ECC -Rater Company is able to adhere 
to its responsibilities which assist in reducing wasteful energy consumption, as directed 
by PRC 25402.   
  
Section:  10-103.3(d)3Bii  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company understands the progressive discipline process for both the ECC -Rater and 
ECC -Rater Company.   
 Necessity:  This addition is necessary to ensure that the training for ECC -Rater 
Companies is consistent regardless of the ECC -Provider. Progressive discipline creates 
an incentive for ECC -Raters to conduct accurate energy efficiency testing. It is 
important for ECC -Rater Companies to understand the progressive discipline process 
and its role in that process so that the company can be proactive in managing its 
employed ECC -Raters. A rigorous training curriculum is necessary to ensure each 
ECC -Rater Company is able to a dhere to its responsibilities which assist in reducing 
wasteful energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)3Biii  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company understands the quality assurance process for both the ECC -Rater and ECC -
Rater Company.  
Necessity:  This addition is necessary to ensure that the training for ECC -Rater 
Companies is consistent regardless of the ECC -Provider. Quality assurance is a critical 
component of the ECC Program and requires that ECC -Rater Companies be aware of 
the process and its role in that process. A rigorous training curriculum is necessary to 
ensure each ECC -Rater Company is able to adhere to its responsibilities which assist in 
reducing wasteful energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)3Biv  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company is aware of the conflict -of-interest  requirements for both the ECC -Rater and 
ECC -Rater Company.  
Necessity:  This addition is necessary to ensure that the training for ECC -Rater 
Companies is consistent regardless of the ECC -Provider.  Conflict of interest is a 
difficult requirement to verify compliance and is the primary source of complaints and 
investigations. I t is critical that the ECC -Rater Companies understand how the conflict -
of-interest  regulations apply to both the ECC -Rater and the ECC -Rater Company. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately de termine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)3Bv  
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company understands the prohibition limits for both the ECC -Rater and ECC -Rater 
Company.  
Necessity:  This addition is necessary to ensure that the training for ECC -Rater 
Companies is consistent regardless of the ECC -Provider. Prohibition limitations are the 
basis of the conflict -of-interest  requirements. They may apply to either (or both) the 
ECC -Rater and ECC -Rater Company. The ECC -Rater Company has responsibilities to  
 actively enforce the conflict -of-interest  prohibitions as part of the progressive discipline 
process. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)4  
Specific Purpose:  The purpose of this addition is to establish the requirements for 
ECC -Rater Company certification as well as the responsibilities of the ECC -Provider 
upon certification.  
Necessity:  This addition is necessary to ensure that the certification process is similar 
regardless of the ECC -Provider. These requirements help ensure that an ECC -Rater 
Company is consistently regulated regardless of the ECC -Provider so as not to give any 
one ECC -Provider an unfair advantage. A properly regulated ECC -Rater Company  
certification process ensures  the relevant requirements can be easily enforced , which in 
turn ensure s ECC -Raters are able to determine accurately and consistently  building 
stand ard compliance which reduce s wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)4A  
Specific Purpose:  The purpose of this addition is to establish both the limits (a single 
code cycle) and requirements (required training and passing tests) to certify an ECC -
Rater Company.  
Necessity:  This addition is necessary to make ECC -Rater Company training a 
requirement for certification. A properly regulated ECC -Rater Company certification 
process ensures the relevant requirements can be easily enforced, which in turn 
ensures ECC -Raters are able to determine accurately and consistently  building 
standard compliance which reduces wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)4B  
Specific Purpose:  The purpose of this addition is to provide a written agreement of 
conduct and rights between the ECC -Provider and ECC -Rater Company.  
Necessity:  This addition is necessary to help establish the roles, responsibilities, and 
rights of the ECC -Rater Company while making clear the ECC -Rater Company will 
comply with all applicable laws and requirements. A properly regulated ECC -Rater 
Company certification process ensures the relevant requirements can be easily 
enforced, which in turn ensures ECC -Raters are able to determine accurately and 
consistently  building standard compliance which reduces wasteful energy consumption, 
as directed by PRC 25 402. 
   
 Section:  10-103.3(d)4C  
Specific Purpose:  The purpose of this addition is to create a publicly available list that 
will allow the public to independently identify a certified ECC -Rater Company.  
Necessity:  This addition is necessary to track ECC -Rater Companies and their current 
certification status. A publicly accessible list increases  accountability and the overall 
reputation of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)4D  
Specific Purpose:  The purpose of this addition is to clarify that only companies that 
meet the requirements stated are eligible for certification. This prevents ineligible ECC -
Rater Companies from being certified.  
Necessity:  This addition is necessary to protect the reputation of the ECC program. A 
good reputation of the ECC program may encourage further participation and therefore 
increase energy efficiency through aggressive testing and verification , as directed by 
PRC 25402 .  
  
Section:  10-103.3(d)4E  
Specific Purpose:  The purpose of this addition is to make plain that the ECC -Rater 
Companies do not need to update their training or certification with the new code cycle 
after initial certification if the company maintains its eligibility under section 10 -
103.3(f)1B.  
Necessity:  This addition is necessary because the changes likely in a code cycle that 
would affect the ECC -Rater Company training are minimal and would not result in better 
performance or compliance.  
  
Section:  10-103.3(d)4F  
Specific Purpose:  The purpose of this addition is to allow the public to independently 
identify a certified ECC -Rater Company by requiring ECC -Providers to maintain a list of 
all certified ECC -Rater Companies.  
Necessity:  This addition is necessary to track ECC -Rater Companies and their current 
certification status. A publicly accessible list increases accountability and the overall 
reputation of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)4Fi   
 Specific Purpose:  The purpose of this addition is to identify the business (not personal) 
contact information of the certified ECC -Rater Company certified primary.  
Necessity:  This addition is necessary to protect the personal information of the ECC -
Rater Company certified primary while allowing the public to identify the Rater by their 
contact information. A publicly accessible list increases accountability and the overall 
reputation of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)4Fii  
Specific Purpose:  The purpose of this addition is to identify the business contact 
information of the certified ECC -Rater Company.  
Necessity:  This addition is necessary to allow the public to identify the Rater Company 
by their contact information. A publicly accessible list increases accountability and the 
overall reputation of the ECC Program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)4Fiii  
Specific Purpose:  The purpose of this addition is to identify the business contact 
information of the certified ECC -Rater Company.  
Necessity:  This addition is necessary to allow the public to identify the Rater Company 
by their contact information. A publicly accessible list increases accountability and the 
overall reputation of the ECC Program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)4Fiiia  
Specific Purpose:  The purpose of this addition is to identify the business contact 
information of the certified ECC -Rater Company.  
Necessity:  This addition is necessary to allow the public to identify the Rater Company 
by their contact information. A publicly accessible list increases accountability and the 
overall reputation of the ECC Program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
   
 Section:  10-103.3(d)4Fiiib  
Specific Purpose:  The purpose of this addition is to identify the business contact 
information of the certified ECC -Rater Company.  
Necessity:  This addition is necessary to allow the public to identify the Rater Company 
by their contact information. A publicly accessible list increases accountability and the 
overall reputation of the ECC Program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)4Fiiic  
Specific Purpose:  The purpose of this addition is to identify the business contact 
information of the certified ECC -Rater Company.  
Necessity:  This addition is necessary to allow the public to identify the Rater Company 
by their contact information. A publicly accessible list increases accountability and the 
overall reputation of the ECC Program. A reputable ECC Program is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(d)4Fiv  
Specific Purpose:  The purpose of this addition is to make public the certification status 
of the ECC -Rater Company.  
Necessity:  This addition is necessary not only for the public but also for the CEC  
investigation into ECC -Rater Company misconduct. It is essential that when an ECC -
Rater Company is disciplined that the public and industry is reasonably informed and 
can act accordingly. It is additionally important to aid the CEC  in its investigations. A 
publicly accessible list increases accountability and the overall reputation of the ECC 
Program. A reputable ECC Program is necessary to encourage widespread program 
adoption and accu rately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
Section : 10-103.3(d) 4G 
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
maintain a record of ECC -Rater Companies that will offer services beyond field 
verification and diagnostic testing.  
Necessity:  This addition is necessary to allow the CEC  and local enforcement agencies 
to verify that an ECC -Rater Company can offer services beyond field verification and 
diagnostic testing without undue influence on the ECC -Rater  and to preserve the ECC -
Rater third -party, independent status from the builder.  A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine  
 building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)5  
Specific Purpose:  The purpose of this addition is to give ECC -Providers a list of 
accomplishable quality assurance measures that can be effective in terms of identifying 
problematic ECC -Raters and ECC -Rate Companies.  
Necessity:  This addition is necessary to address the ongoing issue of quality 
assurance with the ECC program. Accurate field verification testing is necessary to be 
able to identify inefficient installations. If these verifications are conducted incorrectly, 
they wil l result in waste and higher costs to occupants. Quality assurance ensures data 
collected and reported is accurate. Quality assurance verification is also necessary to 
identify bad actors among ECC -Raters and ECC -Rater Companies. A robust quality 
assurance  system is essential to confirm the efficacy of the ECC Program , which is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5A  
Specific Purpose:  The purpose of this addition is to establish the need and 
qualifications of quality assurance staff that the ECC -Provider must hire. Quality 
assurance staff may not include active ECC -Raters and are subject to the same 
standards of required conduct as othe rs conducting field verification and diagnostics, 
additionally, they themselves are subject to Quality Assurance review.  
Necessity:  This addition is necessary to address staff shortages that may result in 
inadequate quality assurance that do not meet the requirements. The addition is also 
necessary to maintain the integrity and impartiality of quality assurance staff.  A robust 
quality assurance system is essential to confirm the efficacy of the ECC Program , which 
is necessary  to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
   
Section:  10-103.3(d)5B  
Specific Purpose:  The purpose of this addition is to recognize and reward a superior 
ECC -Rater that has demonstrated that they are capable of trustworthy field verification 
and diagnostic testing with a significantly reduced quality assurance rate.  
Necessity:  This addition is necessary to allow a greater encouragement of ECC -Raters 
to perform at a higher level. Verified ECC -Raters are conferred benefits not conferred to 
non-verified raters.  Exemplary ECC -Raters are more likely to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
   
 Section:  10-103.3(d)5Bi  
Specific Purpose:  The purpose of this addition is to remind the Verified Rater that this 
designation can be revoked.  
Necessity:  This addition is necessary to ensure that verified ECC -Raters are still 
checked for quality assurance. If a verified ECC -Rater fails a quality assurance check, 
they may lose their status. This ensures they maintain their high quality of work. A 
robust quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)5Bii  
Specific Purpose:  The purpose of this addition is to allow the Verified ECC -Rater to 
advertise their status and set themselves apart from other ECC -Raters.  
Necessity:  This addition is necessary to allow the use of CEC  designations in 
advertisements. The designation and allowed marketing materials incentivize the ECC -
Rater to accurately carry out the ECC -program, benefitting the Rater through increased 
business. Exemplary ECC -Raters are more likely to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.   
  
Section:  10-103.3(d)5C  
Specific Purpose:  The purpose of this addition is to establish three types of quality 
assurance audits that are to be performed by the ECC -Provider on the ECC -Rater.  
Necessity:  This addition is necessary to ensure that the quality assurance procedures 
are consistent regardless of the ECC -Provider. A robust and consistent quality 
assurance system is essential to confirm the efficacy of the ECC Program , which is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ci  
Specific Purpose:  The purpose of this addition is to reframe how and when onsite 
audits are to be used in the future by ECC -Providers.  
Necessity:  This addition is necessary to address to the ongoing issue of ECC -
Providers be unable to perform enough onsite audit in the past. Onsite audits are used 
as a quality assurance tool by the ECC -Provider and the CEC . The CEC  requires that 
each ECC -Rater be audited onsite once per year. The ECC -Provider can, as part of its 
investigation authority, include additional onsite audits at its discretion. Onsite audits 
provide a means to evaluate the actions of an ECC -Rater in the fi eld. A robust and 
consis tent quality assurance system is essential to confirm the efficacy of the ECC  
 Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Cia  
Specific Purpose:  The purpose of this addition is to establish when an onsite audit can 
be performed, an onsite audit should not be performed while an ECC -Rater is on the 
project site.  
Necessity:  This addition is necessary to prevent the ECC -Rater from influencing the 
ECC -Provider auditor. A robust and consistent quality assurance system is essential to 
confirm the efficacy of the ECC Program , which is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cib  
Specific Purpose:  The purpose of this addition is to limit notification to the ECC -Rater 
regarding the audit until the audit is complete.  
Necessity:  This addition is necessary to prevent the ECC -Rater from altering the field 
verification and diagnostic test for the project in preparation for the audit. A robust and 
consistent quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Cic  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of an onsite audit.  
Necessity:  This addition is necessary to ensure that onsite audits are consistent 
regardless of the ECC -Provider. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cic(i)  
Specific Purpose:  The purpose of this addition is to verify the registered certificate of 
installation and certificate of verification for the project.  
Necessity:  This addition is necessary to establish a basis for comparison in an onsite 
audit. A robust and consistent quality assurance system is essential to confirm the 
efficacy of the ECC Program , which is necessary to accurately determine building  
 energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cic(ii)  
Specific Purpose:  The purpose of this addition is to duplicate the field verification or 
diagnostic test performed by the ECC -Rater for the onsite audit.  
Necessity:  This addition is necessary to verify the efficacy of the ECC -Rater’s field 
verification or diagnostic test. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cid  
Specific Purpose:  The purpose of this addition is to establish the passing criteria for an 
onsite audit.  
Necessity:  This addition is necessary to ensure consistent passing criteria regardless 
of ECC -Provider. A robust and consistent quality assurance system is essential to 
confirm the efficacy of the ECC Program , which is necessary to accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
 
Section:  10-103.3(d)5Cid(i)  
Specific Purpose:  The purpose of this addition is to include an inspection of the 
certification of installation and verification regarding false, inaccurate, or incomplete 
information.  
Necessity:  This addition is necessary to ensure that the registered documents are not 
fabricated. A robust and consistent quality assurance system is essential to confirm the 
efficacy of the ECC Program , which is necessary to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cid(ii)  
Specific Purpose:  The purpose of this addition is to establish that passing the auditor 
field verification and diagnostic test is sufficient to show a pass on the audit.  
Necessity:  This addition is necessary to avoid engaging in obtuse measurements of 
accuracy and focusing on the objective of the field verification and diagnostic testing. A 
robust and consistent quality assurance system is essential to confirm the efficacy of 
the ECC Program , which is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
   
Section:  10-103.3(d)5Cie  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
perform an onsite audit when it is engaged in an investigation of a homeowner 
complaint about a field verification or diagnostic test.  
Necessity:  This addition is necessary to encourage the ECC -Provider to take 
complaints and investigations seriously. Conducting an onsite audit after a complaint 
increases public confidence in the ECC program and assists in identifying faulty field 
verification and diagnostic tests that would have otherwise go ne unnoticed.  A robust 
and consistent quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced , as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Cif  
Specific Purpose:  The purpose of this addition is to establish the frequency of sample 
group onsite audits.  
Necessity:  This addition is necessary to address an overall misunderstanding 
regarding ECC -Provider quality assurance audits for sample groups. The requirement 
makes clear that onsite audits are required at specific intervals. A robust and consistent 
quality assurance system is essential to confirm the efficacy of the ECC Program , which 
is necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cif(i)  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to test 
both the untested home and the tested home within the same sample group.  
Necessity:  This addition is necessary to test both the ECC -Provider's abilities as well 
as the subcontractor's ability to perform the field verification and diagnostic tests. A 
robust and consistent quality assurance system is essential to confirm the efficacy of 
the ECC Program , which is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)5Cif(ii)  
Specific Purpose:  The purpose of this addition is to encourage the developer to allow 
the ECC -Provider to conduct the sample grouped onsite audit, otherwise the sample 
groups will be considered conflicted data.  
Necessity:  This addition is necessary because the ECC -Provider does not have a right 
of entry in the same way a local jurisdiction inspector does. Therefore, an incentive  
 must be placed for the developer to grant testing access. A robust and consistent 
quality assurance system is essential to confirm the efficacy of the ECC Program , which 
is necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cig  
Specific Purpose:  The purpose of this addition is to establish the actions an ECC -
Provider must take if a developer refuses the auditor access.  
Necessity:  This addition is necessary to prevent the ECC -Rater or ECC -Rater 
Company from influencing the developer. The ECC -Provider must be able to confirm 
the results of an ECC Rater or Company, in the absence of this, the Provider must 
investigate to confirm the a ccuracy of submitted data. A robust and consistent quality 
assurance system is essential to confirm the efficacy of the ECC Program , which is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energ y consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cih  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to use 
the progressive discipline in response to a failed onsite audit of a sample group.  
Necessity:  This addition is necessary to redress ECC -Raters that have falsified a 
sample group field verification and diagnostic test. A robust and consistent quality 
assurance system is essential to confirm the efficacy of the ECC Program , which is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ci i  
Specific Purpose:  The purpose of this addition is to require the use of photographic 
evidence for onsite audits.  
Necessity:  This addition is necessary to codify the current best practice of ECC -
Provider performing onsite audits. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Cii  
Specific Purpose:  The purpose of this addition is to establish shadow audits to verify 
ECC -Rater inspection of quality insulation installations. Shadow audits are a quality 
assurance measure to help ensure that ECC -Raters are performing the quality 
insulation installation inspections to code. They are required once per year for each 
ECC -Rater o r at the discretion of the ECC -Provider or CEC .   
 Necessity:  This addition is necessary to address one of the most abused energy 
efficiency measures  provided by the Energy Code. Quality insulation installation is a 
visual inspection of the wall assembly at various stages of construction. As such, it is 
often overlooked. This gives rise to builders pressuring ECC -Raters to falsify the quality 
insulatio n installation inspection documentation. There is no effective means of verifying 
the validity of an ECC -Rater inspection other than shadow auditing. A robust  and 
consistent quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Ciia  
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater to be advised 
that they are being audited on the day of the audit. The auditor must also be granted 
entry by the homeowner, if they are not, the audit will be rescheduled.  
Necessity:  This addition is necessary because there is no other means of verifying that 
an ECC -Rater can or has correctly inspected a quality insulation installation. Auditors 
may not enter without permission and must be granted access;  this is accounted for 
through mandatory rescheduling. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ciib  
Specific Purpose:  The purpose of this addition is to ensure that developer do not 
refuse an ECC -Provider auditor when the development is using quality insulation 
installation. If an auditor is refused entry, the data registry will not accept sample -based 
compliance document s.  
Necessity:  This addition is necessary to encourage cooperation from the developer for 
access to the project site because the ECC -Provider auditor does not have a right of 
entry. A robust and consistent quality assurance system is essential to confirm the 
efficacy of the ECC Program , which is necessary to accurately determine building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ciic  
Specific Purpose:  The purpose of this addition is to clearly establish that shadow 
audits are used only for quality insulation installations.  
Necessity:  This addition is necessary to prevent the shadow audit from being misused. 
While shadow audits are the only means to verify that an ECC -Rater is correctly 
following the quality insulation installation inspection procedures, it is a less effective  
 means of quality assurance for most any other purpose. The primary quality assurance 
for all ECC -Rater field verifications and diagnostic tests is onsite auditing. A robust and 
consistent quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Ciid  
Specific Purpose:  This addition is reserved to preserve the number of the sections that 
follow.  
Necessity:  Staff determined that this addition was not necessary based on comments 
received. It is important to maintain the numbering of the sections that follow because 
they are references throughout Section 10 -103.3.  
  
Section:  10-103.3(d)5Ciie  
Specific Purpose:  The purpose of this addition is to require proper documentation and 
notification of the audit results in the quality assurance database, those results must be 
documented by the ECC -Provider and provided to the ECC -Rater and ECC -Rater 
Company.  
Necessity:  This addition is necessary to encourage proper documentation of ECC -
Rater inspections of quality insulation installations. A robust and consistent quality 
assurance system is essential to confirm the efficacy of the ECC Program , which is 
necessary to accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ciif  
Specific Purpose:  The purpose of this addition is to provide progressive discipline for 
an ECC -Rater that fails the shadow audit.  
Necessity:  This addition is necessary to require consistent disciplinary action 
regardless of the ECC -Provider while incentivizing the ECC -Rater to conduct accurate 
testing. Progressive discipline encourage s accurate testing  which  helps to identify 
inadequate building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Ciii  
Specific Purpose:  This addition is reserved to preserve the number of the sections that 
follow.  
Necessity:  Staff determined that this addition was not necessary based on comments 
received. It is important to maintain the numbering of the sections that follow because 
they are references throughout Section 10 -103.3.   
   
Section:  10-103.3(d)5Civ  
Specific Purpose:  The purpose of this addition is to establish desk audits to verify the 
inspections of ECC -Raters across all field verifications and diagnostic tests. Desk audits 
will require an ECC -Provider to evaluate the registered compliance documents in the 
data regis try of ECC -Raters once per year. Verified ECC -Raters will instead only be 
subject to desk audits every code cycle.  
Necessity:  This addition is necessary to ensure that quality assurance is implemented 
consistently regardless of the ECC -Provider. Desk audits are an effective tool to 
determine if an ECC -Rater is consistently falsifying compliance documentation by 
comparing disparat e projects for the same ECC -Rater as well as comparing ECC -
Raters to each other on similar projects. This creates a foundation of expected results 
for field verification and diagnostic testing performed by ECC -Raters.  A robust and 
consistent quality assurance system is essential to confirm the efficacy of the ECC 
Program , which is necessary to accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)5Civa  
Specific Purpose:  The purpose of this addition is to develop maximum variances for 
each data entry so that future desk audits may be streamlined using consistent criteria.  
Necessity:  This addition is necessary to improve quality assurance audits and the 
reputation of the ECC program. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Civb  
Specific Purpose:  The purpose of this addition is to direct an ECC -Provider towards a 
project site and  provide guidance on what documents to consider when auditing a site. 
The auditor may do this by collecting compliance documents and contacting the local 
building authority.  
Necessity:  This addition is necessary to ensure that ECC -Providers do not initially rely 
on generalizations for a desk audit. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Civc   
 Specific Purpose:  The purpose of this addition is to compare desk audits to expected 
tolerances.  
Necessity:  This addition is necessary to provide a foundation for expectations and 
possible further investigation. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Civd  
Specific Purpose:  The purpose of this addition is to expand the focused desk audit to 
other field verifications and diagnostic tests performed by the same ECC -Rater. If 
irregularities are discovered, the ECC -Provider will investigate further to determine if 
test results were falsified or are inaccurate.  
Necessity:  This addition is necessary to ensure that ECC -Raters are not copying field 
verifications and diagnostic tests from one project and using them in other projects. A 
robust and consistent quality assurance system is essential to confirm the efficacy of 
the ECC Program , which is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)5Cive  
Specific Purpose:  The purpose of this addition is to document the desk audit results 
for the ECC -Provider, ECC -Rater, and ECC -Rater Company.  
Necessity:  This addition is necessary to enable the ECC -Rater and ECC -Rater 
Company to be advised regarding the results of the desk audit on whether the results 
are either positive or negative. A robust and consistent quality assurance system is 
essential to confirm the efficacy of the ECC Program , which is necessary to accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Civf  
Specific Purpose:  The purpose of this addition is to connect the failed desk audit with 
the progressive discipline requirements for the ECC -Rater and possibly the ECC -Rater 
Company.  
Necessity:  This addition is necessary to ensure that desk audit results are consistently 
treated regardless of the ECC -Provider. The addition creates a consequence through 
progressive discipline for failing a desk audit, thereby revealing inaccuracies and 
improving a ccuracy over time benefiting energy efficiency and reducing waste.  
Progressive discipline encourages accurate testing which helps to identify inadequate 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduce d, as directed by PRC 25402.   
   
Section:  10-103.3(d)5D  
Specific Purpose:  The purpose of this addition is to address the issue of a flawed field 
verification and diagnostic test discovered during an audit.  
Necessity:  This addition is necessary to ensure that there is a remedy in place for 
when flawed testing is discovered. The additions create a clear path for efficient 
resolutions.  Clear and expeditious  pathway s for remedying inaccurate ECC ratings are 
necessary to  reduce wasteful energy consumption , as directed by PRC 25402.  
  
Section:  10-103.3(d)5Di  
Specific Purpose:  The purpose of this addition is to define what qualifies as a flawed 
field verification or diagnostic test.  
Necessity:  This addition is necessary to ensure that only flawed tests are qualified for 
remedies. Clear and expeditious pathways for remedying inaccurate ECC ratings are 
necessary to reduce wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)5Dii  
Specific Purpose:  The purpose of this addition is to make the ECC -Provider 
responsible to remedy the flawed field verification or diagnostic test.  
Necessity:  Shifting the remedy to the provider removes the burden from an 
inexperienced party, most likely the homeowner, who would have had to seek redress 
for the faulty test results.  Clear and expeditious pathways for remedying inaccurate 
ECC ratings are necessary to reduce wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)5Diii  
Specific Purpose:  The purpose of this addition is to establish that the remedy to a 
flawed field verification or diagnostic test is to provide the audit (of the same test) 
performed by the ECC -Provider to the homeowner (or hiring party).  
Necessity:  This addition is necessary so as to not overburden the ECC -Provider with 
unnecessary costs and limit the cost of remedying flawed test results only to that of the 
boundaries of the ECC program. Clear and expeditious pathways for remedying 
inaccurate ECC ratings are necessary to reduce wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)5E  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to charge 
the ECC -Rater a quality assurance fee meant to cover the expenses of providing the 
required audits.   
 Necessity:  This addition is necessary to aid the ECC -Provider in performing its required 
quality assurance audits for the ECC -Rater field verifications and diagnostic tests. A 
robust and consistent quality assurance system is essential to confirm the efficacy of 
the ECC Program , which is necessary to accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)6  
Specific Purpose:  The purpose of this addition is to require ECC -Providers to create a 
queries and complaints process for the public and governing agencies.  
Necessity:  This addition is necessary to ensure that complaints and queries are 
addressed consistently regardless of the ECC -Provider. An accountable ECC Program 
assists in increasing the overall accuracy of ECC ratings , thereby increasing building 
standard compliance and reducing wasteful energy consumption as directed by PRC 
2540 2.  
  
Section:  10-103.3(d)6A  
Specific Purpose:  The purpose of this addition is to establish the scope and basic 
actions that an ECC -Provider must take when receiving a complaint or query. The 
addition requires the ECC -Provider to respond to complaints in a timely manner, ensure 
ECC -Raters notify compla ints about the complaint process, retain records of 
complaints, and report a summary of all complaints to the Commission annually.  
Necessity:  This addition is necessary to prevent the ECC -Provider from having to take 
extreme measures for every complaint received or relegating all complaints to a 
backlog. The addition creates an orderly framework of how complaints should be 
handled for efficient processing and reporting. An accountable ECC Program assists in 
increasing the overall accuracy of ECC ratings, thereby increasing building standard 
compliance and reducing wasteful energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)6Ai  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of the queries and complaints annual summary, which includes a tracking 
number for each query or complaint in the ECC -Providers tracking system.  
Necessity:  This addition is necessary to ensure a consistent reporting to the CEC  
regardless of the ECC -Provider. A tracking number is a simple means of allowing the 
CEC  to verify that all complaints or queries have been addressed and which ones need 
to be investigated further. An accountable ECC Program assists in increasing the 
overall accuracy of ECC ratings, thereby increasing building standard compliance and 
reducing wasteful energy consumption as directed by PRC 25402.  
   
 Section:  10-103.3(d)6Aii  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of the queries and complaints annual summary, which includes the name 
and contact information of the person submitting the query or complaint.  
Necessity:  This addition is necessary to ensure a consistent reporting to the CEC  
regardless of the ECC -Provider. The contact information allows  the CEC  to follow up 
with the individual submitting the query or complaint to verify that the ECC -Provider is 
following its protocols in compliance with the regulations. An accountable ECC Program 
assists in increasing the overall accuracy of ECC ratings, thereby increasing building 
standard compliance and reducing wasteful energy consumption as directed by PRC 
25402.  
  
Section:  10-103.3(d)6Aiii  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of the queries and complaints annual summary, which includes a 
summary of the query or complaint.  
Necessity:  This addition is necessary to ensure a consistent reporting to the CEC  
regardless of the ECC -Provider. A summary of the query or complaint  allows the CEC  
to understand its nature and evaluate if it is something that the CEC  should follow up 
on. An accountable ECC Program assists in increasing the overall accuracy of ECC 
ratings, thereby increasing building standard compliance and reducing wasteful energy 
consumption as directed by PRC 25402.   
  
Section:  10-103.3(d)6Aiv  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of the queries and complaints annual summary, which includes a 
summary of the result of the ECC -Provider’s investigation and related actions.  
Necessity:  This addition is necessary to ensure  consistent reporting to the CEC  
regardless of the ECC -Provider. A summary of the results of the ECC -Provider actions 
is important for the CEC  to evaluate and verify that the ECC -Provider is in compliance 
with its policies and the Energy Code requirements. An accountable ECC Program 
assists in increasing the overall accuracy of ECC ratings, thereby increasing building 
standard compliance and reducing wasteful energy consumption as directed by PRC 
25402.   
  
Section:  10-103.3(d)6Av  
Specific Purpose:  The purpose of this addition is to establish the minimum 
requirements of the queries and complaints annual summary, which includes a 
summary of the final outcome of the query or complaint.   
 Necessity:  This addition is necessary to ensure a consistent reporting to the CEC  
regardless of the ECC -Provider. A summary of the resolution achieved by the ECC -
Provider allows the CEC  to understand the effectiveness of the query and complaints 
process.  An accountable ECC Program assists in increasing the overall accuracy of 
ECC ratings, thereby increasing building standard compliance,  and reducing wasteful 
energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)6B  
Specific Purpose:  The purpose of this addition is to allow the CEC  to direct an ECC -
Provider to investigate queries related to the performance of the FV&DT and requires 
the ECC -Provider to respond within 30 days of receiving the direction.  
Necessity:  This addition is necessary to allow proper oversight of the ECC -Provider 
and address complaints that come to the CEC . An accountable ECC Program assists in 
increasing the overall accuracy of ECC ratings, thereby increasing building standard 
compliance and reducing wasteful energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)6C  
Specific Purpose:  The purpose of this addition is to provide a separate means of 
complaint from ECC -Raters or ECC -Rater Companies to ECC -Providers.  
Necessity:  This addition is necessary because the complaints from ECC -Raters and 
Rater Companies are more substantive than most any other source of complaint. The 
additional details allow more expedient investigations and are a good source of 
identifying potential im propriety among ECC program participants. An accountable ECC 
Program assists in increasing the overall accuracy of ECC ratings, thereby increasing 
building standard compliance,  and reducing wasteful energy consumption as directed 
by PRC 25402.  
  
Section:  10-103.3(d)7  
Specific Purpose:  The purpose of this addition is to provide for a fair and balanced 
approach to progressive discipline for ECC -Raters. If ECC -Raters fail to perform 
accurate and complete field verification and diagnostic tests, the ECC -Provider must 
take the prescribed dis ciplinary steps to correct noncompliance. The ECC -Provider may 
move toward more severe discipline if violations are severe. The addition also allows 
ECC -Providers and ECC -raters to extend the timeline for final discipline determination 
and clarifies that the Commission may direct an ECC -Provider to investigate or 
discipline an ECC -Rater.  
Necessity:  This addition is necessary to allow the ECC -Provider to discipline bad 
behavior from ECC -Raters while allowing ECC -Rater recourse to address the findings 
of the ECC -Provider. The Commission also retains significant authority to direct 
investigations or dis cipline in the case the ECC -Provider has not already done so.  
Progressive ECC -Rater discipline allows the ECC Program to identify and  discourage  
 inaccurate ECC ratings  so that building energy efficiency standard compliance is 
achieved, and the wasteful energy consumption is avoided, as directed by PRC 25402.    
  
Section:  10-103.3(d)7A  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater reasonable 
notification of the suspected violation. The addition requires the ECC -Provider to issue a 
notice of violation to the ECC -Rater and ECC -Rater Company upon violation discovery. 
The ECC -Rate r Company or independent Rater will notify the affected homeowner, with 
proof of notice to the ECC -Provider. Finally, the ECC -Provider will perform a desk audit 
on the ECC -Rater.  
Necessity:  This addition is necessary to prevent the unwarranted escalation of 
penalties by the ECC -Provider. The entire process gives all parties the ability to 
investigate and respond to issues without unreasonable penalties being forced upon 
ECC -Raters. At the sam e time, these procedures allow the ECC -Provider and CEC  to 
deal effectively with ECC -Raters that are not performing the field verification and 
diagnostic testing per code. Progressive ECC -Rater discipline allows the ECC Program 
to identify and i ncentivize improved rating accuracy so that building energy efficiency 
standard compliance is achieved, and the wasteful energy consumption is avoided, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)7Ai  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
mandate further training for the violating ECC -Rater or another corrective action related 
to the violation within a specified timeframe.  
Necessity:  This addition is necessary to ensure that the corrective action, or additional 
training is appropriate and relevant for the violation, so that the ECC -Rater may learn 
from their mistake. Additional training or other corrective action makes inaccurate test 
results less likely. Progressive ECC -Rater discipline allows the ECC Program to identify 
and discourage inaccurate ECC ratings  so that building energy efficiency standard 
compliance is achieved, and the wasteful energy consumption is avoided, as  directed 
by PRC 25402.    
  
Section:  10-103.3(d)7Aii  
Specific Purpose:  The purpose of this addition is to ensure that the homeowner is 
made whole by the ECC -Rater or ECC -Rater Company and not the ECC -Provider by 
requiring the ECC -Rater or ECC -Rater Company to cover the costs of the original field 
testing and any necessary ret esting due to the violation.  
Necessity:  This addition is necessary to prevent the ECC -Provider from being 
unreasonably burdened by the actions of its certified ECC -Raters or Rater Companies 
while discouraging ECC -Raters and ECC -Rater Companies from submitting faulty test 
results. Progressive ECC -Rater discipline allows the ECC Program to identify and   
 discourage inaccurate ECC ratings  so that building energy efficiency standard 
compliance is achieved, and the wasteful energy consumption is avoided, as directed 
by PRC 25402.    
  
Section:  10-103.3(d)7Aiii  
Specific Purpose:  The purpose of this addition is to specify what elements must be 
contained in the notice of violation to the ECC -Rater.  
Necessity:  This addition is necessary to ensure that the ECC -Rater can respond fully 
within the time allotted. Progressive ECC -Rater discipline allows the ECC Program to 
identify and  discourage inaccurate ECC ratings  so that building energy efficiency 
standard compliance is achieved, and the wasteful energy consumption is avoided, as 
directed by PRC 25402.    
  
Section:  10-103.3(d)7Aiv  
Specific Purpose:  The purpose of this addition is to describe the time limits that the 
ECC -Rater has to respond to the notice of violation issued by the ECC -Provider.  
Necessity:  This is necessary to allow the ECC -Rater to respond without allowing the 
Rater to hold up the proceeding. Progressive ECC -Rater discipline allows the ECC 
Program to identify and  discourage inaccurate ECC ratings  so that building energy 
efficiency standard compliance is achieved, and the wasteful energy consumption is 
avoided, as directed by PRC 25402.    
  
Section:  10-103.3(d)7B  
Specific Purpose:  The purpose of this addition is to establish a second step in the 
progressive disciplinary process for ECC -Raters who fail to comply with the notice of 
violation within the time or receive a second notice of violation within a three -month 
period. The ECC -Provider will then issue a notice to the ECC -Rater and any ECC -Rater 
company for which the ECC -Rater conducts testing for, placing the ECC -Rater on 
probation for up to 6 months.  
Necessity:  This addition is necessary to address ECC -Raters that do not timely 
respond to the notice of violation or have numerous violations. The progressive 
discipline is needed to incentivize the violating ECC -Rater to comply with sanctions 
placed upon them, or to  more closely scrutinize an ECC -Rater who has been 
sanctioned with more than one violation. Progressive ECC -Rater discipline allows the 
ECC Program to identify and  discourage inaccurate ECC ratings  so that building energy 
efficiency standard compliance is achieved, and the wasteful energy consumption is 
avoided, as directed by PRC 25402.    
  
Section:  10-103.3(d)7Bi   
 Specific Purpose:  The purpose of this addition is to require retraining of the ECC -Rater 
as related to the notice of violation. This is accomplished through retaking the training 
for both written and laboratory portions related to the violated regulations.  
Necessity:  This is necessary to keep the penalty within the scope of the violation. 
Progressive ECC -Rater discipline allows the ECC Program to identify and  discourage 
inaccurate ECC ratings  so that building energy efficiency standard compliance is 
achieved, and the wasteful energy consumption is avoided, as directed by PRC 25402.    
  
Section:  10-103.3(d)7Bii  
Specific Purpose:  The purpose of this addition is to provide a written notice to the 
ECC -Rater of the regulatory requirements and violation, time of violations, parties 
affected, corrective actions the ECC -Rater must take, costs to be reimbursed, and the 
timeframe for compl ying with all requirements of the notice of violation.  
Necessity:  This addition is necessary to allow the ECC -Rater to respond to their 
probational status, has a full understanding of what was done incorrectly, and may take 
steps to address the disciplinary action. This addition is necessary to prevent an ECC -
Rater from undermining the integrity of the ECC program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, a s directed by PRC 25402.  
  
Section:  10-103.3(d)7Biii  
Specific Purpose:  The purpose of this addition is to describe the time limits that the 
ECC -Rater has to respond to the notice of probation issued by the ECC -Provider.  
Necessity:  This is necessary to allow the ECC -Rater to respond without allowing the 
Rater to hold up the proceeding. This addition is necessary to prevent an ECC -Rater 
from undermining the integrity of the ECC program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)7C  
Specific Purpose:  The purpose of this addition is to address an ECC -Rater who fails to 
Fully comply with the terms of probation or receives a new notice of violation while on 
probation. The ECC -Provider shall issue a notice of suspension to the ECC -Rater and 
any ECC -Rater C ompany the ECC -Rater tests for.   
Necessity:  This addition is necessary to prevent an ECC -Rater from undermining the 
ECC program reputation. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
   
Section:  10-103.3(d)7Ci  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater with a 
notice of suspension which describes the basis for suspension, duration, and corrective 
actions the ECC -Rater must complete during the suspension.  
Necessity:  This addition is necessary to allow the ECC -Rater the opportunity to 
address the notice of suspension. This addition is necessary to prevent an ECC -Rater 
from undermining the ECC program reputation. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)7Cii  
Specific Purpose:  The purpose of this addition is to provide a time frame for the ECC -
Rater to respond to the notice of suspension.  
Necessity:  This addition is necessary to allow the ECC -Rater time to reply to the 
suspension without allowing the Rater to obstruct the process. This addition is 
necessary to prevent an ECC -Rater from undermining the ECC Program reputation. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)7Ciii  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Rater from 
submitting further field verifications and diagnostic tests to the ECC -Provider data 
registry once the suspension is in place.  
Necessity:  This addition is necessary to prevent an ECC -Rater from undermining the 
integrity of the ECC program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)7D  
Specific Purpose:  The purpose of this addition is to remove an ECC -Rater that will not 
comply with the progressive discipline process. If an ECC -Rater fails to comply with the 
terms of suspension or receives a new notice of violation while suspended, or pending a 
suspension , the ECC -Provider shall issue a notice of decertification to the ECC -Rater 
and any ECC -Rater Company the ECC -Rater tests for.  
Necessity:  This addition is necessary to prevent an ECC -Rater from undermining the 
integrity of the ECC program. A reputable ECC Program is necessary to encourage  
 widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(d)7Di  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater with a 
notice of decertification, explaining why they were decertified.  
Necessity:  This addition is necessary to allow the ECC -Rater the ability to respond to 
the notice prior to being decertified. This addition is necessary to prevent an ECC -Rater 
from undermining the integrity of the ECC program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)7Dii  
Specific Purpose:  The purpose of this addition is to provide a time frame for the ECC -
Rater to respond to the notice of decertification.  
Necessity:  This addition is necessary to allow the ECC -Rater time to reply to the 
decertification without allowing the Rater to obstruct the process. This addition is 
necessary to prevent an ECC -Rater from undermining the integrity of the ECC program. 
A reputable ECC Program is necessary to encourage widespread program adoption 
and accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(d)8  
Specific Purpose:  The purpose of this addition is to provide for a fair and balanced 
approach to progressive discipline for ECC -Rater Companies. The addition requires the 
ECC -Provider to issue a notice of violation to the ECC -Rater Company upon discovery 
of a violation. A severe violation may result in immediate suspension or decertification. 
The ECC -Provider and ECC -Rater Company may extend the time for written responses. 
Finally, at any time the Executive Director may direct the ECC -Provider to  investigate an 
ECC Rater company or discipline an ECC -Rater Company.  
Necessity:  This addition is necessary to allow the ECC -Provider to discipline bad 
behavior from ECC -Rater Companies while allowing ECC -Rater Companies recourse to 
address the findings of the ECC -Provider. Progressive ECC -Rater  Company  discipline 
allows the ECC Program to identify and  discourage inaccurate ECC ratings  so that 
building energy efficiency standard compliance is achieved , and wasteful energy 
consumption is avoided, as directed by PRC 25402.     
  
Section:  10-103.3(d)8A   
 Specific Purpose:  The purpose of this addition is to provide the ECC -Rater Company 
reasonable notification of the suspected violation. Upon discovery of a violation the 
addition requires the ECC -Provider to issue a notice of violation to the ECC -Rater 
Company and any affected homeowners.  
Necessity:  This addition is necessary to prevent the unwarranted escalation of 
penalties by the ECC -Provider. The homeowner typically is victimized by the ECC -Rater 
that falsified the data entries into the ECC -Provider data registry and is just as typically 
not notif ied of any findings by the ECC -Provider. This addition allows the homeowner to 
take action against an ECC -Rater as they see fit.  Progressive ECC -Rater  Company  
discipline allows the ECC Program to identify and  discourage inaccurate ECC ratings  so 
that building energy efficiency standard compliance is achieved , and wasteful energy 
consumption is avoided, as directed by PRC 25402.     
  
Section:  10-103.3(d)8Ai  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
mandate further training for the violating ECC -Rater Company or another corrective 
action related to the violation within a specified timeframe.  
Necessity:  This addition is necessary to ensure that the corrective action , or additional 
training is appropriate and relevant for the violation, so that the ECC -Rater Company 
may learn from their mistake. Additional training or other corrective action makes 
inaccurate test results less likely. Progressive ECC -Rater Company discipline allows the 
ECC Program to identify and discourage inaccurate ECC ratings so that building energy 
efficiency standard compliance is achieved, an d wasteful energy consumption is 
avoided as directed by PRC 25402.     
  
Section:  10-103.3(d)8Aii  
Specific Purpose:  The purpose of this addition is to ensure that the homeowner is 
made whole by the ECC -Rater or ECC -Rater Company and not the ECC -Provider by 
requiring the ECC -Rater Company to cover the costs of the original field testing and any 
necessary retesting due to the violation . 
Necessity:  This addition is necessary to prevent the ECC -Provider from being 
unreasonably burdened by the actions of its certified ECC -Raters or Rater Companies  
while discouraging ECC -Raters and ECC -Rater Companies from submitting faulty test 
results. Progressive ECC -Rater Company discipline allows the ECC Program to identify 
and discourage inaccurate ECC ratings so that building energy efficiency standard 
compliance is achieved , and wasteful energy consumption is avoided, as directed by 
PRC 25402.     
  
Section:  10-103.3(d)8Aiii  
Specific Purpose:  The purpose of this addition is to specify what elements must be 
contained in the notice of violation to the ECC -Rater Company.   
 Necessity:  This addition is necessary to ensure that the ECC -Rater Company can 
respond fully within the time allotted. Progressive ECC -Rater  Company  discipline allows 
the ECC Program to identify and  discourage inaccurate ECC ratings  so that building 
energy efficiency standard compliance is achieved,  and wasteful energy consumption is 
avoided, as directed by PRC 25402.     
  
Section:  10-103.3(d)8Aiv  
Specific Purpose:  The purpose of this addition is to describe the time limit that the 
ECC -Rater Company has to respond to the notice of violation issued by the ECC -
Provider.  
Necessity:  This is necessary to allow the ECC -Rater Company to respond without 
allowing the Rater Company to hold up the proceeding. Progressive ECC -Rater  
Company  discipline allows the ECC Program to identify and  discourage inaccurate ECC 
ratings  so that building energy efficiency standard compliance is achieved, an d wasteful 
energy consumption is avoided, as directed by PRC 25402.     
  
Section:  10-103.3(d)8B  
Specific Purpose:  The purpose of this addition is to establish a second step in the 
progressive disciplinary process for ECC -Rater Companies tha t fail to comply with the 
notice of violation within the time allotted or receive a second notice of violation within a 
three -month period. The ECC -Provider will then issue a notice of probation to the ECC -
Rater company.  
Necessity:  This addition is necessary to address ECC -Raters Companies that do not 
respond (at all) to the notice of violation or have numerous violations.  The progressive 
discipline is needed to incentivize the violating ECC -Rater Company into complying with 
sanctions placed upon them. Progressive ECC -Rater Company discipline allows the 
ECC Program to identify and discourage inaccurate ECC ratings so th at building energy 
efficiency standard compliance is achieved, and wasteful energy consumption is 
avoided,  as directed by PRC 25402.     
  
Section:  10-103.3(d)8Bi  
Specific Purpose:  The purpose of this addition is to provide a notice to the ECC -Rater 
Company of probation, including the basis for probation, the duration of probation, and 
all corrective action the ECC -Rater Company must complete during probation.  
Necessity:  This addition is necessary to allow the ECC -Rater Company to respond to 
its probational status,  has a full understanding of what was done incorrectly, and may 
take steps to address the disciplinary action. Progressive ECC -Rater Company 
discipline allows the ECC Program to identify and discourage inaccurate ECC ratings so 
that building energy efficiency standard compliance is achieved, and wasteful energy 
consumption is avoided, as directed by PRC 25402.     
   
 Section:  10-103.3(d)8Bii  
Specific Purpose:  The purpose of this addition is to describe the time limit that the 
ECC -Rater Company has to respond to the notice of probation issued by the ECC -
Provider.  
Necessity:  This is necessary to allow the ECC -Rater Company to respond without 
allowing the Rater Company to hold up the proceeding. Progressive ECC -Rater  
Company  discipline allows the ECC Program to identify and  discourage inaccurate ECC 
ratings  so that building energy efficiency standard compliance is achieved, an d wasteful 
energy consumption is avoided, as directed by PRC 25402.     
  
Section:  10-103.3(d)8C  
Specific Purpose:  The purpose of this addition is to address an ECC -Rater Company 
that fails to fully comply with the terms of probation or receives a new notice of violation 
while on probation. The ECC -Provider shall issue a notice of suspension to the ECC -
Rater Company if  this occurs.  
Necessity:  This addition is necessary to prevent an ECC -Rater Company from 
undermining the ECC program reputation. This addition is necessary to prevent an 
ECC -Rater  Company  from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)8Ci  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater Company 
with a notice of suspension  which describes the basis for suspension, duration, and 
corrective actions the ECC -Rater must complete during the suspension.  
Necessity:  This addition is necessary to allow the ECC -Rater Company the opportunity 
to address the notice of suspension.  
  
Section:  10-103.3(d)8Cii  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Rater Company 
from submitting further field verifications and diagnostic tests to the ECC -Provider data 
registry.  
Necessity:  This addition is necessary to prevent an ECC -Rater Company from 
undermining the integrity of the ECC program. This addition is necessary to prevent an 
ECC -Rater  Company  from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
   
 Section:  10-103.3(d)8Ciii  
Specific Purpose:  The purpose of this addition is to provide a time frame for the ECC -
Rater Company to respond to the notice of suspension.  
Necessity:  This addition is necessary to allow the ECC -Rater Company time to reply to 
the suspension without allowing the Rater Company to obstruct the process.  
  
Section:  10-103.3(d)8D  
Specific Purpose:  
The purpose of this addition is to remove an ECC -Rater Company that will not comply 
with the progressive discipline process. If an ECC -Rater Company fails to comply with the 
terms of suspension, receives a new notice of violation while suspended, or has a suspension 
pending, the ECC -Provider shall issue a notice of decertification to the ECC -Rater Company.  
Necessity:  This addition is necessary to prevent an ECC -Rater Company from 
undermining the integrity of the ECC program. This addition is necessary to prevent an 
ECC -Rater  Company  from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)8Di  
Specific Purpose:  The purpose of this addition is to provide the ECC -Rater Company 
with a notice if decertification.  
Necessity:  This addition is necessary to allow the ECC -Rater Company the ability to 
respond to the notice prior to being decertified.  
  
Section:  10-103.3(d)8Dii  
Specific Purpose:  The purpose of this addition is to provide a time frame for the ECC -
Rater Company to respond to the notice of decertification.  
Necessity:  This addition is necessary to allow the ECC -Rater Company time to reply to 
the decertification without allowing the Rater Company to obstruct the process.  
  
Section:  10-103.3(d)9  
Specific Purpose:  The purpose of this addition is to identify what data an ECC -
Provider must record.  
Necessity:  This addition is necessary in addition to the requirements in JA7 to ensure 
that all field verifications and diagnostic tests can be explained and verified. Data 
recording  creates a clear record of ECC  Ratings so that building energy efficiency  
 standards are properly tracked and maintained. An accurate record incentivizes code 
compliance , thereby reducing wasteful energy consumption , as directed by PRC 25402.  
  
Section:  10-103.3(d)9A  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to record 
field verification and diagnostic testing data collected by its certified ECC -Raters.  
Necessity:  This addition is necessary in addition to the requirements in JA7 to ensure 
that all field verifications and diagnostic tests can be explained and verified. Data 
recording creates a clear record of ECC Ratings so that building energy efficiency 
standards are properly tracked and maintained. An accurate record incentivizes code 
compliance, thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Ai  
Specific Purpose:  The purpose of this addition is to include the normal required data 
recording as provided in Reference Appendix JA7. This includes the Certificate(s) of 
Compliance, Certificate(s) of installation, and Certificate(s) of Verification in both their 
data entry  format as well as their PDF format.  
Necessity:  This addition is necessary to incorporate and not duplicate the recording 
requirements of JA7. These compliance documents are generally required to be 
recorded by the ECC -Provider in JA7. By referencing these documents, the ECC -
Provider is required to foll ow the data registry requirements in JA7 without having to 
duplicate those requirements here. An accurate record incentivizes code compliance, 
thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Aii  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information not required in JA7. The data registry must be able to identi fy the efficiency 
measure being tested by the ECC -Rater.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. There can be many similar efficiency measures on one project that 
all need to be verified by the ECC -Rater. Identifying them individually is critical. An 
accurate record incentivizes code compliance, thereby reducing wasteful energy 
consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Aiii  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. Homes inspected as part of a 
sample group are not recorded according to the requirements in JA7  but must be 
recorded by the data registry.   
 Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. Home s inspected as part of a sample group might not be the 
actual tested home. As a result, the only way for a homeowner to know if their home 
was inspected is to have a report from the ECC -Provider identifying their sample group 
and tested home. This informati on is also important to the CEC  for quality assurance 
purposes. An accurate record incentivizes code compliance, thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Aiv  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. Initial testing (testing the first unit) is 
performed ECC -Rater to instruct the subcontractor on proper installations.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. Initial testing is a requirement in the Energy Code and is a 
necessary tool to help ensure that subcontractors are properly trained on code 
compliant installat ions. It is necessary to record the initial testing home or unit to allow 
the CEC  to verify that the developer is in compliance with the Energy Code 
requirements. An accurate record incentivizes code compliance, thereby reducing 
wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Av  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. Only one home in a sample group 
(of seven) is tested by the ECC -Rater. The tested home must be recorded for reference 
and quality ass urance purposes.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. Sample groups allow an ECC -Rater to curtail the number of field 
verifications and diagnostic testing that must be performed on a development. One in 
seven home s is tested for each sample group. The ECC -Provider data registry must be 
able to record which home was tested for each energy efficiency measure installed. An 
accurate record incentivizes code compliance, thereby reducing wasteful energy 
consum ption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Avi  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. If a tested home in a sample group 
fails, a second home can be tested to potential pass the rest of the sample group. This 
is referre d to as retesting.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. Just as a tested home must be identified in a Sample Group, if a 
home is retested, it must also be identified. This allows the homeowner to know of the  
 initial issues (failed test) and allows the ECC -Provider as well as the CEC  to potentially 
evaluate the retested home to verify code compliance.  An accurate record incentivizes 
code compliance, thereby reducing wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)9Avii  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. Failed testing in a sample group 
can result in corrective action being taken for the tested home or the entire sample 
group.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. The home that produced a failed test can be corrected and tested 
again, as can the entire sample group. This information is important to include in the 
ECC -Provider data registry not only for the homeowner but also to indicate whether 
quality assurance audits are warranted. An accurate record incentivizes code 
compliance, thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Aviii  
Specific Purpose:  The purpose of this addition is to require the recording of additional 
information regarding sampling not required in JA7. After occupancy, a homeowner can 
decline verification testing for a home that failed.  
Necessity:  This addition is necessary to ensure a consistent data recording regardless 
of the ECC -Provider. When a homeowner occupies the home and later discovers that 
the home was part of a failed sample group, the homeowner can decline further testing 
and correctiv e action. If so, the ECC -Provider data registry must be able to identify this 
decision by the homeowner. An accurate record incentivizes code compliance, thereby 
reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9B  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to record 
quality assurance actions taken.  
Necessity:  This addition is necessary to create an enforceable record and allow the 
CEC  to oversee the ECC -Provider quality assurance actions. An accurate record 
incentivizes code compliance, thereby reducing wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)9Bi  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to record 
all quality assurance and disciplinary actions taken against each ECC -Rater and ECC -
Rater Company.   
 Necessity:  This addition is necessary to ensure that this data is recorded consistently 
regardless of the ECC -Provider and allow the CEC  to oversee the ECC -Providers’ 
actions. An accurate record incentivizes code compliance, thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Bii  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
maintain a database (separate from the data registry system) to record the certification 
status, disciplinary actions, and quality assurance actions of all ECC -Raters and ECC -
Rater Companies.  
Necessity:  This addition is necessary to ensure that the quality assurance database 
does not interfere with the data registry. An accurate record incentivizes code 
compliance, thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biii  
Specific Purpose:  The purpose of this addition is to identify the quality assurance data 
that must be recorded by the ECC -Provider.  
Necessity:  This addition is necessary to ensure that the quality assurance data 
recorded is similar regardless of the ECC -Provider. An accurate record incentivizes 
code compliance, thereby reducing wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)9Biiia  
Specific Purpose:  The purpose of this addition is to identify quality assurance data to 
the ECC -Rater or ECC -Rater Company through common contact information such as 
name and address.  
Necessity:  This addition is necessary to verify the quality assurance status of each 
ECC -Rater and ECC -Rater Company. An accurate record incentivizes code 
compliance, thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiib  
Specific Purpose:  The purpose of this addition is to limit the status of certification of 
ECC -Raters and ECC -Rater Companies to specific identifiers for use in posting to the 
public by the ECC -Provider.  
Necessity:  This addition is necessary to maintain a consistent certification status 
regardless of the ECC -Provider. An accurate record incentivizes code compliance, 
thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiic   
 Specific Purpose:  The purpose of this addition is to provide a simple summary of the 
required audits that resulted in a pass for each ECC -Rater and ECC -Rater Company.  
Necessity:  This addition is necessary to simplify the quality assurance database so as 
not to duplicate recordings by the ECC -Provider. An accurate record incentivizes code 
compliance, thereby reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiic(i)  
Specific Purpose:  The purpose of this addition is to provide for the recording of 
specific audits that resulted in a pass.  
Necessity:  This addition is necessary to ensure consistency regardless of the ECC -
Provider. An accurate record incentivizes code compliance, thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiic(ii)  
Specific Purpose:  The purpose of this addition is to provide for the recording of 
specific audits that resulted in a pass.  
Necessity:  This addition is necessary to ensure consistency regardless of the ECC -
Provider. An accurate record incentivizes code compliance, thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiic(iii)  
Specific Purpose:  The purpose of this addition is to provide for the recording of 
specific audits that resulted in a pass.  
Necessity:  This addition is necessary to ensure consistency regardless of the ECC -
Provider. An accurate record incentivizes code compliance, thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)9Biiid  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to 
maintain detailed quality assurance records for a minimum of 5 years that are not 
required to be reported to the CEC . 
Necessity:  This addition is necessary to allow the ECC -Provider the flexibility to store 
documentation related to a quality assurance action without specific format or 
consistency requirements. An accurate record incentivizes code compliance, thereby 
reducing wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)10   
 Specific Purpose:  The purpose of this addition is to describe the data retention 
requirement for ECC -Providers.  
Necessity:  This addition is necessary to ensure that the CEC  has full access to the 
data retained by the ECC -Providers. Proper record keeping is necessary to ensure 
oversight over ECC -Provider actions. An accurate long-term record incentivizes code 
compliance  through increased accountability , thereby reducing wasteful energy 
consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)10A  
Specific Purpose:  The purpose of this addition is to require data retention for no less 
than 10 years in the format it was collected or received.  
Necessity:  This addition is necessary to allow the ECC -Providers to purge its data 
registry and other databases of outdated information after it is unlikely,  they will be 
needed for verification or other purposes. An accurate long -term record incentivizes 
code compliance through increased accountability, thereby reducing wasteful energy 
consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)10B  
Specific Purpose:  The purpose of this addition is to require the EEC -Provider to 
maintain a data retention system that can be fully accessed by the CEC . 
Necessity:  This addition is necessary to allow the CEC  to oversee the ECC -Provider, 
ECC -Raters, and ECC -Rater Companies as well as effectively pursue complaint 
investigations. An accurate accessible long -term record incentivizes code compliance 
through increased accountability, thereby reducing wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)10C  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Provider from 
obstructing the CEC ’s access to the ECC -Provider data registry.  
Necessity:  This addition is necessary to protect the CEC  oversight authority of the 
ECC -Providers. The Commission’s attempts at data -driven oversight will be hampered 
without access to accurate records. An accurate accessible long -term record 
incentivizes code compliance through increased accountability, thereby reducing 
wasteful energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)10D  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
maintain digital copies of all files that can be indexed and searched unless the 
Commission authorizes the ECC -Provider to operate without this functionality.   
 Necessity:  This addition is necessary because the ECC -Providers originally stored this 
data in hardcopy format only. An accurate accessible long -term record incentivizes code 
compliance through increased accountability, thereby reducing wasteful energy 
consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)10E  
Specific Purpose:  The purpose of this addition is to prevent the ECC -Provider from 
being required to reformate or alter data collected prior to January 1, 2026.  
Necessity:  This addition is necessary to prevent data retention requirements from 
causing unforeseen and unnecessary burdens on the ECC -Provider.  
  
Section:  10-103.3(d)11  
Specific Purpose:  The purpose of this addition is to outline the ECC -Provider reporting 
requirements to the CEC . 
Necessity:  This addition is necessary to ensure consistent reporting from all ECC -
Providers. An accurate accessible long -term record incentivizes code compliance 
through increased accountability, thereby reducing wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)11A  
Specific Purpose:  The purpose of this addition is to maintain a basic representative 
reporting sample from the ECC -Provider. This can be accomplished by a 10% random 
sample of buildings field verified and diagnostically tested by ECC -Raters certified by 
the respective ECC -Provider each year.  
Necessity:  This addition is necessary to maintain this level of reporting until such time 
as the Commission Compliance Document Repository is approved by the CEC . An 
accurate accessible long -term record incentivizes code compliance through increased 
accountability, thereby reducing wasteful energy consumption, as directed by PRC 
25402.  
  
Section:  10-103.3(d)11B  
Specific Purpose:  The purpose of this addition is to re -establish the annual reporting of 
field verification and diagnostic testing requirements for ECC -Providers beginning 
January 1, 2027.  
Necessity:  This addition is necessary to allow the ECC -Provider ample time to design 
an annual report system for its data registry. An accurate accessible long -term record 
incentivizes code compliance through increased accountability, thereby reducing 
wasteful energy consumption, as directed by PRC 25402.  
   
 Section:  10-103.3(d)11C  
Specific Purpose:  The purpose of this addition is to require the reporting data in a 
useful format for the CEC , by organizing the data by climate zone.  
Necessity:  This addition is necessary to allow the CEC  to make use of this data in a 
timely manner. An accurate accessible long -term record incentivizes code compliance 
through increased accountability, thereby reducing wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)11D  
Specific Purpose:  The purpose of this addition is to supersede 10 -103.310A - C once 
the CEC  has approved the Commission Compliance Document Repository. ECC -
Providers will have to transmit compliance to the CEC at least once per calendar 
quarter.  
Necessity:  This addition is necessary to avoid over burdening the ECC -Providers with 
unnecessary reporting requirements. Once a quarter is sufficient to ensure the 
Commission can provide adequate oversight while not being too burdensome on an 
ECC -Provider. An accurate accessible long -term record incentivizes code compliance 
through increased accountability, thereby reducing wasteful energy consumption, as 
directed by PRC 25402.  
  
Section:  10-103.3(d)11E  
Specific Purpose:  The purpose of this addition is to establish the quarterly reporting 
requirements for the ECC -Provider quality assurance activities.  
Necessity:  This addition is necessary to ensure that the quality assurance activities of 
the ECC -Providers are on track throughout the year. Irregular quality assurance 
activities flagged in quarterly reports may alert the Commission to potential wrongdoing. 
Correcti ng this wrongdoing is integral to a functioning ECC -program. A regular quality 
assurance report increases  accountability throughout the ECC Program . Increased 
accountability likely will encourage more accurate ECC Ratings and building energy 
standard compliance , lowering wasteful energy consumption, as directed by PRC 
25402.   
  
Section:  10-103.3(d)11Ei  
Specific Purpose:  The purpose of this addition is to report projects that failed their 
quality assurance testing within the calendar quarter with sufficient specificity. The 
report must be submitted within 60 days after the end of the calendar quarter and 
include identifyin g information, project permit codes, and code violations for each failed 
audit.  
Necessity:  This addition is necessary to keep the CEC  advised regarding failed quality 
assurance audits within a reasonable time after the audits’ findings. A regular quality  
 assurance report increases accountability throughout the ECC Program. Increased 
accountability likely will encourage more accurate ECC Ratings and building energy 
standard compliance, lowering wasteful energy consumption, as directed by PRC 
25402.   
  
Section:  10-103.3(d)11Eii  
Specific Purpose:  The purpose of this addition is to require the quarterly quality 
assurance report to be submitted to a publicly accessible CEC  docket.  
Necessity:  This addition is necessary to allow the public to understand the quality 
assurance activities of the ECC -Provider. A regular quality assurance report increases 
accountability throughout the ECC Program. Increased accountability likely will 
encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, as directed by P RC 25402.   
  
Section:  10-103.3(d)11F  
Specific Purpose:  This purpose of this addition is to establish the annual quality 
assurance reporting from the ECC -Providers.  
Necessity:  This addition is necessary to enable the CEC  to oversee the quality 
assurance activities of the ECC -Providers. A regular quality assurance report increases 
accountability throughout the ECC Program. Increased accountability likely will 
encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, as directed by P RC 25402.   
  
Section:  10-103.3(d)11Fi  
Specific Purpose:  The purpose of this addition is to establish the reporting time frame 
of the annual quality assurance ECC -Provider report, which is submission to the 
Commission no later than the end of February of the following year.  
Necessity:  This addition is necessary to allow the CEC  to confirm ECC -Provider 
compliance with the quality assurance requirements. A regular quality assurance report 
increases accountability throughout the ECC Program. Increased accountability likely 
will encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, as directed by P RC 25402.   
  
Section:  10-103.3(d)11Fii  
Specific Purpose:  The purpose of this addition is to establish the scope of the annual 
quality assurance report which includes all specified records within the annual 
timeframe.  
Necessity:  This addition is necessary to limit the report to only the annual calendar 
year, this prevents outdated information from cluttering and potentially shrouding 
relevant data points. A regular quality assurance report increases accountability  
 throughout the ECC Program. Increased accountability likely will encourage more 
accurate ECC Ratings and building energy standard compliance, lowering wasteful 
energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)11Fiii  
Specific Purpose:  The purpose of this addition is to describe the contents of the 
annual quality assurance report. This is done by requiring the annual report to 
summarize all quality assurance actions taken for each ECC -Rater by the ECC -Provider 
during the preceding year.  
Necessity:  This addition is necessary to allow the ECC -Provider the ability to 
summarize and explain in detail all quality assurance activities. This allows the ECC -
Provider to show the quality assurance actions taken in tabular form or another  simple 
summary. It also allows the CEC  to effectively review the overall actions taken by the 
ECC -Provider. A regular quality assurance report increases accountability throughout 
the ECC Program. Increased accountability likely will encourage more accurate ECC 
Rating s and building energy standard compliance, lowering wasteful energy 
consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)11Fiv  
Specific Purpose:  The purpose of this addition is to allow the CEC  to request detailed 
quality assurance action records as needed from the ECC -Provider.  
Necessity:  This addition is necessary to allow the CEC  to investigate specific quality 
assurance actions without requiring detailed reporting on all actions. A regular quality 
assurance report increases accountability throughout the ECC Program. Increased 
accountability likely will encourage more accurate ECC Ratings and building energy 
standard compliance, lowering wasteful energy consumption, as directed by P RC 
25402.   
  
Section:  10-103.3(d)11G  
Specific Purpose:  The purpose of this addition is to require annual reporting from 
ECC -Rater Companies through the ECC -Providers.  
Necessity:  This addition is necessary to allow the CEC  to gain a better understanding 
of the activities and effects that the ECC program has on the construction industry. An 
annual report increases accountability throughout the ECC Program. Increased 
accountability likely will encourage more accurate ECC Ratings and building energy 
standard compliance, lowering wasteful energy consumption, as directed by PRC 
25402.   
  
Section:  10-103.3(d)11Gi   
 Specific Purpose:  The purpose of this addition is to require annual reporting of the 
ECC -Rater Company activities from the ECC -Provider beginning in June 2027.  
Necessity:  This addition is necessary to allow the ECC -Rater Companies and ECC -
Providers ample time to provide a systematic means of compliance for this reporting 
requirement. An annual report increases accountability throughout the ECC Program. 
Increased accountability likely will encourage more accurate ECC Ratings and building 
energy standard compliance, lowering wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)11Gii  
Specific Purpose:  The purpose of this addition is to require a summary of the 
progressive discipline actions taken against either the ECC -Rater Companies or the 
ECC -Raters under its employment.  
Necessity:  This addition is necessary to allow the CEC  to verify that ECC -Rater 
Companies are fulfilling their obligations regarding progressive discipline. This addition 
references the progressive discipline actions that the ECC -Rater Companies are 
required to take when an ECC -Rater is disciplined (Sections 10-103.3(f)2H and 10 -
103.3(e)2G). The annual summary is intended to allow the ECC -Provider and CEC  to 
evaluate the actions taken by the ECC -Rater Company in compliance with these 
requirements. An annual  report increases accountability throughout the ECC Program. 
Increased accountability likely will encourage more accurate ECC Ratings and building 
energy standard compliance, lowering wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)11Giii  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
ensure that the ECC -Rater Company annual reports are complete.  
Necessity:  This is necessary to ensure that the CEC  can verify ECC -Rater Company 
activities. An annual report increases accountability throughout the ECC Program. 
Increased accountability likely will encourage more accurate ECC Ratings and building 
energy standard compliance, lowering wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)11Giiia  
Specific Purpose:  The purpose of this addition is to include the compliance status of 
the ECC -Rater Company principal licensure as well as the license status of the ECC -
Rater if they are filing as independent.  
Necessity:  This is necessary to ensure that the CEC  can verify ECC -Rater Company 
and independent ECC -Rater activities. An annual report increases accountability 
throughout the ECC Program. Increased accountability likely will encourage more  
 accurate ECC Ratings and building energy standard compliance, lowering wasteful 
energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)11Giiib  
Specific Purpose:  The purpose of this addition is to include the certification status of all 
ECC -Raters employed by each ECC -Rater Company.  
Necessity:  This is necessary to ensure that the CEC  can verify ECC -Rater Company 
activities. An annual report increases accountability throughout the ECC Program. 
Increased accountability likely will encourage more accurate ECC Ratings and building 
energy standard compliance, lowering wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)11Giiic  
Specific Purpose:  The purpose of this addition is to include a comparison of the 
number and type of certificates of verification registered by each ECC -Rater Company 
employed ECC -Rater when compared to the ECC -Provider data registry.  
Necessity:  This is necessary to ensure that the CEC  can verify ECC -Rater Company 
activities. An annual report increases accountability throughout the ECC Program. 
Increased accountability likely will encourage more accurate ECC Ratings and building 
energy standard compliance, lowering wasteful energy consumption, as directed by 
PRC 25402.   
  
Section:  10-103.3(d)11Giiid  
Specific Purpose:  The purpose of this addition is to include the cost of services 
provided be each ECC -Rater Company or independent ECC -Rater. The costs of 
services may not be identifiable to the Company or Rater but must be separated among 
climate zone and local jurisdicti on. 
Necessity:  This addition is necessary to help the CEC  to ascertain the financial impact 
of field verification and diagnostic testing on the construction industry. An annual report 
increases accountability throughout the ECC Program. Increased accountability likely 
will encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)11H  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to 
immediately notify the CEC  of any ECC -Rater or ECC -Rater Company decertification. If 
this occurs the Commission will instruct all ECC -Providers to suspend the ECC -Rater or 
ECC Rater Company’s access to data registries.  
Necessity:  This addition is necessary to allow the CEC  to prepare for any possible 
appeal from the ECC -Rater or ECC -Rater Company as well as to allow the CEC  to  
 direct other ECC -Providers to decertify the ECC -Rater or ECC -Rater Company. An up 
to date and reputable ECC Program will increase the likelihood accurate building energy 
standard compliance is enforced among reputable  ECC participants, so that  wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)12  
Specific Purpose:  The purpose of this addition is to require ECC -Providers to respond 
to valid data requests from the CEC . 
Necessity:  This addition is necessary to put a clear process in place rather than rely on 
an ad hoc process. A clear well understood process for data requests  increases 
accountability throughout the ECC Program. Increased accountability likely will 
encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)12A  
Specific Purpose:  The purpose of this addition is to give the CEC  the explicit authority 
to request access to the ECC -Provider data registry.  
Necessity:  This addition is necessary to establish the scope of possible data requests 
from the CEC . A clear well understood process for data requests increases 
accountability throughout the ECC Program. Increased accountability likely will 
encourage more accurate ECC Ratings and building energy standard compliance, 
lowering wasteful energy consumption, a s directed by PRC 25402.   
  
Section:  10-103.3(d)12B  
Specific Purpose:  The purpose of this addition is to establish a timeline for the ECC -
Provider to respond to a data request from the CEC  as specified by the Executive 
Director .  
Necessity:  This addition is necessary to allow the ECC -Provider a reasonable amount 
of time to respond to CEC  data requests  as provided by the Executive Director , while 
still requiring prompt responses from ECC -Providers. A clear well understood process 
for data requests increases accountability throughout the ECC Program. Increased 
accountability likely will encourage more accurate ECC Ratings and building energy 
standard compliance, lowering wasteful energy consumption, a s directed by PRC 
25402.   
  
Section:  10-103.3(d)12C  
Specific Purpose:  The purpose of this addition is to require ECC -Provider to ensure 
that its data registry and quality assurance database are capable of complying with an 
CEC  data request.   
 Necessity:  This addition is necessary to ensure that ECC -Providers do not intentionally 
make their data registry inaccessible to the CEC . Assigning sole responsibility of 
maintaining their data registries ensures they aren’t able to sidestep responsibility by 
reassigning responsibility. A clear well understood process for data requests increases 
accountability throughout the ECC Program. Increased accountability likely will 
encourage more accurate ECC Ratings and building energy standard compliance, 
lowerin g wasteful energy consumption, as directed by PRC 25402.   
  
Section:  10-103.3(d)13  
Specific Purpose:  The purpose of this addition is to require that the ECC -Providers 
comply with the data registry requirements included in the Building Efficiency standards, 
JA7, and Section 10 -109. 
Necessity:  This addition is necessary to ensure that the ECC -Provider operates a data 
registry. An accurate accessible long -term record incentivizes code compliance through 
increased accountability . Increased accountability likely will encourage more accurate 
ECC Ratings and building energy standard compliance , thereby reducing wasteful 
energy consumption, as directed by PRC 25402.  
  
Section:  10-103.3(d)14  
Specific Purpose:  The purpose of this addition is to allow for the possibility that the 
CEC  cannot approve any ECC -Providers for a code cycle. If this occurs, the 
Commission may act as the ECC -Provider or suspend all or a portion of the FV&DT 
program.  
Necessity:  This addition is necessary to address a long-standing  issue of compliance 
with the Energy Code in the event that there are no approved ECC -Providers. This 
provision allows the CEC to become the de facto  Provider  of last resort to continue all or 
part of the ECC Program so that wasteful  energy consumption is reduced as directed by 
PRC 25402, even in the event there are no Providers.   
  
Section:  10-103.3(d)15  
Specific Purpose:  The purpose of this addition is to establish the ECC -Provider 
progressive discipline process for the CEC  to use. Violations that trigger the disciplinary 
process including failure to comply with quality assurance requirements, failure to 
investigate or discipline ECC -Raters and ECC -Rater, failure to allow the Commission 
full access to the ECC -Provider data r egistry, refusal to comply with Commission data 
requests, failure to cooperate in a Commission complaint investigation, and failure to 
otherwise comply with any applicable law or regulation. In the event of a severe 
violation, the Executive Director may proceed immediately to issue a notice of 
suspension for the first severe violation and to issue a notice of decertification for a 
second severe violation.    
 Necessity:  This addition is necessary to provide a clear discipline process that does not 
only rely on rescinding the CEC  ECC -Provider approval. For varying levels of 
misconduct, varying levels of discipline must be available. Otherwise, small infractions 
may go undisciplined due to a mismatch in the violation and remedy.  Progressive ECC -
Provider discipline all ows the ECC Program to identify and incentivize improved rating 
accuracy so that building energy efficiency standard compliance is achieved , and 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)15A  
Specific Purpose:  The purpose of this addition is to provide a reasonable notice of 
violation to the ECC -Provider, allowing it reasonable time to respond. Upon 
identification of one or more violations of these regulations by an ECC -Provider, the 
Executive Director shall iss ue a notice of violation to the ECC -Provider’s designated 
contact and publicly post the notice. The Executive Director shall require the ECC -
Provider to take corrective action related to the violations within a specified timeframe. 
The no tice of violation shall be in writing and include a description of the legal 
requirements and violations, any corrective action the ECC -Provider must take, and the 
timeframe for complying with all the notice of violation requirements  
Necessity:  This addition is necessary to give the ECC -Provider reasonable means to 
respond and explain the issue of the violation. Progressive ECC -Provider discipline 
allows the ECC Program to identify and incentivize improved rating accuracy so that 
building energy efficiency standard compliance is achieved, and wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)15B  
Specific Purpose:  The purpose of this addition is to progress to a higher level of 
discipline when an ECC -Provider is noncooperative. If an ECC -Provider fails to 
complete all corrective action prescribed by the Executive Director within the specified 
timeframe or receives a sec ond notice of violation within a three -month period, the 
Executive Director shall issue a notice of probation to the ECC -Provider’s designated 
contact.  
Necessity:  This addition is necessary to prevent the ECC -Provider from ignoring the 
violation and remedies. Progressive ECC -Provider discipline allows the ECC Program 
to identify and take steps to correct regulation violations. Correcting these violations 
increases accountability, increases  the reputation of the ECC Program, and increas es 
the accuracy of ECC -Ratings. These steps decrease wasteful energy con sumption as 
directed by PRC 25402.   
  
Section:  10-103.3(d)15C  
Specific Purpose:  The purpose of this addition is to progress to a higher level of 
discipline when an ECC -Provider is noncooperative. If an ECC -Provider fails to 
complete all corrective action or receives a new notice of violation while on probation,  
 the Executive Director shall issue a notice of suspension to the ECC -Provider’s 
designated contact.  
Necessity:  This addition is necessary to prevent the ECC -Provider from continuing 
business as usual while ignoring the violation and remedy.  Progressive ECC -Provider 
discipline allows the ECC Program to identify and take steps to correct regulation 
violations. Correcting these violations increases accountability, increases the reputation 
of the ECC Program, and increases the accuracy of ECC -Ratings. These steps 
decrease wasteful energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)15Ci  
Specific Purpose:  The purpose of this addition is to specify the timeline that the ECC -
Provider has to respond to the suspension.  
Necessity:  This addition is necessary to allow a reasonable amount of time for the 
ECC -Provider to explain its actions regarding the violation and remedy. Progressive 
ECC -Provider discipline allows the ECC Program to identify and take steps to correct 
regulation violations. Correcting these violations increases accountability, increases the 
reputation of the ECC Program, and increases the accuracy of ECC -Ratings. These 
steps decrease wasteful energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)15Cii  
Specific Purpose:  The purpose of this addition is to establish the length and condition 
of the ECC -Provider suspension.  
Necessity:  This addition is necessary to allow the CEC  to customize the suspension 
based in part on the original violation. Progressive ECC -Provider discipline allows the 
ECC Program to identify and take steps to correct regulation violations. Correcting 
these violations increases accountability, increases the reputation of the ECC Program, 
and increases the accuracy of ECC -Ratings. These steps decrease wasteful energy 
consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)15Ciii  
Specific Purpose:  The purpose of this addition is to allow the CEC  to modify the terms 
of the ECC -Provider suspension, while preserving the ECC -Provider’s ability to appeal 
the decision, if they fail to do so, the terms of the modification will apply.  
Necessity:  This addition is necessary to tailor the suspension terms based on any new 
information that the CEC  discovers is presented by the ECC -Provider. Progressive 
ECC -Provider discipline allows the ECC Program to identify and take steps to correct 
regulation violations. Correcting these violations increases accountability, increases the 
reputation of the ECC Program, and increases the accuracy of ECC -Ratings. These 
steps decrease wasteful energy consumption as directed by PRC 25402.  
   
 Section:  10-103.3(d)15Civ  
Specific Purpose:  The purpose of this addition is to make public ECC -Provider 
suspensions after 180 days.  
Necessity:  This addition is necessary to keep the public informed of an ECC -Provider 
suspension and its impacts on the construction industry. Progressive ECC -Provider 
discipline allows the ECC Program to identify and take steps to correct regulation 
violations. Correcting these violations increases accountability, increases the reputation 
of the ECC Program, and increases the accuracy of ECC -Ratings. These steps 
decrease wasteful energy consumption as directed by PRC 25402.  
  
Section:  10-103.3(d)15D  
Specific Purpose:  The purpose of this addition is to allow the CEC  to rescind its 
approval of an ECC -Provider.  
Necessity:  This addition is necessary as the final step in the progressive discipline 
process to prevent an ECC -Provider from negatively impacting the reputation of the 
ECC program. Progressive ECC -Provider discipline allows the ECC Program to identify 
and take steps to correct regulation violations. Correcting these violations increases 
accountability, increases the reputation of the ECC Program, and increases the 
accuracy of ECC -Ratings. These steps decrease wasteful energy consumption as 
directed by PRC 25402.  
  
Section:  10-103.3(d)15Di  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider time to 
respond to the CEC  rescinding its approval.  
Necessity:  This addition is necessary to give the ECC -Provider a final means of 
remedying its violations. Progressive ECC -Provider discipline allows the ECC Program 
to identify and take steps to correct regulation violations. Correcting these violations 
increases accountability, increases the reputation of the ECC Program, and increases 
the accuracy of ECC -Ratings. These steps decrease wasteful energy consumption as 
directed by PRC 25402.  
  
Section:  10-103.3(d)15E  
Specific Purpose:  The purpose of this addition is to prevent an ECC -Provider from 
reapplying to the CEC  after its approval has been rescinded. It may only reapply after 
completing the remediation process.  
Necessity:  This addition is necessary to prevent an ECC -Provider from gaming the 
progressive discipline process and wasting the CEC  resources. A clear and robust 
remediation process is necessary to maintain the reputation of the ECC Program . A 
reputable program encourages widespread program adoption and accurately  
 determines building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)15Ei  
Specific Purpose:  The purpose of this addition is to require a decertified ECC -Provider 
to submit an application for remediation to the CEC  for the CEC  to consider allowing the 
decertified ECC -Provider to reapply.  
Necessity:  This addition is necessary to give a reasonable pathway to remediation of 
the ECC -Provider. A clear and robust remediation process is necessary to maintain the 
reputation of the ECC Program. A reputable program encourages widespread program 
adoption and accurately determines building energy efficiency standard compliance so 
that wasteful energy c onsumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(d)15Eii  
Specific Purpose:  The purpose of this addition is to allow the CEC  to declare the 
decertified ECC -Provider as remediated and allow it to reapply.  
Necessity:  This addition is necessary to ensure that the remediated ECC -Provider can 
address its violations prior to reapplying to the CEC . A clear and robust remediation 
process is necessary to maintain the reputation of the ECC Program. A reputable 
program encourages widespread program adoption and accurately determines building 
energy efficiency standard compliance so that wasteful energy c onsumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(e)  
Specific Purpose:  The purpose of this addition is to describe the basic certification 
process for ECC -Raters and their responsibilities.  
Necessity:  This addition is necessary to ensure that the ECC -Rater certification 
process is consistent regardless of the ECC -Provider. Clearly delineated  certification 
process es and responsibilities are  necessary to ensure ECC -Raters understand what is 
required to participate in the ECC Program. The procedures encourage a widespread 
program adoption  which accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)1  
Specific Purpose:  The purpose of this addition is to describe the basic certification 
process for ECC -Raters.  
Necessity:  This addition is necessary to ensure that the ECC -Rater certification 
process is consistent regardless of the ECC -Provider. Clearly delineated certification 
processes are necessary to ensure ECC -Raters understand what is required to 
participate in the ECC Program. The procedures encourage a widespread program  
 adoption which accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)1A  
Specific Purpose:  The purpose of this addition is to require the ECC -Rater to apply to 
the ECC -Provider for certification.  
Necessity:  This addition is necessary to enforce the training and testing requirements 
for certification. Clearly delineated certification processes are necessary to ensure ECC -
Raters understand what is required to participate in the ECC Program. The procedures 
encourage a widespread program adoption which accurately determine building energy 
efficiency standa rd compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(e)1B  
Specific Purpose:  The purpose of this addition is to require the training for the ECC -
Rater to be completed.  
Necessity:  This addition is necessary to ensure that all required training is completed. 
Minimum qualifications are necessary to ensure ECC -Raters understand what is 
required to participate in the ECC Program. The training requirements  ensure ECC -
Raters  accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)1C  
Specific Purpose:  The purpose of this addition is to require an agreement signed by 
the ECC -Rater that includes the ECC -Rater statement of compliance with these 
requirements.  
Necessity:  This addition is necessary to ensure that the ECC -Rater can be held 
accountable for falsifying compliance documents. ECC -Rater Agreements ensure 
progressive discipline can be carried out. Progressive discipline assists in ensuring all 
requirements are carried out, which hel ps identify and incentivize improved rating 
accuracy so that building efficiency standard compliance is achieved , and the wasteful 
consumption of energy is reduced , as directed by PRC 25402.  
  
Section:  10-103.3(e)1D  
Specific Purpose:  The purpose of this addition is to prevent an ECC -Rater with an 
existing disciplinary action against them from moving to another ECC -Provider and 
receiving a certification from the alternate ECC -Provider.  
Necessity:  This addition is necessary to prevent ECC -Rater with outstanding 
disciplinary actions from transferring to another ECC -Provider, thereby avoiding 
disciplinary actions. This prevents an ECC -Rater from undermining the integrity of the  
 ECC Program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance  so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)1Di  
Specific Purpose:  The purpose of this addition is to require the ECC -Provider to verify 
that the ECC -Rater is in good standing regarding their existing certification status.  
Necessity:  This addition is necessary to encourage the ECC -Provider to make efforts 
to check the background of prospective ECC -Raters. This prevents an ECC -Rater from 
undermining the integrity of the ECC Program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy cons umption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(e)1Dii  
Specific Purpose:  The purpose of this addition is to allow ECC -Providers to submit a 
complaint to the CEC  if they suspect an ECC -Rater has an outstanding disciplinary 
action and yet has received new certification from a new ECC -Provider.  
Necessity:  This addition is necessary to allow the CEC  to enforce this requirement. The 
ECC -Provider will have limited leverage enforcing disciplinary action if the ECC -Rater is 
able to move to a new ECC -Provider. This prevents an ECC -Rater from undermining 
the integrity of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(e)2  
Specific Purpose:  The purpose of this addition is to specify ECC -Rater conduct.  
Necessity:  This addition is necessary to require a level of professional conduct of the 
ECC -Raters because they deal directly with the public. This prevents an ECC -Rater 
from undermining the integrity of the ECC Program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy cons umption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)2A  
Specific Purpose:  The purpose of this addition is to require ECC -Raters to perform the 
necessary field verification and diagnostic testing as required by the Energy Code.  
Necessity:  This addition is necessary to ensure that the ECC -Rater understands their 
role and all the standards they must comply with when carrying out a FV&DT. This  
 prevents an ECC -Rater from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumpti on is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)2B  
Specific Purpose:  The purpose of this addition is to restrict the ECC -Rater from 
falsifying the field verification and diagnostic tests they perform.  
Necessity:  This addition is necessary to ensure that the ECC -Rater accurately reports 
the results of their FV&DT. This prevents an ECC -Rater from undermining the integrity 
of the ECC Program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy cons umption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)2C  
Specific Purpose:  The purpose of this addition is to restrict ECC -Raters from accepting 
bribes.  
Necessity:  This addition is necessary to help ensure the reputation of the ECC 
program. This prevents an ECC -Rater from undermining the integrity of the ECC 
Program. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy consumption is reduce d, as directed by PRC 25402.  
  
Section:  10-103.3(e)2D  
Specific Purpose:  The purpose of this addition is to restrict the ECC -Rater’s 
relationships in compliance with the conflicts of interest regulations.  
Necessity:  This addition is necessary to help ensure the reputation of the ECC 
program. This prevents an ECC -Rater from undermining the integrity of the ECC 
Program. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful energy cons umption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)2E  
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater to use 
assistance if they are directly overseen.  
Necessity:  This addition is necessary to limit the use of non -certified individuals 
performing field verifications and diagnostic tests. This prevents an ECC -Rater from 
undermining the integrity of the ECC Program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy  
 efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(e)2F  
Specific Purpose:  The purpose of this addition is to restrict the ECC -Rater from 
falsifying the field verification and diagnostic tests they perform.  
Necessity:  This addition is necessary to ensure that the ECC -Rater accurately reports 
the results of their FV&DT.  This prevents an ECC -Rater from undermining the integrity 
of the ECC Program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy cons umption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)2G  
Specific Purpose:  The purpose of this addition is to allow ECC -Raters to be self -
employed.  
Necessity:  This addition is necessary to promote competition in the marketplace. This 
prevents an ECC -Rater from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
cons umption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(e)3  
Specific Purpose:  The purpose of this addition is to link compliance with the ECC -
Rater required conduct to the progressive discipline regulations.  
Necessity:  This addition is necessary to clearly identify these requirements as 
enforceable by the ECC -Provider. This prevents an ECC -Rater from undermining the 
integrity of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful energy cons umption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(e)4  
Specific Purpose:  The purpose of this addition is to provide an appeal process for the 
ECC -Rater.  
Necessity:  This addition is necessary to ensure that ECC -Raters are not subjected to 
unfair targeting by ECC -Providers. This addition allows an ECC -Rater to show they 
acted within the regulations of the ECC Program and may continue determining building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.   
   
Section:  10-103.3(e)4A  
Specific Purpose:  The purpose of this addition is to reinforce the appeal process set in 
the progressive disciplinary regulations.  
Necessity:  This addition is necessary to ensure that ECC -Raters are not subjected to 
unfair targeting by ECC -Providers. This addition allows an ECC -Rater to show they 
acted within the regulations of the ECC Program and may continue determining building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(e)4B  
Specific Purpose:  The purpose of this addition is to reinforce the appeal process set in 
the progressive disciplinary regulations.  
Necessity:  This addition is necessary to ensure that ECC -Raters are not subjected to 
unfair targeting by ECC -Providers. This addition allows an ECC -Rater to show they 
acted within the regulations of the ECC Program and may continue determining building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(f)  
Specific Purpose:  The purpose of this addition is to describe the basic certification 
process for ECC -Rater Companies.  
Necessity:  This addition is necessary to ensure that the ECC -Rater Company 
certification process is consistent regardless of the ECC -Provider. Clearly delineated 
certification processes and responsibilities are necessary to ensure ECC -Rater 
Companies understand what is required to participate in the ECC Program. The 
procedures encourage a widespread program adoption which accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25 402. 
  
Section:  10-103.3(f)1  
Specific Purpose:  The purpose of this addition is to require the ECC -Rater to apply to 
the ECC -Provider for certification.  
Necessity:  This addition is necessary to enforce the training and testing requirements 
for certification. Clearly delineated certification processes are necessary to ensure ECC -
Rater Companies understand what is required to participate in the ECC Program. The 
procedures encourage a widespread program adoption which accurately determine 
building energy efficien cy standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
   
 Section:  10-103.3(f)1A  
Specific Purpose:  The purpose of this addition is to require the ECC -Rater Company 
to apply to the ECC -Provider for certification.  
Necessity:  This addition is necessary to enforce the training and testing requirements 
for certification. Clearly delineated certification processes are necessary to ensure ECC -
Rater Companies understand what is required to participate in the ECC Program. The 
procedures encourage a widespread program adoption which accurately determine 
building energy efficien cy standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)1B  
Specific Purpose:  The purpose of this addition is to ensure that one of the ECC -Rater 
Company principals is a certified ECC -Rater.  
Necessity:  This addition is necessary to ensure the ECC -Rater Company leadership is 
competent and has direct understanding of the ECC -Rater responsibilities. Minimum 
qualifications are necessary to ensure ECC -Rater Companies understand what is 
required to participate in the ECC Program. The training requirements ensure ECC -
Raters accurately determine building energy efficiency standard compliance so that 
wastef ul energy consumption is reduced, as directed by PRC 25402.  
 
  
Section:  10-103.3(f)1C  
Specific Purpose:  The purpose of this addition is to require the training for ECC -Rater 
Company to be completed.  
Necessity:  This addition is necessary to ensure that all required training is complete. 
The ECC -Rater Company is a new addition to the ECC Program and as such, each 
ECC -Rater Company must be trained in how to demonstrate compliance with its new 
responsibilities. Proper training is necessary to ensure ECC -Rater  Companies  
understand what is required to participate in the ECC Program. The training 
requirements ensure ECC -Rater  Companies  accurately determine building energy 
efficiency standard compliance so tha t wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(f)1D  
Specific Purpose:  The purpose of this addition is to require the ECC -Rater Company 
to sign an agreement with the ECC -Provider agreeing that the ECC -Rater Company will 
comply with all applicable laws and regulations.  
Necessity:  This addition is necessary to ensure that the ECC -Rater Company can be 
held accountable for falsifying compliance documents. ECC -Rater Company 
Agreements ensure progressive discipline can be carried out. Progressive discipline  
 assists in ensuring all requirements are carried out, which helps identify and incentivize 
improved rating accuracy so that building efficiency standard compliance is achieved, 
and the wasteful consumption of energy is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2  
Specific Purpose:  The purpose of this addition is to specify ECC -Rater Company 
conduct.  
Necessity:  This addition is necessary to require a level of professional conduct of the 
ECC -Rater Companies because they deal directly with the public. This prevents an 
ECC -Rater Company from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful ene rgy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2A  
Specific Purpose:  The purpose of this addition is to allow ECC -Providers, the CEC , 
and the public to verify which ECC -Rater's  work for which ECC -Rater Companies.  
Necessity:  This addition is necessary to effectively enforce the ECC -Rater conduct and 
activity requirements. This prevents an ECC -Rater Company from undermining the 
integrity of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful ene rgy consumption is reduced, as directed by 
PRC 25402.  
  
Section:  10-103.3(f)2B  
Specific Purpose:  The purpose of this addition is to limit ECC -Rater Company access 
to the certificates of verification, while allowing viewing access.  
Necessity:  This addition is necessary to prevent ECC -Rater Companies from altering 
the verification without the ECC -Rater's knowledge. This prevents an ECC -Rater 
Company from undermining the integrity of the ECC Program. A reputable ECC 
Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful ene rgy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2C  
Specific Purpose:  The purpose of this addition is to forbid the ECC -Rater Company 
from altering the certificates of verification.  
Necessity:  This addition is necessary because ECC -Rater Companies have used ECC -
Rater passwords to access the ECC -Provider data registry without the ECC -Rater's 
consent.  This prevents an ECC -Rater Company from undermining the integrity of the  
 ECC Program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2D  
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater Company to 
complete the certificate of compliance and installation for the project.  
Necessity:  This addition is necessary to prevent the ECC -Rater from compiling the 
certificate of compliance and verification, which is a violation of the conflict of interest. 
This prevents an ECC -Rater Company from undermining the integrity of the ECC 
Program. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful ene rgy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2Di  
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater Company to 
complete the certificate of compliance and installation for the project.  
Necessity:  This addition is necessary to prevent the ECC -Rater from complying the 
certificate of compliance and verification, which is a violation of the conflict of interest. 
This prevents an ECC -Rater Company from undermining the integrity of the ECC 
Program. A reputable ECC Program is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency standard compliance so 
that wasteful ene rgy consumption is reduced, as directed by PRC 25402.  
Section : 10-103.3(f)2Dii  
Specific Purpose : The purpose of this addition is to establish the circumstances and 
requirements for an ECC -Rater Company to voluntarily provide services other than field 
verification and diagnostic ser vices to a builder  that they otherwise would be required to 
be independent from.  
Nece ssity : This addition is necessary to allow ECC -Rater Companies to engage in 
these practices while maintaining the indepen dent, third -party nature of ECC -Raters  
from the builder . The ECC -Rater must be indepen dent from the builder to help ensure 
that the field verification and diagnostic tests results are not coer ced. This prevents an 
ECC -Rater Company from undermining the integrity of the ECC Program. A reputable 
ECC Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.   
 
Section:  10-103.3(f)2Dii i 
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater Company to 
submit a declaration to establish a separation of services between field verification and  
 diagnostic testing  services , and all other construction related services  that the ECC -
Rater Company may wish to provide .  
Necessity:  This addition is necessary to help ensure that the ECC -Rater Company 
does not circumvent the conflict -of-interest  requirements (Section 10 -103.3(b)1)  or 
otherwise compromise the integrity of the ECC Program. This is critical to help ensure 
that the ECC -Rater does not experience undue pressure from the builder  or designer 
within th eir own ECC -Rater Company.  This prevents an ECC -Rater Company from 
undermining the integrity of the ECC Program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful en ergy consumption is reduced, as 
directed by PRC 25402.  
 
Section:  10-103.3(f)2Dii ia 
Specific Purpose:  The purpose of this addition is to allow the ECC -Rater Company to 
show proof  as to the separation of influence of the ECC -Rater and person(s) providing 
non-field ver ification and diagnostic testing ser vices.  
Necessity:  This addition is necessary to help ensure that the ECC -Rater can provide 
an accurate field verification and diagnostic test without concern of retaliation from the 
person(s) providing non -field verification and diagnostic testing services . This prevents 
an ECC -Rater Company from undermining the integrity of the ECC Program. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
 
Section:  10-103.3(f)2Dii ib 
Specific Purpose:  The purpose of this addition is to help ensure that the person 
providing construction services  is qualified  under Division 3 of the Business and 
Professions Code  to perform thos e services . 
Necessity:  This addition is necessary to help ensure that the designs and specifications 
for construction a re competent and in compliance with the Energy Code. Persons 
providing design , installation , and other construction services are regulated by the 
Business and Professions Code . This prevents an ECC -Rater Company from 
undermining the integrity of the ECC Program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
 
Section: 10 -103.3(f)2Dii ic 
Specific Purpose: The purpose of this addition is to specifically show proof that the 
person acting as the Responsible Person for the Certificates of Compliance and  
 Installation does not have any influence on the ECC -Rater performing the field 
verifications or diagnostic tests.  
Necessity:  This addition is necessary to help ensure that the ECC -Rater has specific 
protections from the influence of the person acting as the Responsible Person for the 
Certificates of Compliance and Installation . Such influence within a n ECC -Rater 
Company can undermine the ECC program integrity. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
 
Section:  10-103.3(f)2Dii id 
Specific Purpose:  The purpose of this addition is to ensure that the ECC -Rater 
Company files the Declaration of ECC -Rater Company Separation of Services with the 
ECC -Provider data registry being used  for the project.  
Necessity:  This addition is necessary to help ensure that the correct ECC -Provider is 
made aware of the servi ces being offered by the ECC -Rater Company . There are 
several  independent ECC -Providers that do not communicate the filing of compliance 
documents with each other.  This addition will help to clarify which ECC -Provider is 
being used for each project.  This prevents an ECC -Rater Company from undermining 
the integrity of the ECC Program. A reputable ECC Program is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
standard compliance so that wasteful ene rgy consumption is reduced, as directed by 
PRC 25402.  
 
Section:  10-103.3(f)2E  
Specific Purpose:  The purpose of this addition is to require the ECC -Rater Company 
to use the ECC -Provider data registry user interface or approved external digital data 
service.  
Necessity:  This addition is necessary because many ECC -Provider Companies have 
their own internal data gathering systems that are not permitted to upload to the data 
registry. This prevents an ECC -Rater Company from undermining the integrity of the 
ECC Program. A reputable ECC Program is necessary to encourage widespread 
program adoption and accurately determine building energy efficiency standard 
compliance so that wasteful ene rgy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2F  
Specific Purpose:  The purpose of this addition is to require annual reporting to the 
ECC -Provider.  
Necessity:  This addition is necessary to ensure that the ECC -Rater Companies 
perform this reporting and not the ECC -Provider. This ensures ECC -Rater Companies 
do their portion of annual reporting requirements to encourage transparency within the  
 ECC Program to accurately determine building energy efficiency standard compliance 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2Fi  
Specific Purpose:  The purpose of this addition is to require specific information in the 
annual report to the ECC -Provider.  
Necessity:  This addition is necessary to allow the ECC -Provider to report this 
information to the CEC  in aggregate form. This ensures ECC -Rater Companies do their 
portion of annual reporting requirements to encourage transparency within the ECC 
Program to accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as di rected by PRC 25402.  
  
Section:  10-103.3(f)2Fii  
Specific Purpose:  The purpose of this addition is to require specific a list of all ECC -
Raters working for the ECC -Rater Company in the annual report to the ECC -Provider.  
Necessity:  This addition is necessary to allow the ECC -Provider to report this 
information to the CEC  in aggregate form. This ensures ECC -Rater Companies do their 
portion of annual reporting requirements to encourage transparency within the ECC 
Program to accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as di rected by PRC 25402.  
  
Section:  10-103.3(f)2Fiii  
Specific Purpose:  The purpose of this addition is to require the total number of field 
verifications and diagnostic tests performed by ECC -Raters working for the ECC -Rater 
Company during the prior calendar year, organized by building code jurisdiction. in the 
annual report to the ECC -Provider.  
Necessity:  This addition is necessary to allow the ECC -Provider to report this 
information to the CEC  in aggregate form. This ensures ECC -Rater Companies do their 
portion of annual reporting requirements to encourage transparency within the ECC 
Program to accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as di rected by PRC 25402.  
  
Section:  10-103.3(f)2Fiv  
Specific Purpose:  The purpose of this addition is to require the total and average cost 
of services charged for each type of field verification and diagnostic test performed by 
ECC -Raters working for the ECC -Rater Company during the prior calendar year in the 
annual report to the ECC -Provider.  
Necessity:  This addition is necessary to allow the ECC -Provider to report this 
information to the CEC  in aggregate form. This ensures ECC -Rater Companies do their 
portion of annual reporting requirements to encourage transparency within the ECC  
 Program to accurately determine building energy efficiency standard compliance so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2G  
Specific Purpose:  The purpose of this addition is to make the ECC -Rater Company 
responsible for the actions of the ECC -Raters that they employ.  
Necessity:  This addition is necessary to motivate the ECC -Rater Companies to adopt 
internal policies in support of these regulations. This prevents an ECC -Rater Company 
from undermining the integrity of the ECC Program. A reputable ECC Program is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency standard compliance so that wasteful ene rgy consumption is 
reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2H  
Specific Purpose:  The purpose of this addition is to require that the ECC -Rater 
Companies support the progressive discipline regulations for ECC -Raters.  
Necessity:  This addition is necessary to promote more robust compliance with these 
regulations. Robust compliance with these regulations encourages accurate building 
energy efficiency standard compliance so that wasteful energy consumption is reduced, 
as directed by PRC 25402.  
  
Section:  10-103.3(f)2Hi  
Specific Purpose:  The purpose of this addition is to require an ECC -Rater Company to 
support the ECC Rater progressive discipline by ensuring the ECC -Rater complies with 
all actions prescribed in the notice of violation.  
Necessity:  This addition is necessary to promote better compliance with these 
requirements. Progressive discipline allows the ECC Program to identify and incentivize 
improved rating accuracy so that building energy efficiency standard compliance is 
achieved, and the wasteful consumption  of energy is reduced, as directed by PRC 
25402.  
  
Section:  10-103.3(f)2Hii  
Specific Purpose:  The purpose of this addition is to require an ECC -Rater Company to 
support the ECC Rater progressive discipline by ensuring the ECC -Rater complies with 
all actions prescribed in the notice of probation.  
Necessity:  This addition is necessary to promote better compliance with these 
requirements. Progressive discipline allows the ECC Program to identify and incentivize 
improved rating accuracy so that building energy efficiency standard compliance is 
achieved, and the wasteful consumption of energy is reduced, as directed by PRC 
25402.   
   
Section:  10-103.3(f)2Hiii  
Specific Purpose:  The purpose of this addition is to require an ECC -Rater Company to 
support the ECC Rater progressive discipline by ensuring the ECC -Rater complies with 
all actions prescribed in the notice of suspension.  
Necessity:  This addition is necessary to promote better compliance with these 
requirements. Progressive discipline allows the ECC Program to identify and incentivize 
improved rating accuracy so that building energy efficiency standard compliance is 
achieved, and the wasteful consumption of energy is reduced, as directed by PRC 
25402.  
  
Section:  10-103.3(f)2Hiv  
Specific Purpose:  The purpose of this addition is to ensure the ECC -Rater Company 
will guarantee the decertified ECC -Rater does not perform any FV&DT services  
Necessity:  This addition is necessary to promote better compliance with these 
requirements. A decertified ECC -Rater has shown they have not adequately complied 
with these regulations are unfit to accurately determine building energy efficiency , 
therefore they are not contributing to a reduction of wasteful energy, and  should be 
removed from the ECC Program as directed by PRC 25402.  
  
Section:  10-103.3(f)2I  
Specific Purpose:  The purpose of this addition is to restrict ECC -Rater Companies 
from falsifying verifications.  
Necessity:  This addition is necessary to oversee the ECC -Rater Companies. This 
prevents an ECC -Rater Company from undermining the integrity of the ECC Program. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2J  
Specific Purpose:  The purpose of this addition is to restrict ECC -Rater Companies 
from accepting bribes.  
Necessity:  This addition is necessary for the integrity of the ECC program. This 
prevents an ECC -Rater Company from undermining the integrity of the ECC Program. A 
reputable ECC Program is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency standard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)2K   
 Specific Purpose:  The purpose of this addition is to require the ECC -Rater Companies 
to comply with the conflict -of-interest  regulations.  
Necessity:  This addition is necessary to ensure that the ECC -Rater Companies do not 
cause a conflict of interest for the ECC -Raters that they employ. This prevents an ECC -
Rater Company from undermining the integrity of the ECC Program. A reputable ECC 
Program is necessary to encourage widespread program adoption and accurately 
determine building energy efficiency standard compliance so that wasteful energy 
consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(f)3  
Specific Purpose:  The purpose of this addition is to link compliance with the ECC -
Rater Company required conduct to the progressive discipline regulations.  
Necessity:  This addition is necessary to clearly identify these requirements as 
enforceable by the ECC -Provider. This prevents an ECC -Rater Company from 
undermining the integrity of the ECC Program. A reputable ECC Program is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful ene rgy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(f)4  
Specific Purpose:  The purpose of this addition is to provide an appeal process for the 
ECC -Rater Company.  
Necessity:  This addition is necessary to ensure that ECC -Rater Companies are not 
subjected to unfair targeting by ECC -Providers. The addition allows an ECC -Rater 
Company to show they acted w ithin the regulations of the ECC Program and may 
continue participating in the ECC Program so that wasteful energy consumption is 
reduced as directed by PRC 25402.   
  
Section:  10-103.3(g)  
Specific Purpose:  The purpose of this addition is to prevent suspended or decertified 
ECC -Raters, ECC -Rater Companies, or ECC -Providers from continuing to operate 
under these regulations.  
Necessity:  This addition is necessary to describe the exact restrictions for ECC -Raters, 
ECC -Rater Companies, and ECC -Providers based on their certification status. 
Preventing suspended or decertified ECC participants from practice and re -entry 
increases the reputation of the ECC Program. A strong reputation is necessary to 
encourage widespread program adoption and accurately determine building energy 
efficiency standard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
   
 Section:  10-103.3(g)1  
Specific Purpose:  The purpose of this addition is to describe the limitations of ECC -
Raters under suspension.  
Necessity:  This addition is necessary to restrict the activities of the ECC -Rater while 
under suspension. Preventing suspended or decertified ECC participants from practice 
and re -entry increases the reputation of the ECC Program. A strong reputation is 
necessary to encourage widespread program adoption and accurately determine 
building energy efficiency stand ard compliance so that wasteful energy consumption is 
reduced, as directed by PRC 25402.   
  
Section:  10-103.3(g)1A  
Specific Purpose:  The purpose of this addition is to restrict the ECC -Rater from using 
the ECC -Provider data registry while under suspension.  
Necessity:  This addition is necessary to prevent the ECC -Rater from altering entries in 
the data registry while under investigation. Preventing suspended or decertified ECC 
participants from practice and re -entry increases the reputation of the ECC Program. A 
strong reputation is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency stand ard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(g)1B  
Specific Purpose:  The purpose of this addition is to invalidate any information entered 
into the data registry by a suspended ECC -Rater.  
Necessity:  This addition is necessary to allow the ECC -Provider to flag data entered 
into the data registry by a suspended ECC -Rater as conflicted data. Preventing 
suspended or decertified ECC participants from practice and re -entry increases the 
reputation of the ECC Program. A strong reputation is necessary to encourage 
widespread program adoption and accurately determine building energy efficiency 
stand ard compliance so that wasteful energy consumption is reduced, as directed by 
PRC 25402.   
  
Section:  10-103.3(g)2  
Specific Purpose:  The purpose of this addition is to restrict the actions of the ECC -
Rater Company while under suspension.  
Necessity:  This addition is necessary to prevent the ECC -Rater Company from altering 
the data registry while under investigation. Preventing suspended or decertified ECC 
participants from practice and re -entry increases the reputation of the ECC Program. A 
strong reputation is necessary to encourage widespread program adoption and 
accurately determine building energy efficiency stand ard compliance so that wasteful 
energy consumption is reduced, as directed by PRC 25402.    
   
Section:  10-103.3(g)3  
Specific Purpose:  The purpose of this addition is to restrict the actions of the ECC -
Provider when interacting with ECC -Raters or ECC -Rater Companies while they are 
under suspension.  
Necessity:  This addition is necessary to prevent the ECC -Provider from allowing the 
data registry to be altered by entities under investigation. Preventing suspended or 
decertified ECC participants from practice and re -entry increases the reputation of the 
ECC Program. A strong reputation is necessary to encourage widespread program 
adoption and accurately determine building energy efficiency stand ard compliance so 
that wasteful energy consumption is reduced, as directed by PRC 25402.   
  
Section:  10-103.3(g)3A  
Specific Purpose:  The purpose of this addition is to restrict an ECC -Provider that is 
under suspension from accepting entries into its data registry.  
Necessity:  This addition is necessary to ensure that suspended entities do not alter the 
data registry. Preventing suspended or decertified ECC participants from practice and 
re-entry increases the reputation of the ECC Program. A strong reputation is necessary 
to encourage widespread program adoption and accurately determine building energy 
efficiency stand ard compliance so that wasteful energy consumption is reduced, as 
directed by PRC 25402.   
  
Section:  10-103.3(g)3B  
Specific Purpose:  The purpose of this addition is to make it clear that the ECC -
Provider can register documents from a suspended ECC -Rater that were submitted 
prior to suspension.  
Necessity:  This addition is necessary to clarify that an ECC -Provider does not need to 
purge its data registry of all compliance documents submitted by a suspended ECC -
Rater. A well understood ECC Program is necessary to encourage widespread program 
adoption and accurately determine building efficiency standard compliance so that 
wasteful energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(g)4  
Specific Purpose:  The purpose of this addition is to allow the CEC  to reinstate a 
suspended entity for good cause.  
Necessity:  This addition is necessary to allow for the possibility that it would be in the 
best interest of the ECC program to reinstate a suspended ECC -Rater or ECC -Rater 
Company. A dynamic ECC Program that allows a previously suspended or decertified 
ECC participant allows the Executive Director or Commission to weigh the benefits to 
the larger ECC Program vs the risks. The Commission or Director may find that the  
 benefits to the program reduce the wasteful consumption of energy as directed by PRC 
25402, outweighing potential harms in keeping the ECC participant out of the ECC 
Program.  
  
Section:  10-103.3(h)  
Specific Purpose:  The purpose of this addition is to provide a final appeal for 
progressive discipline actions taken against ECC -Raters and ECC -Rater Companies.  
Necessity:  This addition is necessary to allow the CEC  to consider all actions of the 
ECC -Provider when it decertifies an ECC -Rater or ECC -Rater Company. This addition 
allows a decertified ECC participant to argue  they acted within the regulations of the 
ECC Program and may continue to participate in the ECC program so that wasteful 
energy consumption is reduced, as directed by PRC 25402.  
  
Section:  10-103.3(h)1  
Specific Purpose:  The purpose of this addition is a general outline of the appeal 
submitted to the CEC . 
Necessity:  This addition is necessary to ensure that a minimum record is created for 
the CEC  to consider. This addition allows a decertified ECC participant to argue they 
acted within the regulations of the ECC Program and may continue to participate in the 
ECC program so that wasteful energy consumption is reduced, as directed by PRC 
25402.  
  
Section:  10-103.3(h)2  
Specific Purpose:  The purpose of this addition is to allow the ECC -Provider to submit 
a response to the appeal.  
Necessity:  This addition is necessary to allow the ECC -Provider the opportunity to 
answer any accusations in the appeal. This addition allows a decertified ECC participant 
to argue they acted within the regulations of the ECC Program and may continue to 
participate in the ECC program so that wasteful energy consumption is reduced, as 
directed by PRC 25402.  
  
Section:  10-103.3(h)3  
Specific Purpose:  The purpose of this addition is to describe the appeal process that 
the CEC  will follow.  
Necessity:  This addition is necessary to clarify that the CEC  will follow its standard 
appeal process in Title 20. This addition allows a decertified ECC participant to argue 
they acted within the regulations of the ECC Program and may continue to participate in 
the ECC program so that wasteful energy consumption is reduced, as directed by PRC 
25402.   
   
Section:  10-103.3(h)3A  
Specific Purpose:  The purpose of this addition is to allow the CEC  to use its standard 
appeal process.  
Necessity:  This addition is necessary to reference the CEC  standard appeal process 
directly.  
  
Section:  10-103.3(h)3B  
Specific Purpose:  The purpose of this addition is to direct the CEC  to review the 
decision process used by the ECC -Provider to decertify the ECC -Rater or ECC -Rater 
Company.  
Necessity:  This addition is necessary to limit the CEC  review to only the ECC -Provider 
process and not the validity of the evidence collected by the ECC -Provider.  
 
Section: 10-104(b)  
Purpose:  The reason for including the term 'and' after each semicolon is to ensure a 
clear understanding that all the requirements in Section 10 -104(b) shall be met .   
Necessity:  These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous, enabling non -technical readers to easily locate 
and comprehend the technical requirements.  
 
Section: Section 10 -109(c)1  
Specific Purpose: Include language under the Alternative Calculation Method, to 
specify that the compliance manager is the compliance software developed by the 
Energy Commission to demonstrate building compliance with the Energy Code.  The 
compliance manager  determines compliance by comparing the  standard design energy 
budget to the proposed design as described in the following subsections.  
Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC.  Descriptions of the Compliance 
Manager and Alternative Calculation Method  software standard design have been 
brought over from the ACM Approval Manual. By incorporating the application process 
and requirements specified in the ACM Approval Manual, this additional document can 
be removed. The requi rements are relocated into Section 10 -116 and language will be 
revised to point to this new section in place of the ACM Approval Manual . 
 
Section: Section 10 -109(c) 1A  
 Specific Purpose: Include language under the Alternative Calculation Method, to 
specify the standard design for building models is calculated in the compliance manager 
software and Alternative Calculation Method s oftware . 
Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC . Descriptions of the Compliance 
Manager and Alternative Calculation Method  software  standard design  have been 
brought over from the ACM Approval Manual. By incorporating the application process 
and requirements specified in the ACM Approval Manual, this additional document can 
be removed. The requirements are relocated into Section 10 -116 and language w ill be 
revised to point to this new section in place of the ACM Approval Manual . 
Section: Section 10 -109(c)1B  
Specific Purpose: Include language under the Alternative Calculation Method, to 
explain  Long-term System Cost and Source Energy  for building models calculated using  
the compliance manager software and Alternative Calculation Method software.  
Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC . Descriptions of the Compliance 
Manager  and Alternative Calculation Method software  energy budget, Long-term 
System Cost, and Source Energy  have been brought over from the ACM Approval 
Manual. By incorporating the application process and requirements specified in the 
ACM Approval Manual, this additional document can be removed. The requirements are 
relocated into Section 10 -116 and language wi ll be revised to point to this new section 
in place of the ACM Approval Manual.  
Section: Section 10 -109(c)1C  
Specific Purpose: Include language under Alternative Calculation Method, to specify 
the climate zone use  for building models in the compliance manager software and 
Alternative Calculation Method software.  
Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC . Descriptions of the Compliance 
Manager  and Alternative Calculation Method  software  climate zone use have been 
brought over from the ACM Approval Manual. By incorporating the application process 
and requirements specified in the ACM Approval Manual, this additional document can 
be removed. The requirements are relocated into Section 10 -116 and language w ill be 
revised to point to this new section in place of the ACM Approval Manual.  
Section: Section 10 -109(c)1 D 
Specific Purpose: Include language under the Alternative Calculation Method, to 
specify the development of  the Alternative Calculation Method Reference Manual .  
 Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC . The Alternative Calculation 
Method Reference Manual provides additional clarification  of the standard design, 
energy budget, Long-term System Cost, Source Energy , and climate zone usage in 
software . By incorporating the application process and requirements specified in the 
ACM Approval Manual, this additional document can be removed. The requirements are 
relocated into Section 10 -116 and language will be revised to point to this new section 
in place of the ACM Approval Manual.  
Section: Section 10 -109(c)1E  
Specific Purpose: Include language under the Alternative Calculation Method, to 
specify the compliance documentation in  the compliance manager software and 
Alternative Calculation Method software . 
Necessity: Currently, the Alternative Calculation Method Approval Manual is adopted 
as a separate document during the rulemaking process. The Compliance Manager 
references the software that is provided by the CEC . Description  of the Compliance 
Manager  and Alternative Calculation Method  software  compliance documentation 
requirements have been brought over from the ACM Approval Manual . By incorporating 
the application process and requirements specified in the ACM Approval Manual, this 
additional document can be removed. The requirements are relocated into Section 10 -
116 and language will be revised to point to this new section in place of the ACM 
Approval Manual.  
Section:  Section 10 -109(c)2  
Specific Purpose:  Added term compliance manager to this section to indicate that the 
compliance manager is the public domain computer program.  
Necessity:  The term compliance manager was used in the 2022 Alternative Calculation 
Method Approval Manual to identify the public domain computer program that the CEC  
used to meet Public Resources Code Section 25402.1. The Alternative Calculation 
Method Approval Manual was incorporated into Section s 10-109 and  10-116 of the 
Energy Code . The term compliance manager was added to Section 10 -109(c)2 to clarify 
that the public domain computer program identified here is the same compliance 
manager discussed in Section 10 -116 
 
Section: Section 10 -109(c)3  
Specific Purpose: Revise language to reference Section 10 -116, 10-109(c)1A, 10 -
109(c)1B, 10-109(c)1C, 10 -109(c)1D, and 10 -109(c)1E  for requirements for applications 
for approval of compliance software.  
Necessity: The Alternative Calculation Method Approval Manual was dissolved , with 
regulatory language moved into Section 10 -116, 10-109(c)1A, 10 -109(c)1B, 10 -
109(c)1C, 10 -109(c)1D, and 10 -109(c)1E . The revised section in 10 -116 provides  
 information on applications for all Alternative Calculation Method software, and the 
revised sections in 10-109 include software capabilities applicable to both the 
compliance manager software and all other compliance software. Additionally, 
supporting language from the Alternative Calculation Method Approval Manual will be 
moved into the ACM Reference Manual.  
 
Section : Section 10 -109(k)  
Specific Purpose : The purpose of this change is to clarify actions the CEC may take 
under its own motion and limit the obligations of prior approved applicants.  
Necessity : This change is necessary to clarify applicant requirements and duty, and to 
reduce administrative burden.  
 
Section: 10-110 
Specific Purpose:  
The purpose of this change is to add section 10 -103.3 to the heading of Title 24, Part 1, 
Section 10 -110. 
Necessity:  
This change is necessary to help clarify the application review and to give constructive 
structure to the review and approval process.  
Section: 10-114 
Specific Purpose:  
The purpose of this change is to update the US  Census guideline f rom 2010 to 2020 . 
Necessity:  
This change is necessary to align with t he latest  US Census designations .  
 
Section : Section 10 -115 
Specific Purpose : The purpose of this change is to specify that the code only is 
regulating Battery Energy Storage Systems and not any other storage systems.  
Necessity : These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous  and only apply to Battery Energy Storage 
Systems.  
Section : Section 10 -115(a)6   
 Specific Purpose : The purpose of this addition is to clarify and make more specific the 
meaning of distribution system  within the community shared sol ar electric generation 
system . The distribution system shall have an electrical voltage less than 100kV   
Necessity : These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous.  It aligns the scope of distribution system to be 
consistent with the 100 million kV capacity minimum that the North American Electric 
Reliability Corporation (NERC) establishes as the minimum threshold for transmission 
lines; distribution lines operate at lower voltages.”  
 
Section:  Section 10 -116 
Specific Purpose: This new section includes the application requirements for third 
party Alternative Calculation Method compliance software.  
Necessity : These requirements were originally included in the ACM Approval Manual 
which was adopted as part of the rulemaking process. To reduce the number of 
rulemaking documents, application requirements and user manual requirements 
included in the ACM Approval M anual were relocated to Section 10 -116. Additional 
language included in the ACM Approval Manual which provided additional supporting 
information will be relocated into the ACM Reference Manual. The ACM Reference 
Manual already provides language to  support the ACM Approval Manual. Appendix A 
and Appendix B of the Approval Manual will be moved into the ACM Reference Manual.  
 
   
 TITLE 24, PART 6 PROPOSED AMENDMENTS  
 
Section: Section 100.0(a)1 – Scope  
Specific Purpose: This change will add occupancy group L to the list of building 
occupancy groups covered by the Energy Code.  
Necessity: Currently occupancy group L is not covered under the Energy Code. 
Laboratories were previously covered under the Energy Code prior to revisions to 
occupancy groups in the building code which separated occupancy group L laboratories 
from other occupancy gro ups. This revision will bring these laboratories back under the 
Energy Code where considerations have already been made for laboratory spaces. 
Applying the Energy Code to occupancy group L will reduce excessive energy use as 
directed by California Public R esources Code Sections 25213 and 25402.  
  
Section: Exception  2 to Section 1 00.0(a) 
Purpose: The purpose of this change is to modify terminology and eliminate the use of 
the term "exempt" for clarity without changing the intent of the Energy Code. When 
particular requirements in the Energy Code are not applicable to particular construction 
situati ons or equipment for specific reasons, the Energy Code does provide exceptions 
that indicate compliance is not required in that instance.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity, provide 
consistency with other exceptions in the Energy Code.  
 
Section: 100.0(e)2C Unconditioned Nonresidential Buildings and Process Space  
Purpose: The purpose of this change is to remove unnecessary and duplicative 
language for the sections that are applicable to both unconditioned nonresidential 
buildings and process spaces.    
Necessity:  It is necessary to make this change because  Section 140.1 is not applicable 
to these spa ces, and Section 140. 3(c) is already mentioned in the beginning of this 
subsection. The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
Section: 100.0(e)2F Covered processes  
Specific Purpose: The purpose of this change is to clean up language to properly 
reference mandatory requirements for covered processes that are located in Section 
110.2 and 120.3 of the Energy Code , as well as prescriptive requirements in 141.1.  
Section 110.2 is appropriately referenced in Section 100.0(e) 2Fi but  should also be 
referenced in Section 100.0(e)2Fii and removed the note to Section 100.0(e)2F  as it is 
not enforceable . Section 120.3 is newly applicable to covered processes. Section 141.1 
is appl icable to additions and alterations to existing covered processes. Remove note 
regarding the applicability of mandatory requirements to prescriptive projects.  
Necessity: This change is required to reduce confusion in which sections a user should 
refer to when identifying requirements for covered process measures. Additional, new 
requirements for covered processes included in Section 120.3 are referenced to notify  
 users that where these new requirements are located. Finally, the note that was 
removed provided redundant information  and not enfor ceable . 
  
Section : Table 100.0 -A 
Specific Purpose : The purpose of this change is to u pdate  covered processes to 
reference Section 120.3 for mandatory requirements and Sections 110.2 and 120.3 for 
additions and alterations.  The purpose was to also update the nonresidenti al HVAC 
sections to include 120.10.  
Necessity : Revisions to the code language included new pipe insulation requirements 
for covered process equipment located in Section 120.3. Additionally, requirements in 
Section 120.3 and 110.2 are now applicable to addition and alteration projects.  The 
addition of 120.10 to this table was needed to improve clarity and consistency of the 
code.  
  
 
  
Section  100.1 (b) - Definitions  
Specific Purpose : The specific purpose of the change is to correct  minor grammatical 
and typographical errors throughout section 100.1.  
Necessity : The changes are necessary  to ensure the code can be read without any 
confusions. The changes are reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code.  
  
  
  
 
Section: 100.1 (b) – AHRI 420 Definition  
Specific Purpose: The purpose of this change is to add the definition for AHRI 420, 
including specifics regarding the version of the document, used for Energy Code 
requirements.  
Necessity: The definition AHRI 420 is required to ensure that the appropriate versions 
of AHRI 420 are referenced and used when calculating specific minimum efficiency of 
refrigerated warehouse evaporator equipment.  
 
Section: 100.1(b) – AHRI 540 definition  
Specific Purpose: The purpose of this change is to add the definition of AHRI 540, 
including specifics regarding the version of the document, used for Energy Code 
Requirements.  
Necessity: The definition of AHRI 540 is required to ensure that the appropriate 
versions of AHRI 540 are referenced and used when calculating compressor capacity to 
meet minimum heat pump water heater ventilation requirements.  
 
Section: 100.1 (b) – AHRI 1240 Definition   
 Specific Purpose: The purpose of this change is to add the definition of AHRI 1240, 
including specifics regarding the version of the document, used for Energy Code 
Requirements.  
Necessity: The definition of AHRI 1240 is required to ensure that the appropriate 
versions of AHRI 1240 are referenced and used when calculating specific minimum 
efficiency of refrigerated warehouse evaporator equipment.  
 
Section : 100 .1(b) - Air-To-Water Heat Pump (AWHP)  
Specific Purpose : Add definition for air -to water heat pumps to clarify the type of 
equipment that is required in new Energy Code requirements.  
Necessity : New heat pump requirements for offices and school buildings were added 
into the 2025 Energy Code. This definition provides clarity regarding the air -to-water 
heat pump equipment that are required to be installed as part of these new 
requirements.  
   
Section: 100.1(b) – ANSI/AMCA 220 definition  
Purpose:  The specific purpose of adding a definition for ANSI/AMCA 220  to the 
Definitions section is to provide clean and specific definition for this technical term, 
which is used within other updates to Part 6, aligned with the use of the term where it is 
proposed to occur later in the Energy Code. This includes the added definition for new 
industry standards documents that are incorporated by reference into later portions of 
the Energy Code.  
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section : 100.1(b) – ASHRAE Guideline 36 definition  
Specific Purpose: The specific purpose of this addition is to include a definition for the 
ASHRAE Guideline 36 publication to state the title and topic  and provide  a precise 
understanding of the guideline's scope, objectives, and relevance in the context of 
building design  with regards to  energy efficiency . This inclusion will aid in promoting 
consistency, adherence, and effective utilization of the guideline's principles and 
strategies.  
Necessity: These changes are necessary to increase energy efficiency via cost - 
effective HVAC controls.   Providing a clear and concise definition of ASHRAE Guideline 
36 within the California Energy Code aids in interpretation, compliance, and 
enforcement efforts. It offers guidance to designers, engineers, contractors, and building 
officials, ensuring that pr ojects meet or exceed established energy efficiency criteria.  
 
Section : 100.1(b) – ASHRAE  Standard 62.2 definition  
Specific Purpose : The specific purpose of this change is to  update to the current 
version of ASHRAE 62.2  (2022 version)  to be referenced by Title 24 , Part 6.   
 Necessity : This change is necessary to align with industry standard practices, and 
model codes.  
Section : 100.1(b) – Battery System, Stationary Storage and Battery Energy Storage 
System (BESS) definition  
Specific Purpose : This definition is being merged with the Energy Storage System 
(ESS) and renamed to Battery Energy Storage System (BESS). All references to  battery 
storage system and energy storage system (including references to ESS) throughout 
Parts 1 and 6, as well as the reference appendices, are also being updated to BESS to 
reflect this change.  
Necessity : This change is necessary to align with the more up -to-date industry 
terminology for electro -chemical battery storage systems. Currently the only type of 
ESS recognized by the Standards is BESS, this change clarifies the intent of the 
Standard and ensures  that the terms used within the regulations will have clear and 
unambiguous meaning to readers, including the public, and particularly to the persons 
and organizations affected by these regulations.  
 
   
Section: 100.1(b) – Cathedral Ceiling definition  
Specific Purpose: Add a definition of cathedral ceilings that ensures a consistent 
interpretation and accurate compliance with energy efficiency requirements of the 
code's provisions related to building construction.  
Necessity: This change is necessary to clarify what assemblies qualify as cathedral 
assemblies. Incorporating a precise definition to provide a standardized reference point 
that aids architects, engineers, and builders in accurately identifying and implementing 
cathe dral ceilings in construction projects.  
 
Section: 100.1(b) – Demand Flexibility Measure  definition  
Specific Purpose: The specific purpose of the change is to update the terminology of 
Time Dependent Valuation  to Long -term System Cost.  
Necessity: These changes are necessary to ensure that the terms used within the 
regulations will have clear and unambiguous meaning to readers, including the public, 
and particularly to the persons and organizations affected by these regulations. 
Additionally, th is new term ensure s consistency between the Energy Code and the other 
Parts of the Building Standards Code.  
 
Section : 100.1(b) – Domestic Hot Water System Appurtenance  definition  
Specific Purpose : Add definition for Domestic Hot Water System Appurtenance.  
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section: 100.1(b) – Dwelling Unit, Junior Accessory, or JADU  definition   
 Specific Purpose:  This specific purpose of this change is to add additional language to 
the existing definition to clarify that the JADU may be within a newly constructed or an 
existing single -family building.  
Necessity:  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.   
 
Section: 100.1(b) – Energy Budget  definition  
Specific Purpose: The specific purpose of the change is to update the terminology of 
Time Dependent Valuation  to Long -term System Cost. The Energy Budget definition is 
updated to include all terms for which an energy budget is set, L ong-term System Cost 
and Source Energy . Definition of each of these terms is also added to section 100.1(b ). 
Time Dependent Valuation , which is no longer being used for setting an energy budget, 
is deleted . 
Necessity: These changes are necessary to ensure that the terms used within the 
regulations will have clear and unambiguous meaning to readers, including the public, 
and particularly to the persons and organizations affected by these regulations. 
Additionally, th is new term ensure s consistency between the Energy Code and the other 
Parts of the Building Standards Code.  
  
Section : 100.1(b) – Energy Design Rating (EDR) definitions  
Specific Purpose:  The specific purpose of these changes is to remove definitions 
relating to Energy Design Ra ting (EDR). The following EDR definitions have been 
removed:  
• Energy Design Rating (EDR)  
• Energy Design Rating, Energy Efficiency  
• Energy Design Rating, Solar Electric Generation and Demand Flexibility  
Necessity: These changes are necessary because Energy Design Rating is no longer 
being used for establishing energy budgets. The proposed change is reasonably 
necessary to ensure and improve the general clarity and internal consistency of the 
Energy Code, as directed  by California Government Code, Section 11349 and 11349.1, 
and California Code of Regulations, Title 1, Section 16.  
 
Section : 100.1(b) – Energy Storage System (ESS) definition  
Specific Purpose : This definition is being merged with the definition for Battery Energy 
Storage System (BESS) and subsequently removed.  All Standards references to battery 
storage system and energy storage system are also being updated to BESS to reflect 
this change.  
Necessity : This change is necessary to align with the more up -to-date industry 
terminology for electro -chemical battery storage systems. Currently the only type of 
ESS recognized by the Standard is BESS, this change clarifies the intent of the 
Standard and ensure t hat the terms used within the regulations will have clear and 
unambiguous meaning to readers, including the public, and particularly to the persons 
and organizations affected by these regulations.   
  
Section: 100.1(b ) – Healthcare Facility definition  
Specific Purpose: Revise definition of healthcare facility to clarify that only health 
facilities, as defined in the California Health and Safety Code Division 2, Chapter 2, 
Section 1250, and clinics, as defined in the California Health and Safety Code Division 
2, Chapter 1 , Section 1204, located within a health facility fall under the healthcare 
facility category.  
Necessity: This revision  is necessary because the Department of Health Care Access 
and Information (HCAI) reviews clinics located in health facilities but does not review 
clinics not located in health facilities. This left clinics located outside of health facilities 
outside of r egulations by HCAI or the Energy Code. Bringing clinics under the Energy 
Code and HCAI ensures that these facilities meet appropriate energy requirements and 
reduce excessive energy use as directed by California Public Resources Code Sections 
25213 and 254 02. 
 
  
Section: 100.1(b) – Heat  Pump Water Heater  definition  
Specific Purpose: The purpose of this change is to move the heat pump water heater 
definition under water heater definition.  
Necessity: These changes are necessary to improve readability and provide easy 
access to all  related water heater definitions.  
 
Section : 100.1(b)  – Kitchen definitions  
Specific Purpose: The specific purpose of the newly added definitions to the 
Definitions section are to provide clear and specific definitions for technical terms used 
within other updates to Part 6, aligned with the use of the term where it is proposed to 
occur later in the Energy Code. This includes added definitions for new industry 
standards documents that are incorporated by reference into later  portions of the 
Energy Code. The newly added definitions are:  
KITCHEN, FULL -SERVICE COMMERCIAL            
KITCHEN, INSTITUTIONAL COMMERCIAL  
KITCHEN, QUICK -SERVICE COMMERCIAL  
Necessity: These newly added definitions are necessary to ensure that provisions in 
subsequent sections are clear and unambiguous, and that non -technical readers are 
able to find and understand the technical meaning of specific terms relating to building 
design and c onstruction.  
 
Section  100.1(b) – Lighting – Multilevel Lighting  Control  definition  
Specific Purpose : The specific purpose of the change is to clarify and to update the 
definition of multilevel lighting controls. The change is to delete the phrase “reduces 
power going to a lighting system in multiple steps” and to replace it with “enables the 
level of li ghting to be adjusted up and down  across multiple levels”.  
Necessity : The proposed change to delete “reduces power going to a lighting system in 
multiple steps” is to clarify that current available multilevel lighting controls technology is  
 capable of adjusting lighting level of lighting upward and downward and beyond multiple 
steps - over in continuous range or continuous dimming. The proposed update of 
multilevel lighting controls is reasonably necessary to ensure and improves the general 
clarity and internal consistency of the Energy Code.  
 
Section : 100.1 (b) – Lighting – Programming  Library  definition  
Specific Purpose : The specific purpose of this addition is to include a definition for the 
term “Programming Library .” The term is used in other proposed changes  and are 
collections of prewritten  code that users can use to optimize HVAC system operation . 
Necessity: The inclusion of the  term "Programming Library" is crucial, as it not only 
aligns with proposed modifications but also addresses the need for standardized 
language in the documentation of HVAC control systems.  
 
Section  100.1(b ) – Lighting – Temporary Lighting  definition  
Specific Purpose : The specific purpose of the change is to revise the definition of 
installation period of temporary lighting and to define that temporary lighting does not 
persist beyond the time constraints specified about temporary lighting installations in 
California Electrical Code Article 590.  
Necessity : The proposed change of the definition of temporary lighting are reasonably 
necessary to ensure the Energy Code is in harmony with the California Electrical Code 
for the meaning of time constraint of temporary lighting. The changes are reasonably 
necessar y to ensure and improve the general clarity and internal consistency of the 
Energy Code . 
 
Section:  100.1(b) – Long -Term  System Cost (LSC ) definition   
Purpose:  The specific purpose of this change is to add a definition for the term Long -
term System Cost , which replaces the term Time Dependent Valuation  as the primary 
compliance metric  for the Energy Code performance approach . The definition  provides  
clear and specific definition for this technical term, which is used within other updates to 
Part 6, aligned with the use of the term where it is proposed to occur later in the Energy 
Code. This includes the added definition for new industry standards doc uments that are 
incorporated by reference into later portions of the Energy Code.  
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
   
Section: 100.1(b) – NEEA Advanced Water Heater Specification definition  
Specific Purpose: The specific purpose of the change is to update the version to 8.0. 
and include the effective date of this version.  
Necessity: These changes are necessary to align with the latest version of the NEEA 
Advanced Water Heater Specification.  
 
Section: 100.1(b) – Net Free Area  definition   
 Specific Purpose: The purpose of this change is to add definition for Net Free Area.  
Necessity: These changes are necessary to support the new ventilation requirements 
for consumer integrated heat pump water heaters in 110.3(c)7 . This definition clearly 
describes what area can count towards any “net free area” minimum requirement, which 
will ensure that where these requirements are triggered, the systems they serve perform 
as efficiently as expected. This is needed  to increase energy efficiency via cost -effective 
building design standards, as directed by California Public Resources Code Sections 
25213 and 25402.  
 
Section: Section 100.1( b) – Nonresidential Building definition  
Specific Purpose: This change will add occupancy group L to the list of building 
occupancy groups covered under the nonresidential building definition.  
Necessity: Currently occupancy group L is not covered under the Energy Code 
nonresidential buildings. Laboratories were previously covered under the Energy Code 
prior to revisions to occupancy groups in the building code which separated occupancy 
group L laboratories  from other occupancy groups. This revision will bring these 
laboratories back under the Energy Code where considerations have already been 
made for laboratory spaces. Applying the Energy Code to occupancy group L will 
reduce excessive energy us e as directed by California Public Resources Code Sections 
25213 and 25402.  
 
Section : 100.1(b) – Nonresidential Building Occupancy Types – Events & Exhibits  
definition  
Specific Purpose : The purpose of this change is to add a definition  to a newly covered 
space under our photovoltaic and energy storage system requirements of Section 
140.10.  
Necessity : This change is needed to ensure that spaces which have photovoltaic and 
energy storage system requirements are clearly identified and defined.  
 
Section : 100.1(b)  – Nonresidential Building Occupancy Types – Religious Facility 
Building  
Specific Purpose : The purpose of this change is to add a definition  to a newly covered 
space under our photovoltaic and energy storage system requirements of Section 
140.10.  
Necessity : This change is needed to ensure that spaces which have photovoltaic and 
energy storage system requirements are clearly identified and defined.  
 
Section : 100.1(b) – Nonresidential Building Occupancy Types – Religious Worship 
Building  definition  
Specific Purpose : The purpose of this change is to add a definition  to a newly covered 
space under our photovoltaic and energy storage system requirements of Section 
140.10.  
Necessity : This change is needed to ensure that spaces which have  photovoltaic and 
energy storage system requirements  are clearly identified and defined.   
  
Section : 100.1(b) – Nonresidential Building Occupancy Types – Sports & Recreation 
Building  definition  
Specific Purpose : The purpose of this change is to add a definition  to a newly covered 
space under our photovoltaic and energy storage system requirements of Section 
140.10.  
Necessity : This change is needed to ensure that spaces which have photovoltaic and 
energy storage system requirements are clearly identified and defined.  
 
Section: Section 100.1( b) – Nonresidential Function Areas – Laboratory definition  
Specific Purpose: Add definition for laboratory spaces.  
Necessity: Occupancy group L includes laboratory spaces and spaces supporting 
laboratory spaces. A definition to specify laboratory spaces versus the occupancy group 
L in general was provided to clarify that only the lab spaces would have to meet 
laboratory requireme nts and be able to use appropriate exceptions.  
  
Section: Section 100.1( b) – Nonresidential Function Areas – Laboratory Suite  
Specific Purpose: Add definition for laboratory suite.  
Necessity: The building code definition for Occupancy group L is based off the term 
laboratory suites. Laboratory suites includes laboratory spaces, and offices, storage 
rooms and other spaces supporting laboratory spaces. A definition to specify laboratory 
spaces ve rsus the occupancy group L, laboratory suites, in general was provided to 
clarify that only the lab spaces would have to meet laboratory requirements and be able 
to use appropriate exceptions.  
 
Section: 100.1(b) – Pools  
Specific Purpose: The specific purpose of the change is to update the definition to 
align pool definition with national and International Codes.  
Necessity: These changes are necessary based on industry feedback to ensure that 
the terms used within the regulations will have clear and unambiguous meaning to 
readers, including the public, and particularly to the persons and organizations affected 
by these regulations. Additionally, these new terms ensure consistency between the 
Energy  Code and the other Parts of the Building Standards Code.  
 
Section : 100.1(b) - Pool Pump, Dedicated -Purpose definition  
Specific Purpose : Add definition for Pool Pump, Dedicated -Purpose  
Necessity :  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building design and construction.  
 
Section : 100.1(b) - Pool, Public  definition  
Specific Purpose : Add definition for Pool, Public  
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and  
 understand the technical meaning of specific terms and technical standards relating to 
building design and construction.  
 
Section : 100.1(b) - Portable Electric Spa definition  
Specific Purpose : Add definition for Portable Electric Spa  
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building de sign and construction.  
  
Section: 100.1(b) – Pools, Residential definition  
Specific Purpose: The specific purpose of the change is to update the definition to 
align pool definition with national and International Codes.  
Necessity: These changes are based  on industry feedback and are necessary to  
ensure that the terms used within the regulations will have clear and unambiguous 
meaning to readers, including the public, and particularly to the persons and 
organizations affected by these regulations. Additionally, these new terms ensure 
consistency b etween the Energy Code and the other Parts of the Building Standards 
Code.  
 
Section: 100.1(b) – Power Conditioning System (PCS)  
Specific Purpose:  The specific purpose of the change is to add a definition for Power 
Conditioning System (PCS).  
Necessity:  This change is necessary to support the updated definition Battery Energy 
Storage System (BESS) , which includes the term “Power Conditioning System” as a 
component of a BESS. Defining this term as proposed helps ensure consistency 
between the Energy Code  and industry accepted definitions . 
 
Section: 100.1(b) – Process, Covered definition  
Specific purpose: The purpose of this change is to cleanup referenced section that 
apply to covered processes, and to add language specifying that process heating and 
cooling piping are considered covered processes. References to sections in the Energy 
Code that apply to covered process projects was removed.  
Necessity: New insulation requirements for process heating and cooling piping were 
added. Adjusting the definition of covered process to specifically call out process 
heating and cooling piping will ensure that users will know that this equipment also has 
requirement s under the Energy Code. References to specific code language was 
removed as it is not actually a definition.  
 
Section : 100.1(b) - Recovered Energy, On-Site definition  
Specific Purpose : Add definition for Recovered Energy, On -Site 
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non-technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building design and construction.   
  
Section : 100.1(b) - Single Zone Constant Volume Heat Pump definition  
Specific Purpose : Add definition for Single Zone Constant Volume Heat Pump  
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building design and construction.  
 
Section : 100.1(b) - Solar Pool Heating System  
Specific Purpose : Add definition for Solar Pool Heating System  
Necessity : These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section: 100.1 (b) – Ventilation Systems  definitions  
Specific Purpose:  The specific purpose of the revision in the definitions is to add a 
specification of having ‘at least one’ mechanical device to comply with the ventilation 
strategies. The revised definitions are:  
VENTILATION SYSTEM, BALANCED  
VENTILATION SYSTEM, EXHAUST  
VENTILATION SYSTEM, SUPPLY  
Necessity:  These changes are necessary as several buildings provide ventilation 
systems, particularly balanced ventilation systems, through two separate continuously 
operating fans and adding the above specification would improve general clarity for the 
updated chan ges made to the multifamily ventilation and compartmentalization 
requirements while ensuring internal consistency of the Energy Code.  
 
Section: 100.1(b) – Water Heater  definition  
Specific Purpose: The specific purpose of the change is to group all related water 
heater definition into a single heading. The following definitions have been grouped 
under water heater:  
• Consumer water heater  
• Integrated heat pump water heater  
• Split-refrigerant heat pump water heater  
• Split-hydronic heat pump water heater  
• Multi -pass water heater  
• Single -pass water heater  
Necessity: These changes are necessary to improve readability and provide easy 
access to all related water heater definitions. The changes ensure that the terms used 
within the regulations will have clear and unambiguous meaning to readers, including 
the public, and particularly to the persons and organizations affected by these 
regulations. Additionally, these new terms ensure consistency between the Energy 
Code and t he other Parts of the Building Standards Code.  
   
 Section: 100.1(b) – Water Heater – Consumer water heater definition  
Specific Purpose: The purpose of this change is to add the definition for consumer 
water heater as a consumer product regulated under USDOE.  
Necessity: The changes ensure that the terms used within the regulations will have 
clear and unambiguous meaning to readers, including the public, and particularly to the 
persons and organizations affected by these regulations. Additionally, these new terms 
ensure co nsistency between the Energy Code and the other Parts of the Building 
Standards Code.  
 
Section: 100.1(b) – Water Heater – Heat  Pump Water Heater  definition  
Specific Purpose: The purpose of this change is to move the heat pump water heater 
definition under water heater definition.  
Necessity: These changes are necessary to improve readability and provide easy 
access to all  related water heater definitions.  
 
Section: 100.1(b) – Water Heater – Integrated Heat Pump Water Heater  definition  
Specific Purpose: The purpose of this change is to add definition for integrated heat 
pump water heater.  
Necessity: These changes are necessary to ensure that new ventilation requirements 
in 110.3(c)7 only applies to types of HPWHs that need ventilation and to ensure correct 
use of ventilation methods to increase energy efficiency via cost -effective building 
design standards, as directed by California Public Resources Code Sections 25213 and 
25402.  
 
Section: 100.1(b) – Water Heater – Split-Refrigerant Heat Pump Water Heater  
definition  
Specific Purpose: The purpose of this change is to add definition for Split -Refrigerant 
heat pump water heater.  
Necessity: These changes are necessary to ensure that new ventilation requirements 
in 110.3(c)7 only applies to types of HPWHs that need ventilation and to ensure correct 
use of ventilation methods to increase energy efficiency via cost -effective building 
design stan dards, as directed by California Public Resources Code Sections 25213 and 
25402.  
 
Section: 100.1(b) – Water Heater – Split-Hydronic Heat Pump Water Heater  definition  
Specific Purpose: The purpose of this change is to add definition for Split Hydronic 
heat pump water heater.  
Necessity: These changes are necessary to ensure that new ventilation requirements 
in 110.3(c)7 only applies to types of HPWHs that need ventilation and to ensure correct 
use of ventilation methods to increase energy efficiency via cost -effective building 
design stan dards, as directed by California Public Resources Code Sections 25213 and 
25402.  
 
Section: 100.1(b) – Water Heater – Multi -Pass Water Heater  definition   
 Specific Purpose: The purpose of this change is renamed and modify the existing 
multi -pass heat pump water heater definition to apply generally to all multi -pass water 
heater.  
Necessity: Multi -pass operation is not unique to heat pump water heater. By separating 
operation mode definition and the heat pump water heater definition, the changes 
ensure that the terms used within the regulations will have clear and unambiguous 
meaning to reader s, including the public, and particularly to the persons and 
organizations affected by these regulations.  
 
Section: 100.1(b) – Water Heater – Single -Pass Water Heater  definition  
Specific Purpose: The purpose of this change is renamed and modify the existing 
single -pass heat pump water heater definition to apply generally to all single -pass water 
heater.  
Necessity: single -pass operation is not unique to heat pump water heater. By 
separating operation mode definition and the heat pump water heater definition, the 
changes ensure that the terms used within the regulations will have clear and 
unambiguous meaning to readers, including the public, and particularly to the persons 
and organizations affected by these regulations.  
 
 
 
Section : 100.2  – CALCULATIN TO ENERGY BUDGETS  
Specific Purpose: The purpose of the changes to this section is to make it clear that 
energy budgets are expressed using t wo terms, Long -term System Cost and Source 
Energy. The term Time Dependent Valuation  is no longer being used. The title of the 
section is changed to Calculation of Energy Budgets. The purpose of energy budgets is 
explained consistent with other sections of the Energy Code and JA3. The terms that 
are used for established energy budgets are explained consistent with  definitions and 
JA3.  
Necessity: These changes are necessary to clarify and make specific how energy 
budgets are calculated. These changes align with language that is used other sections 
of the Energy Code.  
  
 
Section:  Section 110.2(a)  
Specific Purpose: Update Table reference and include reference to federal minimum 
efficiency requirements.  
Necessity: Several efficiency tables were deleted so the reference to Tables 110 -2-A 
through Table 110.2 -N was updated to Tables 110.2 -A through Table 110.2 -L. Where 
the federal minimum efficiency requirements were the same as the 2022 version of 
ASHRAE 90.1, the table references federal minimum requirements. If the entire table 
references federal minimum requirements, these table was removed. Where the 2022 
version of ASHRAE  90.1 was different from existing federal minimum requirements, the 
2022 version of  ASHRAE 90.1 efficiencies were identified. These were located in Table  
 110.2 -F Electrically Operated Variable Refrigerant Flow (VRF) Air Conditioners 
Minimum Efficiency Requirements, and Table 110.2 -H DX -DOAS Units, Single Package 
and Remote Condenser – Minimum Efficiency Requirements. The CEC  is identifying 
these efficiencies to capture associated energy savings before these efficiencies are 
federally adopted.  
  
Section : 110.2(b)  
Specific Purpose: The purpose of this change is to identify the requirement for 
supplementary heater controls for heat pumps in single family buildings described in 
Section 150.0(h) 7. This alteration is to provide clarity and distinction in heat pump 
control requirements between single -family buildings and other building types, such as 
non-residential and multifamily buildings.  
Necessity:  The necessity for the proposed amendment to Section 110.2(b) is to provide 
specificity in heat pump controls for single -family buildings . This amendment is crucial 
for identifying and delineating the essential requirements for supplementary heater 
controls in the context of heat pumps within single -family dwellings.  
 
Section:  110.2(b) Exception 3  
Specific Purpose:  The purpose of this change is to provide an exception to the 
requirement disallowing supplementary heater use when heating loads can be met by 
heat pumps in cases where heat pumps are meeting requirements in 150.0(h)7 or 
150.0(i)2.  
Necessity:  The addition of this exception is necessary to ensure that the requirement 
disallowing supplementary heater use when heating loads can be met by heat pumps 
does not interfere with requirements that supplementary heaters have a cutoff 
temperature of 35°F. The clarification in this exception is needed for achieving the 
desired functionality and reliability of heat pump systems across varying environmental 
conditions.  
 
Section: Section 110.2(e) Open and Closed -Circuit Cooling Towers  
Specific Purpose: The revisions to this section will remove the option for flow -based 
controls, specifies water parameters for blowdown controls in a new table, and adds 
testing requirements by reference to NA 7.5.18.  
Necessity: Requirements are included to reduce water usage of open and closed -
circuit cooling tower systems. Flow based controls can result in blowdown of cooling 
towers before appropriate parameters are met. Additional testing requirements are 
included to ensure tha t the blowdown controls are working properly as faulty controls 
have previously been shown to increase water usage. Expanding water parameters also 
ensures that cooling towers operate effectively, reducing maintenance and degraded 
energy perform ance. These requirements for blowdown controls will reduce excessive 
unnecessary water use as directed by California Public Resources Code Sections 
25402 . Energy usage is expected to remain unchanged.  
 
Section : Table 110.2 -A-1  
 Specific Purpose: This table was added to provide the minimum parameters for 
cooling tower blowdown.  
Necessity: Cooling towers are required to replace water within the system due to build 
up of different particulates during operation. Table 110.2 -A-1 provides the value for 
different cooling tower water properties that should be reached before cooling tower 
blowdown occurs. This ensures that water in the cooling tower is not replaced before it 
is necessary. This will result in less water used by the cooling tower and reduction in 
water consumption and associated energy savings at the site.  These parameters are 
consistent with recirculation water properties identified in ANSI/ASHRAE 189.1  and, 
therefore, are necessary to be consistent with industry standards . 
  
Section:  Table 110.2 -A through 110.2 -N 
Specific Purpose: Remove specific numerical federal minimum values  and include  a 
general reference federal minimum value . Tables 110.2 -E, 110.2 -I, 110.2 -J, 110.2 -L, 
and 110.2 -M were removed because they were completely reliant on federal minimum 
values.  
Necessity: Tables 110.2A through 110.2 -N include federal minimum requirements as a 
courtesy to builders. However, due to timing for adoption of federal minimum 
requirements, the values in the table can be out of date causing confusion. Tables that 
are based only on f ederal minimum requirements were removed. Additionally, in tables 
that include both state and federal minimum requirements, the federal value was not 
included.  
 
Section:  Table 110.2 -F 
Specific Purpose: Table 110.2 -G was renamed to Table 110.2 -F to reflect removal of 
tables. Specific federal minimum values were removed because they were completely 
reliant on federal minimum values. Minimum efficiencies reliant on ASHRAE 90.1 were 
updated to reflect minimu m efficiencies as of 01/01/2024.  
Necessity: Table  110.2 -F include federal minimum requirements as a courtesy to 
builders. However, due to timing for adoption of federal minimum requirements, the 
values in the table can be out of date causing confusion. In Table  110.2 -F, the federal 
value was not included. A separate supporting document is expected to be created to 
include these federal required values. This supporting document can be updated as 
necessary if federal requirements change. Additionally, Table 110.2 -F includes 
minimum efficienc y requirements based on ASHRAE 90.1. These minimum efficiencies 
are going to be updated on 01/01/2024. Since the 2025 Energy Code is expected to go 
into 01/01/2026, the minimum efficiencies in Table 110.2 -F were updated to reflect the 
ASHRAE 90.1 minimum efficiencies that would be in effect  on or after 01/01/2024.  
  
Section:  Table 110.2 -G 
Specific Purpose: Table 110.2 -H was renamed to Table 110.2 -G to reflect removal of 
tables. Specific federal minimum values were removed because they were completely 
reliant on federal minimum values. Minimum efficiencies reliant on ASHRAE 90.1 were 
updated to reflect minimu m efficiencies as of 01/01/2024.   
 Necessity: Tables 110.2 -G include federal minimum requirements as a courtesy to 
builders. However, due to timing for adoption of federal minimum requirements, the 
values in the table can be out of date causing confusion. In Table110.2 -G, the federal 
value was not inc luded. A separate supporting document is expected to be created to 
include these federal required values. This supporting document can be updated as 
necessary if federal requirements change. Additionally, Table 110.2 -G includes 
minimum efficienc y requirements based on ASHRAE 90.1. These minimum efficiencies 
are going to be updated on 01/01/2024. Since the 2025 Energy Code is expected to go 
into 01/01/2026, the minimum efficiencies in Table 110.2 -G were updated to reflect the 
ASHRAE 90.1 minimum e fficiencies that would be in effect  on or after 01/01/2024.  
  
Section:  Table 110.2 -H 
Specific Purpose: Update minimum efficiency requirement based on ASHRAE 90.1 
efficiencies.  
Necessity: Efficiency requirements for this equipment has been updated in ASHRAE 
90.1. Table 110.2 -H was updated to align wit h these revised efficiency values.  
Section:  Table 110.2 -I 
Specific Purpose: Table 110.2 -N was renamed to Table 110.2 -I to reflect removal of 
tables. The new table breaks out efficiency requirements for cooling operations.  
Necessity: The table was broken up for ADA purposes. Values were also updated to 
match the most recent version of ASHRAE 90.1. This table specifically focuses on the 
cooling operation requirements.  
  
Section:  Table 110.2 -J 
Specific Purpose: Table 110.2 -J was added and named to reflect removal of tables. 
The new table breaks out efficiency requirements for heat pump requirements originally 
included in Table 110.2 -N.  
Necessity: The table was broken up for ADA purposes. Values were also updated to 
match the most recent version of ASHRAE 90.1. This table specifically focuses on heat 
pump requirements.  
  
Section:  Table 110.2 -K 
Specific Purpose: Table 110.2 -K was added and named to reflect removal of tables. 
The new table breaks out efficiency requirements for simultaneous heating and cooling 
requirements originally included in Table 110.2 -N.  
Necessity: The table was broken up for ADA purposes. Values were also updated to 
match the most recent version of ASHRAE 90.1. This table specifically focuses on 
simultaneous heating and cooling requirements.  
  
Section:  Table 110.2 -L 
Specific Purpose: Table 110.2 -L was added and named to reflect removal of tables. 
The new table breaks out efficiency requirements for heat recovery which would have 
been added to Table 110.2 -N.   
 Necessity: The table was broken up for ADA purposes. Values were also updated to 
match the most recent version of ASHRAE 90.1. This table specifically focuses on heat 
recovery requirements.  
  
Section : 110.3(c)7  
Specific Purpose: The specific purpose of this change is to add mandatory ventilation 
and backup heat requirements to heat pump water heater installation to ensure best 
practice in heat pump water heater installation and energy efficiency.  
Necessity:  Recent field studies and laboratory testing indicated degraded HPWH 
performance and efficiency when they are installed in confined spaced with out 
adequate ventilation . Installation in such condition attribute s to lower evaporator  
temperature and increase of backup electric resistance use , which  results in excessive 
energy use  and lower efficiency than the assumptions in the performance compliance 
calculation . Backup heat is necessary to provide acceptable water heater performance 
in colder climates.  When the inlet air temperature is below the HPWH compressor 
cutout temperature, HPWH without backup heat cannot produce more hot water, which 
can le ad to unacceptable occupant expe rience  and safety concerns.   
 
Section : 110.4(a)  
Specific Purpose : The specific purpose of this change is to clarify that the mandatory 
requirements shall apply to pool, spa, or pool and spa combinations.  
Necessity :  
These terms ensure and improve the general clarity and internal consistency of the 
Energy Code, providing stakeholders with precise and unambiguous guidelines for 
compliance, while also promoting energy efficiency in pools, spas, or pool and spa 
combinatio ns.  
Section : 110.4(a)1  
Specific Purpose : The specific purpose of this change is to update references to the 
applicable appliance standards by referencing Section 110.1.  
Necessity:   
These terms ensure and improve the general clarity and internal consistency of the 
Energy Code, providing stakeholders with precise and unambiguous guidelines for 
compliance, while also promoting energy efficiency in pools, spas, or pool and spa 
combinatio ns. 
 
  
Section : 110.4(a)3  
Specific Purpose : The specific purpose of this change is clean up existing code 
language for pool heater instructions by removing instruction requirement for pool cover 
based on industry feedback.  
Necessity  The pool cover instruction requirement is outside the scope of a pool heater 
manufacturer is required to know and provide to the consumer. These  changes are 
necessary to ensure and improve the general clarity and internal consistency of the 
Energy Code.   
   
Section : 110.4(a)4  
Specific Purpose : The specific purpose of this change is to remove subsection 4 and 
exception 1 and 2 to Section 110.4(a)4  
Necessity: This language is superseded by the new pool heating equipment language 
in 110.4(c) and therefore is no longer needed. Exception 1 to 110.4(a)4 for listed 
package units is covered under the new Exception 1 to 110.4(c) for portable electric 
spas. Exception 2  to 110.4(a)4 is covered under the new heating source sizing 
requirement under 110.4(a)3.   
  
Section : 110.4(b)1, Table 110.4 -A 
Specific Purpose : The specific purpose of this change is to add applicable appliance 
standard for each heating source type to align with federal and industry standards.  
Necessity: These changes are necessary to align with federal and industry standards, 
are necessary to promote energy efficiency and safety in the use of pool and spa 
heating systems. These terms ensure and improve the general clarity and internal 
consistency of the Energy Code.  
  
Section : 110.4(b)2  
Specific Purpose : The specific purpose of this change is to modify the pipe 
requirement to 18 inches of horizontal or vertical pipe between the pool heater filter to 
the heater or dedicated suction and return lines, or built -in or built -up connections. This 
modification a ddresses industry feedback that the previous requirement of 36 inches is 
excessive.  
Necessity: This change is necessary to be consistent with section 5.4.3 of the 
ANSI/PHTA/ICC -15 2021 Standard for Residential Swimming Pool and Spa Energy 
Efficiency. The updated requirement still provides  enough clearance for future 
installation of solar heating equipment.  
 
Section : 110.4( b)3 & (b)4 
Specific Purpose : The specific purpose of this change is to update numbering of the 
subsection.   
Necessity:   
This is to ensure and improve the general clarity and internal consistency of the Energy 
Code, providing stakeholders with precise and unambiguous guidelines for compliance . 
 
Section : 110.4(c)  
Specific Purpose : The specific purpose of this change is to add new heating source 
sizing requirements for the primary pool heater. This change requires a solar  pool 
heating system, a heat pump pool heater  as the primary heating system , or a heating 
system that derives at least 60 percent of heating energy from on -site renewable or 
recovered energy.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code  
 Sections 25213 and 25402. These additions reduce L ong-term System Cost  and 
Source Energy use via the use of cost -effective solar thermal swimming pool 
applications, properly sized heat pump pool heater, or alternative energy efficient pool 
heating technologies.  
  
Section : 110.4(c) Exception 1  
Specific Purpose : The specific purpose of this change is to support the new heating 
source sizing requirement in 110.4(c). Portable electric spas are not required to to 
comply . 
Necessity: These changes are necessary because portable electric spas are subject to 
regulation under California Appliance Efficiency Standards (Title 20) and are regulated 
separately as a package by the U.S. Department of Energy (DOE). This product has 
been optimize d to perform efficiently through these rulemaking processes. These 
changes are necessary to increase energy efficiency via cost -effective building design 
standards, as mandated by California Public Resources Code Sections 25213 and 
25402.  
  
Section : 110.4(c) Exception 2  
Specific Purpose : The specific purpose of this change is to support the new heating 
source sizing requirement in 110.4(c). Replacements of e xisting pool and/or spa heat 
systems are not required to comply . 
Necessity: This change is necessary because of increased difficulty and cost for 
replacements of existing  pool and/or spa heating systems .  These changes are 
necessary to increase energy efficiency via cost -effective building design standards, as 
mandated by California Public Resources Code Sections 25213 and 25402.  
  
Section : 110.4(c) Exception 3  
Specific Purpose : The specific purpose of this change is to support the new heating 
source sizing requirement in 110.4(c). A pool/and or spa that is heated solely by a solar 
swimming pool or spa heating system without any backup heater are not required to 
comply . 
Necessity: This change is necessary because a pool that relies only on solar heating 
does not consume any energy from utility sources. These changes are necessary to 
increase energy efficiency via cost -effective building design standards, as mandated by 
California Pu blic Resources Code Sections 25213 and 25402.  
  
Section : 110.4(c) Exception 4  
Specific Purpose : The specific purpose of this change is to support the new heating 
source sizing requirement in 110.4(c). A heating system used solely for permanent spa 
in existing building with gas availability is not required to comply . 
Necessity: This change is necessary based on industry feedback. The typical user 
behavior and expectation for permanent spa requires rapid heating in the evening. It is 
more difficult to align the energy efficiency benefit of the requirements in 110.4(c) with 
the typ ical usage pattern for permanent spa only systems.   
   
Section : 110.4(c) Exception 5  
Specific Purpose : The specific purpose of this change is to support the new heating 
source sizing requirement in 110.4(c). A heating system used solely for permanent spa 
in existing building with inadequate solar access is not required to comply .  
Necessity: This change is necessary based on industry feedback. Existing building with 
inadequate solar access preclude the use of 110.4(c)1. The typical user behavior and 
expectation for permanent spa requires rapid heating in the evening. It is more difficult 
to align the energy efficiency benefit of the requirements in 110.4(c)2 and (c)3 with the 
typical usage pattern for permanent spa only systems.  
 
Section: Table 110.6 -B 
Purpose:  Formatted tables to comply with the ADA provisions.  
Necessity:  To meet the ADA provisions.  
  
Section : 110.8(i)2  
Specific Purpose : The specific purpose of this change is clean up existing code 
language for CRRC aged solar reflectance.  
Necessity: These changes are necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code.  
  
Section : 110.8(i)3  
Specific Purpose : The specific purpose of this change is to make sure the updated 
ASTM E1980 with the latest equation is being used  to calculate Solar Reflectance Index 
(SRI).  
Necessity: These changes are necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code.  
 
Section : 110.8( j) 
Specific Purpose : The specific purpose of this relocation is to make sure the 
requirement of Radiant Barrier is not missed.  
Necessity: These changes are necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code.  
 
Section 110.12(a)2  
Specific Purpose: The specific purpose of the change is to replace “pathway” with 
“protocol” in the term “wired or wireless bidirectional communication”, and the change is 
to clarify the demand responsive controls communications. The word “protocol”, 
according to Merriam -Webster Dictionary, means a set of conventions governing the 
treatment and especially the formatting of data in an electronic communication system, 
such as network protocols, whereas the word “pathway” could be understood to be a 
path or a particular way of achieving something. The revised term “wired or wireless 
bidirectional communication protocol” with the word “protocol” conveys a more accurate  
 information about what constitutes as the qualified wired and wireless bidirectional 
communications.  
Necessity: The proposed changes with the usage of the term “wired or wireless 
bidirectional communication protocol” are reasonably necessary to ensure and improve 
the general clarity and internal consistency of the Energy Code . The term “wired or 
wireless bidirectional communication protocol” is commonly used in the field of 
technology and in information and communications industry, whereas the term “wired or 
wireless bidirectional communication pathway” is not commonly used.  
  
Section 110.12(a)4  
Specific Purpose: The specific purpose of the change is to replace “communication” 
with “the demand response signal” and the change is to clarify it is during the scenario 
that the demand response signal is disabled or unavailable that the requirement of 
Section 110.12(a)4 would apply.  
Necessity:  The proposed changes with the usage of the term “the demand response 
signal” are reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code.  The term “the demand response signal” conveys a 
more accurate information about what constitutes as the condition of being disabled or 
unavailable for the demand responsive controls.  
  
Section  110.12(c)  
Specific Purpose: The specific purpose of the change is to specify more accurately 
that the general lighting in the spaces required to meet Section 130.1(b) and 
160.5(b)4B, multilevel lighting controls, shall be controlled with demand -responsive 
lighting controls and to rev ise the illuminance uniformity requirements with reference to 
Section 130.1(b) and 160.5(b)4B  instead of Table 130.1 -A. 
The specific purpose of the change to Section 110.12(c)2 is to replace the phrase “that 
is subject to the requirements” with “in the spaces required to meet” and to delete the 
phrase “and may control additional lighting”. The phrase “may control additional  lighting” 
is an option and not a mandatory requirement and the specific purpose of the change is 
to simplify the language in deletion of the voluntary requirement, “may control additional 
lighting”, from the mandatory code section.  
The specific purpose of the change to Section 110.12(c)3 is to replace the phrase 
“uniform level of illumination requirements in Table 130.1 -A” with “illuminance uniformity 
requirements of Section 130.1(b)”. Since Table 130.1 -A is proposed to be removed, t he 
change is to update the language and to reference the illuminance uniformity 
requirements to Section 130.1(b).  
Necessity: The proposed change to specify more accurately that the general lighting in 
the spaces required to meet Section 130.1(b) is reasonably necessary to improve the 
general clarity internal consistency of the Energy Code.  
The proposed change of Section 110.12(c)2 is necessary to improve the clarity of the 
requirements without changing the mandatory requirements. The proposed change of 
Section 110.12(c)3 is necessary to update the whereabouts of the illuminance  
 uniformity requirements for the demand responsive lighting controls and the applicable 
general lighting to comply with.  
 
  
Section:  110.12(e)  
Specific Purpose :  
The specific purpose of the change is to clarify building spaces already have demand 
responsive lighting controls are required to have demand responsive controlled 
receptacles and to delete Exception 1.  
The specific purpose of the change is to add references to Section 130.5(d) and 
160.6(d) for where the spaces are required to have demand responsive controlled 
receptacles to be installed.  
 Necessity : The proposed change to specify building spaces already have demand 
responsive lighting controls are required to have demand responsive controlled 
receptacles is necessary to clarify it is building spaces but not an entire building for 
meeting the demand responsive controlled receptacles requirements.   
The proposed change to add references to Section 130.5(d) and 160.6(d) to expressly 
specified the spaces that are required to have demand responsive controlled 
receptacles to be installed so that to avoid any confusions for the whereabouts that the 
demand responsive controlled receptacles are required.  
The proposed changes can improve the general clarity and internal consistency of the 
Energy Code.  
  
Section:  110.12(e) Exception 1  
Specific Purpose : The specific purpose of the change is to delete the Exception 1 to 
Section 110.12(e) and the change is to harmonize with the other proposed change that 
clarifies the spaces, not buildings, are required have demand responsive controlled 
receptacles.  
Necessity : The proposed changes to delete the Exception 1 to Section 110.12(e) could 
simplify the code language and the changes are reasonably necessary to ensure the 
language is easier to read and comprehend.  
The proposed changes can improve the general clarity and internal consistency of the 
Energy Code.  
Section : 120.1(c)2A and B  
Specific Purpose : The specific purpose of these non -substantial changes is aligning  
natural ventilation requirements with ASHRAE 62. 1 – 2022 version. These changes 
make clearer  the requirements of different building openings and correctly cites the new 
sections in ASHRAE 62. 1-2022 version which were unaligned previous code cycle.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  This rewording and 
aligning of cit ations ensure  and improves the general clarity and internal consistency of 
the Energy Code . 
   
 Section : 120.1(c)2, 120.1(c)2D, Exception 1 to Section 120.1(c)2D, Exception 2 to 
Section 120.1(c)2D  
Specific Purpose : The specific purpose is to move the mechanical ventilation 
requirements from Section 120.1(c)2 to Section 120.1(c)2D  for better clarity of the 
requirements of mechanical ventilation even with a natural ventilation design approach.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. Previous cycles there 
have been misinterpretation that mechanical ventilation was not a requirement when 
using natural ventilation. Moving the requirement from the body of the intro text to this 
section into the listed requirements below make this requirem ent clearer. Additionall y, 
this new term ensures and improves the general clarity and internal consistency of the 
Energy Code  
 
Section : 120.1(c)3  
Specific Purpose : The specific purpose of these changes is to revert the language to 
align with 2019 Building Energy Code  ventilation logic. The exception that was added in 
2022 Building Energy Code was intended to clarify this section, but instead had remove 
this ‘greater than logic ’ for ventilation.  
Necessity: These changes reintroduce the equations and  that ‘greater of ’ comparison 
but does not change the ventilation rates from previous cycles. This prevents designers 
from taking an exception  to only use a designed occupancy when previous cycles 
designed occupancy method and area method had to be compared for the larger 
ventilation rate.  
Section : 120.1(d)4E  
Specific Purpose : The specific purpose of these changes is to align with the changes 
made to the minimum ventilation section 120.1(c)3 and Table 120.1 -A. This increases 
clarity of the requirements for minimum ventilation which has been an issue for the last 
two code cycles.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. These changes allow 
the designer to  understand why the ventilation rates are at specific values which 
improves the general clarity and internal consistency of the Energy Code.  
 
 
Section : 120.1(d)5  
Specific Purpose : The specific purpose of these changes is to make clear the 
requirements of this section without changing stringency  and to follow similar format of 
previous in in 120.1 .  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. In the previous code  
 cycle designers are seeming to avoid this requirement where the requirement language 
is in the intro body of this section. Moving from the intro body into a list format improves 
compliance by showing the requirements explicitly.  
 
 
 
Section : 120.1(f)1  
Specific Purpose : The specific purpose of this change is to modify the language for 
clarity without changing the intent.  
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section : 120.1(g)  
Specific Purpose : Updated to the latest ASHRAE 62.1 sections.  
Necessity : These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous, enabling non -technical readers to easily locate 
and comprehend the technical requirements  
  
  
Section : Table 120.1 -A 
Specific Purpose : The specific purpose of these changes is to align the table with the 
California Mechanical Code and the revision to the minimum ventilation rates in 
120.1(c)3.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. This change allows 
designers to see  the comparison of ventilation rates between the area method or person 
method which has been a confusion among the industry since the change went into 
effect in 2019. This reverts back to 2016 using a greater than equation and provides 
more tran sparency in the ventilation rates and these changes are not intended to affect 
the current minimum ventilation requirements.  
  
Section : Table 120.1 -B and Table 120.1 -C 
Specific Purpose : The specific purpose is to align with the table updates provided in 
ASHRAE 62. 1 – 2022 version. These changes make clearer of new space requirements 
for air classification and minimum exhaust which allows the Energy Code to align with 
new table references in ASHRAE 62. 1-2022 version which were unaligned previous 
code cycle.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  This rewording and 
aligning of cit ations ensure  and improves the general clarity and internal consistency of  
 the Energy Code as directed by California Government Code Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section: 120.2(b)4 – Exception 1 – Edited for clarity   
  
Specific Purpose : The specific purpose of this change is to modify the language for 
clarity without changing the intent.  
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section:  120.2(i)8  
Specific Purpose:  
The purpose of this change is to clarify that the CEC  does not certify FDD systems but 
only accepts specific third -party certifications.  
Necessity:  
This change is necessary to clarify the role of the CEC  in accepting manufacturer 
certifications of FDDs.  
  
Section : 120.2(l)  
Specific Purpose : The specific purpose of this change is to add mandatory 
requirements to limit hot water supply temperature to no greater than 130 °F for HVAC 
space -conditioning systems. These changes intend to save energy by reducing pipe 
distribution energy loss.  This  new measure will be required in newly constructed 
buildings  as well as additions and alterations.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as mandated by California Public Resources Code 
Sections 25213 and 25402. This requirement helps save energy by reducing the energy 
used to generate hig her temperatures and piping distribution energy losses.  
  
Section: 120.3(a) General Requirements  
Specific Purpose: The purpose of this change is to add process heating system piping 
and process cooling system piping to the list of piping conditions where pipe insulation 
requirements are applicable. This will extend existing insulation requirements identified 
in Section  120.3 to covered process heating and cooling systems.  
Necessity: Currently there are no piping insulation requirements for covered process 
heating and cooling pipes. Extending existing insulation requirements for pipe insulation 
will reduce energy loss from hot and cold pipe distribution systems serving covered 
processe s. These additional requirements for insulation to heating and cooling 
distribution pipes will reduce excessive energy uses as directed by California Public 
Resources Code Sections 25213 and 25402.  
  
Section: 120.3(c) Insulation Thickness   
 Specific Purpose: The purpose of this change is updating  references to Table 120.3 -A. 
Necessity: The original Table 120.3 -A was revised into Table 120.3 -A1 and 120.3 -A2 
for ADA purposes. References to the original Table 120.3 -A were updated to reflect this 
change.  
  
Section: Table 120.3 -A Pipe Insulation Thickness  
Specific Purpose: Table 120.3 -A was broken up into two tables, Table 120.3 -A1 and 
Table 120.3 -A2. Table 120.3 -A1 and Table 120.3 -A2 were revised to add process 
heating system piping in the list of insulation requirements associated with space 
heating and service water heati ng. Additionally, process cooling system piping was 
added in the list of insulation requirements associated with space cooling systems. 
These additions extend insulation requirements to covered process distribution systems 
piping.  
Necessity:  
Tables 120.3 -A was broken up into two table to better meet ADA requirements. 
Extending insulation requirements to covered process system piping will reduce energy 
usage in covered process facilities. By using the existing Tables an additional table did 
not need to be added in Section 120.6. These additional requirements for insulation to 
heating and cooling distribution pipes will reduce excessive energy uses as directed by 
California Public Resources Code Sections 25213 and 25402.  
  
Section: 120.3 Exception 5  
Specific Purpose: An exception has been added for the following components within 
process equipment: Fluid pumps, steam traps, blow -off valves, and piping. These 
components cannot be insulated due to the necessity of access for maintenance 
reasons.  
Necessity: These components located within equipment are not easily accessible for 
installation and maintenance of insulation. Additionally, space constraints within 
equipment and operation of these components limit the effectiveness of insulation. This 
would increas e costs for insulation projects. This exception is necessary due to practical 
capability of installing and maintaining insulation and to ensure and improve the general 
clarity and internal consistency of the Energy Code . 
  
Section: 120.3 Exception 6  
Specific Purpose: An exception has been added for the following components within 
process equipment: Valves, strainers, coil u -bends, air separators with at least 0.5 
inches of insulation, and piping within process equipment. These components cannot be 
insulated due to the necessity of access for maintenance reasons.    
Necessity: These components located within equipment are not easily accessible for 
installation and maintenance of insulation. Additionally, space constraints within 
equipment and operation of these components limit the effectiveness of insulation. 
Minimum insulation  of 0.5 inches will reduce energy loss to the environment. This would 
increase costs for insulation projects. This exception is necessary due to practical  
 capability of installing and maintaining insulation and to ensure and improve the general 
clarity and internal consistency of the Energy Code . 
 
Section : 120.4(g)1  
Purpose : The purpose of this change is to delete field verification and diagnostic testing 
and replace it with acceptance testing.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential duct leakage test to first be 
performed by a certified mechanical ATT and then field verified by an ECC -Rater 
(form erly referred to as a HERS rater ). The change is necessary because this is 
duplicative and redundant as written in the 2022 Energy Code where the duct leakage 
test procedure is the same for both tests. The ATTCP program and the ECC  program 
are both intended to ensur e equipment are installed in compliance with the Energy 
Code. Functional testing in nonresidential buildings is under the scope of the ATTCP 
program. Removing the field verification and diagnostic requirement will reduce 
confusion moving forward on who nee ds to perform the nonresidential duct leakage 
test.  
 
Section:  120.5(a)4  and Exception to Section 120.5(a)4  
Specific Purpose:  
The purpose of these  non-substantive  change s i to include DOAS, HRV, and ERV 
systems  that have a bypass damper subject to 140.4(q)  to be tested under  NA7.5.4  for 
air economizing.  The exception to this testing was added to not include systems that 
are not subject to 140.4(q) to have  a bypass damper .  
Necessity:  
These  non-substantive  change s are necessary to better clarify the requirements in  the 
Energy Code. These testing requirements in NA 7.5.4 mention DOAS, HRV, and ERV  in 
the 2022 Energy Code and these changes help to improve clarity and compliance.  This 
benefits the CEC  by complying with California Government Code 11349 and 11349.1 
and California Code of Regulations title 1, Section 16.  
  
Section: 120.6(a)3D  
Specific Purpose: Minimum specific efficiency requirements have been added to 
reduce energy usage of fan -powered evaporators in refrigerated warehouses. 
Requirements vary based on refrigerant, type of evaporator and cooling purpose to 
ensure that one technology is not penalized or benefited more than another technology. 
Static pressure drop for evaporators was identified to ensure that excessive pressure 
drop does not result in redu ced performance.  
Necessity: This revision is necessary to reduce energy usage in refrigerated 
warehouses by reducing the use of evaporators used to provide cooling to the 
warehouse spaces. Other technologies supporting cooling warehouses, such as fans 
supporting evaporators already h ave efficiency requirements. These additional 
requirements for evaporators will reduce excessive energy uses as directed by 
California Public Resources Code Sections 25213 and 25402 .  
   
Section : 120.6(a)3E  
Specific Purpose : Static pressure drop for evaporators was identified to ensure that 
excessive pressure drop does not result in reduced performance.  
Necessity : This revision is necessary to that the energy savings associated with 
evaporator efficiency requirements are not lost due to increased energy usage from 
pressure drops within a system. These additional requirements for evaporators will 
reduce excessive e nergy uses as directed by California Public Resources Code 
Sections 25213 and 25402.  
  
Section: Table 120.6 -A-2 
Specific Purpose: Add table identifying specific efficiency requirements based on 
equipment. These efficiencies are referenced in Section 120.6(a)3D.  
Necessity: This revision is necessary to reduce energy usage in refrigerated 
warehouses by reducing the use of evaporators used to provide cooling to the 
warehouse spaces. Other technologies supporting cooling warehouses, such as fans 
supporting evaporators already h ave efficiency requirements. These additional 
requirements for evaporators will reduce excessive energy uses as directed by 
California Public Resources Code Sections 25213 and 25402.  
  
 
Section: Exception 2 to Section 120.6(a)4A, Exception 1 to Section 120.6(a)4B, 
Exception 2 to Section 120.6(a)4C, Exception 2 to Section 120.6(a)4G and Exception 2 
to Section 120.6(a)4H.  
Specific Purpose: Add exception for condensing units that meet requirements under 
Title 20.  
Necessity: Original analysis for condenser requirements  in 120.6(a)4 were based on 
standalone condenser equipment that was not part of condenser units. Exception 1 to 
Section(a)4B was added in 2013 to clarify how that specific requirement applies to 
condenser units. This introduced confusion if requirements in  120.6(a)4 applied to 
condenser units as well as standalone condensers. The new exception provides 
clarification to how these requirements apply to condensing units, that condensing units 
covered by Ti tle 20 are excepted from this requirement. This ensures that condensing 
units are covered either by Title 20 or by the Energy Code. The exception was applied 
to 120.6(a)4A, B, C, G, and H, which were condenser requirements included in 2013. 
120.6(a)4D, E, and F were not included as these were not part of the original 
requirements that were analyzed based on standalone condenser equipment.  
 
Section : Table 120.6 -B 
Specific Purpose :  The specific purpose of this change is to modify the language for 
clarity without changing the intent.  
 
Necessity :  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California  
 Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section: 120.6(b)5E Transcritical CO2 Gas Coolers  
Specific Purpose: Update references for gas cooler pressure controls to 120.6(b)1B, 
120.6(b)1C, and 120.6(b)1D.  
Necessity: Section 120.6(b)1A provides specifics for compressor fan operations. These 
specifics do not pertain to gas cooler pressure controls. Gas cooler pressure controls 
are based on ambient temperatures which are described in Section 120.6(b)1B, 
120.6(b)1C, and 120.6(b)1D. Revising section 120.6(b)5E aligns to similar refrigerated 
warehouse requirements in Section120.6(a)8E.  
  
 
Section: 120.6(h)2, 3, and 4  
Specific Purpose: The specific purpose of the change to theses Sections is to 
renumber and clean up the existing code language.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  The existing language in Section 120.6(h)2 got 
removed  and combined with Section 120. 6(h)6 since the new lighting requirements for 
both indoor grows and conditioned greenhouses are aligned.  
 
Section : 120.6(h)5  
Specific Purpose:  
The specific purpose of the change to this Section is to increase horticultural lighting 
efficiency for indoor growing and greenhouse lighting systems.  
Necessity:  
This change is necessary to increase energy efficiency via cost -effective building design 
standards, as mandated by California Public Reand sources  Code, Sections 25213 and 
25402 et seq.  Lighting efficacy for indoor grows and greenhouses increased to 2.3 from 
1.9 and 1.7 micromoles  per Joule , respectively.  
  
Section : 120.6(k)  
Specific Purpose : The specific purpose of this change is to add mandatory 
requirements for newly constructed commercial  kitchens to have infrastructure to 
support an all -electric cookline. Currently  commercial kitchens  are not required to have 
all-electric infrastructure and retrofit costs are more costly than including them in a new 
build.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as mandated by California Public Resources Code 
Sections 25213 and 25402 . These requirements promote energy efficiency  by ensuring  
infrastructure is installed for when the building owner decides to move forward with an 
all-electric commercial kitchen.  
  
Section : Exception to Section 120.6(k)   
 Specific Purpose:  The specific purpose of this change is to add an exception for 
healthcare facilities since they were not included in the cost benefit analysis. Healthcare 
facilities have multiple kitchen types and schedules and were not included in the scope 
of the propo sal. 
Necessity: These changes are necessary to prevent these requirements from applying 
to healthcare facilities where cost benefit have not been analyzed.  
  
Section: 120.7  
Purpose: The specific purpose of this change is to rename Section 120.7 to “Mandatory 
Requirements for Building Envelope” to make it clear to the reader that the 
requirements found within this section apply to more than just insulation.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
  
Section: 120.7  
Purpose: The specific purpose of this change is to update the subsections include 
within Section 120.7 to include the new requirements of Section 120.7(d) and 120.7(e)  
but striking (c) and adding (e) at the start of the section . 
Necessity: This change is necessary to ensure that the 120.7 requirements for non -
residential and hotel/motel buildings clearly include the requirements contained in 
Sections 120.7(d) and 120.7(e).  
  
Section: 120.7(d)  
Purpose:  The specific purpose of this change is to add a mandatory requirement for 
exterior windows in a newly constructed building to meet a minimum U -factor of U -0.47 
to limit how much window efficiency can be traded away by non -envelope systems.  
Necessity:  A minimum U -factor of U -0.47 is necessary because it ensures that exterior 
windows in newly constructed building perform at a minimum level of performance and 
do not consume a wasteful, or uneconomical amount of energy.  
  
Section: 120.7(e)  
Purpose:  The specific purpose of this change is to add mandatory requirement for a 
vestibule enclosing the main entrance for buildings of a certain occupancy (A, B, E, I, 
and M) with high traffic through their main entrances, so they do not consume more 
energy tha n is otherwise needed to keep occupants comfortable.  
Necessity:  This change is reasonabl y necessary to ensure that buildings with high 
traffic main entrances  limit the amount of air infiltration  through the door , thereby 
reducing the amount of energy needed to condition that space.  These changes are 
necessary to increase energy efficiency via cost effective building design standards as 
mandated by California Public Resources Code Sections 25213 and 25402.  
   
Section:  130.0 (a) 
Specific Purpose : The specific purpose of this change is to remove the note as 
reference the language for clarity without changing the intent.   
 Necessity : The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section:  130.0 (b) 
Specific Purpose : The specific purpose of this change is to remove the note as 
reference the language for clarity without changing the intent.  
Necessity : The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section 130.1(a)  
Specific Purpose: The proposed change is to rename the term as “manual controls” 
(previous term “manual area controls”) and the other term as “enclosed space” 
(previous term “area enclosed by ceiling partitions”). The change to rename the term of 
Section 130.1(a)1, the sect ion title and other lighting section locations that have the 
usage of the previous terms. Both terms are used in the national energy model code, 
IECC and using similar terms can provide a code language widely available to read and 
compreh end.  
The third proposed change is to clarify Section 130.1(a)2, to consolidate Exception 1 as 
part of Section 130.1(a)2, and to remove the Exception. The change can provide a code 
language easier to read and comprehend.  
Necessity: The change to use the terms, “manual controls” and “enclosed spaces” can 
provide an easier read to readers who may use both the IECC and California Energy 
Code. The name changes do not alter the mandatory requirements of the section for 
providing manual co ntrols for the mandated locations.  
The change to clarify and revise Section 130.1(a)2 is reasonably necessary to provide 
more concise language that can be easier to read and are less burdensome to 
comprehend.  
The changes improve the general clarity and internal consistency of the Energy Code.  
 
Section 130.1(a)1: Exception to 130.1(a)1  
Specific Purpose: The proposed change is to rename the term as “spaces” (previous 
term “areas”) and the change is to harmonize the usage of both terms, “spaces” an d 
“enclosed space”  in Section 130.1(a). The change to the use of term “enclosed space” 
has been provided with its specific purpose and necessity in the other part of this ISOR 
document.  
Necessity : The change to use the term “spaces” is to harmonize the usage of both 
terms, “spaces” and “enclosed space”  in Section 130.1(a) and to improved clarify and 
ensure consistency of the Energy Code.   
 The name changes do not alter the mandatory requirements of the section for providing 
manual controls for the mandated locations. The changes improve the general clarity 
and internal consistency of the Energy Code.  
  
Section 130.1(a)2: Exception 1 to 130.1(a)2  
Specific Purpose: The proposed change is to delete Exception 1 - the exception 
contains a list of spaces deemed to have the manual controls located outside of the 
controlled space.  
Necessity:  The change to delete Exception 1 is reasonably necessary to provide a 
code language easier to read and comprehend.  Section 130.1(a)2 already allows 
spaces that are not appropriate to have the manual controls inside the controlled space 
to be located outside the controlled space. Removal of the exception with the long list of 
spaces would eliminate the redundant languag e of the exception and would provide a 
code language easier to read and comprehend.  
The changes improve the general clarity and internal consistency of the Energy Code.  
  
Section 130.1(b)  
Specific Purpose: The proposed change is to rename the term as “enclosed space” 
(previous term “enclosed area”). The term is used in the national energy model code, 
IECC and using similar terms can provide a code language widely available to read and 
comprehend. proposed ch ange to section 130.1(b) includes consolidating the controls 
requirements of Table 130.1 -A, Subsection 130.1(b)1 and 130.1(b)2 to Section 130.1(b) 
and to the remove Table 130.1 -A. The requirements and to provide “continuous 
dimming from 1 0-100 percent” are retained and moved to be part of Section 130.1(b). 
The continuous dimming from 10 -100 percent is retained as continuous dimming 
requirement is applicable to LED light sources, which is the widely adopted and in use 
in all commercial and nonresidential lighting applications. The controls requirements for 
fluorescent lamp as light sources are not proposed to be retained as a California law 
(AB-2208) bans the sales and distribution of fluorescent lamps as a new manufactured 
product after 202 4 and 2025 – banning screw and bayonet base type compact 
fluorescent (CFL) lamps after January of 2024 and banning pin -base type CFL) and 
linear fluorescent lamps after January of 2025. The requirements to maintain 
“illuminance uniformity” is removed and i s not required for meeting the multilevel lighting 
control requirements.  
Necessity: These changes are reasonably necessary to ensure the usage of the same 
term “enclosed space” can provide an easier read to readers who may use both the 
IECC and California Energy Code. The name changes do not alter the mandatory 
requirements of the section  for providing multilevel lighting controls for the mandated 
locations.  
The changes to revise and consolidate the requirements of Section 130.1(b), including 
removal of Table 130.1 -A and consolidation of subsection 1 and subsection 2 as part of 
Section 130.1(b), are reasonably necessary to provide more concise language that ca n 
be easier to read and are less burdensome to comprehend.   
 The changes to repeal the uniformity requirements for multilevel lighting controls are 
necessary as the term “illuminance uniformity” in Section 130.1(b) is not the same as 
“illuminance uniformity” used by lighting industry. Illuminance uniformity in illum inating 
engineering refers to the ratio of maximum to average illuminance or the ratio of 
average to minimum illuminance over the practical work surface within a space that 
receives illuminance. Reducing the light level in the space is inherently changing the 
illuminance of the controlled space at each controlled level of the multilevel lighting 
controls. The change is necessary as it would provide flexibility for the practitioners to 
meet the Illuminating Engineering Society’s (IES) recommended maintained illuminance 
targets including illuminance uniformity and to ensure the requirements of Section 
130.1(b) can be met without having to meet a seemingly competing or conflicting 
illuminance uniformity requirement.  
The change to clarify and revise Exception 1  
The changes improve the general clarity and internal consistency of the Energy Code.  
  
 
Section  130.1(b): Exception 1 to 130.1(b)  
Specific Purpose: The proposed change is to clarify the Exception about the enclosed 
space that has only one luminaire and to revise that as long as there is only one 
luminaire in the space , it is not required to comply with the multilevel lighting controls 
requirements. The change is to clarify the requirements related to LED light source 
technology and LED luminaires that they are widely adopted and in used in all 
commercial and nonresident ial lighting applications and LED light sources are not in the 
form factor of lamps.  
Necessity : The change to clarify and revise the Exception about the enclosed space 
that has only one luminaire is reasonably necessary to address the new form factor of 
LED light source technology and LED luminaires. The changes improve the general 
clarity and inte rnal consistency of the Energy Code.  
  
Section  130.1(b): Exception 4 & 5 to Section 130.1(b)  
Specific Purpose: The proposed change is to add two new Exception s, Exception 4  & 
5.  
Necessity : The change to add two new Exception s, Exceptions 4 & 5 is necessary to 
address the scenario where the light source of HID and induction may still be used for 
meeting the multilevel lighting control requirements. The changes improve the general 
clarity and internal consistency of the Energy Code.  
  
Section : 130.1(c)  
Specific Purpose: The specific purpose is to move the means of egress illumination as 
an exception to Section 130.1(c) and to revise with word changes to improve the 
readability of the language. The change to move the means of egress illumination as an 
exception to Section 130.1(c) is that the means of egress illumination is a life safety 
requirement taking precedence to the shut -off controls requirement. The editorial 
changes include ad ding the phrase “continuous illumination” so that it reads “continuous  
 illumination of up to 0.1 watts per square foot in any area designated for egress within a 
building is allowed” and revising the phrase “as defined in the California Building Code” 
(was “as the term is used in the California Building Code”).  
Necessity:  The editorial changes is to clarify the allowance of continuous illumination 
for the means of egress illumination and to state it more accurately that the term “means 
of egress illumination” is defined in the California Building Code. The change is 
necess ary as the means of egress illumination is a life safety requirement taking 
precedence to the shut -off controls requirement.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
  
Section : 130.1(c)1  
Specific Purpose: The specific purpose is to clarify time delay requirement of occupant 
sensing controls and the change is specify the control time -delay setting is no more 
than a 20 -minute time delay.  
The other specific purpose is to clarify separate shutoff control zones are required for 
each space exceeding 5000 square feet and the change is to revise the term as 
“separate control zones” (was “separate controls”).  
Necessity : The proposed change to specify the time -delay setting of occupant sensing 
controls is to clarify the time -delay setting required under Section 110.9 also applies to 
the occupant sensing controls specified under Section 130.1(c). This is reasonably 
necess ary to include the time -delay setting requirements in this portion of the code so 
that this important information related to energy and cost savings from using the 
occupant sensing controls is readily available for readers to comprehend the code 
requirements.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
  
Section : Exception 2 to 130.1(c)1  
Specific Purpose: The specific purpose is to update the list of sections for which lighting 
in compliance with each section is not required to comply with Section 130.1(c)1 in 
order to reflect the changes within the shut -OFF controls section of Section 130.1(c). 
The change is to remove Section 130.1(c)7 from the list and to add Section 130.1(c)6E 
and “lighting in stairwells and common area corridors” located  in hotel/motels to the list.  
Necessity : The change to the list of sections in the exception (Exception 2 to Section 
130.1(c)1) is to reflect other changes within the shut -OFF controls section of Section 
130.1(c). The change is necessary to ensure consistency and correctness of the code 
languag e. 
  
Section : Exception 3 to 130.1(c)1 (Exception 3 in the 2022 Code)  
Specific Purpose : There are several proposed changes affecting emergency lighting 
and means of egress illumination. The specific purpose is to move means of egress 
exception from Section 130.1(c)1 to  Section 130.1 (c); the change is to clarify the 
exception  applies to all shut -off controls not just to subsection 130.1(c)1.   
 Necessity : The change is reasonably necessary to clarify by using the phrase 
“separate control zones” to convey the same control system can be used to control a 
space larger than 5,000 square feet as long as each control zone is designated for a 
space not exceeding 5,000  square feet.  
  
Section : Exception 4 to 130.1(c)1  
Specific Purpose : The specific purpose is to clarify what is considered to be “lighting 
equipment designated for emergency lighting” and the change is to delete the phrase, 
“connected to an emergency power source or battery supply”, from the Exception to 
Section 130.1(c)1 . 
Necessity : The change to delete the phrase, “connected to an emergency power 
source or battery supply”, is to harmonize between California Energy Code and 
California Electrical Code about lighting equipment designated for emergency lighting. 
California Electrical C ode specify how emergency systems including emergency lighting 
and “lighting equipment that is designated for emergency lighting” to be connected to 
emergency source. The change to delete the phrase could avoid any confusions about 
which codes to comply with about the connection requirements of emergency lighting.  
  
Section  130.1(c)3 and 4  
Specific Purpose : The specific purpose is to clarify the automatic time -switch control 
requirements by removing  of the phrase “other than an occupant sensing control” from 
Section 130.1(c)3 and 130.1(c)4.  
- The removal of the subsection 130.1(c)3A.   
Necessity : The change to remove the permissive phrase “other than an occupant 
sensing control” to avoid  over-burdensome language and the removal is not altering the 
mandatory automatic time -switch control requirements. The change is necessary to 
produce code language easier to read so that what is not required to meet the 
automatic time -switch requirements is specified in an exception.  
The change to remove subsection 130.1(c)3A is to remove the redundant language 
about meeting Section 130.1(a) as all occupant sensing controls including automatic 
time-switch controls are required to meet Section 130.1(a).  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
  
Section  Exception 2 to 130.1(c)3  
Specific Purpose : The addition of a new exception to the automatic time -switch control 
requirements. The exception is for areas where occupant sensing controls are installed.  
Necessity : The change to add a new exception for areas where occupant sensing 
controls are installed is to clarify that the installation of occupant sensing controls would 
eliminate the obligation to comply with  the automatic time -switch installation 
requirements.   
  
Section  Exception 1 to 130.1(c)4   
 Specific Purpose : The re -arrangement of the phrase “Automatic holiday shut -OFF 
features are not required” to the front of the sentence. The deletion of the word 
“associated” from the term “associated malls”.  
Necessity : The changes about the automatic holiday shut -off features of automatic 
time-switch control is to clarify with an emphasis the exception is about the automatic 
holiday shut -off features so that the code requirements are easier to read and 
comprehend. The change to delete the word “associated” is to clarify the exception is 
applicable to all malls, not just associated malls.  Further, the change is to avoid any 
confusions arising from using the term “associated malls” as it is unclear about what 
“associated” is being referred to.  
  
Section  Exception 2 to 130.1(c) 4  
Specific Purpose : The proposed change is to add a new exception for “areas where 
occupant sensing controls are installed .” 
Necessity : The change is necessary to produce easier -to-read code language that 
establishes an exception  to the automatic time -switch control requirements.  
 
Section  130.1(c)5  
Specific Purpose : The specific purpose is to delete the phrase “of any size” from the 
term “ classrooms”, the term “conference rooms” , and the term “restrooms”.  
The other purpose is to add “and in restrooms” to the regulation about “areas not 
required by Section 130.1(b) to have multi -level lighting controls” and to add “automatic 
full-on” to the regulation about occupant sensing controls that are “in areas not re quired 
by Section 130.1(b) to have multi -level lighting controls”.  
Necessity : The change to delete the phrase “of any size” is necessary to delete the 
redundant language as the phrase “of any size” does not add more information about 
the requirement.  
The change to add “and in restrooms” to the regulation about “areas not required by 
Section 130.1(b) to have multi -level lighting controls” is necessary as restrooms are 
excepted  from the multi -level lighting controls requirements as stated in Section 
130.1(b). The change can clarify lighting controls required for restrooms.  The change to 
add “automatic full -on” to the regulation about occupant sensing controls  is necessary to 
the specify the type as there are occupant sensing cont rols other than the automa tic 
full-on type.   
 
Section:  130.1(c)6  
Specific Purpose : The specific purpose is to clarify the subsection heading by adding 
add descriptive words and the change is to add “warehouse” to qualify the term “aisle 
ways”, to revise the term as “warehouse open areas” (was “open area”) and to add 
“parking  garages, parking areas, and loading and unloading areas” to the subsection 
heading. Another change is to delete the phrase "in addition to complying with Section 
130.1(c)1.”  
Necessity : The change to clarify the subsection heading with addition of space types 
required for occupant sensing controls is to provide guidance for readers of the affected  
 space types by the occupant sensing controls requirement . The change to delete the 
phrase "in addition to complying with Section 130.1(c)1” is to remove the phrase as it is 
already a mandatory requirement for all indoor lighting controls, including this section 
(Section 130.1(c)6 and 7) to comply with Section 13 0.1(c)1.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
  
Section:  Exception 1 to 130.1(c)6A  
Specific Purpose : The specific purpose is to clarify the occupant sensing controls 
requirements of warehouse open areas and warehouse aisle ways  and the change is to 
delete the Exception 1 to Section 130.1(c)6A. The requirement of Section 130.1(c)6A 
already specifies to reduce lighting power by at least 50 percent and the Exception 1 is 
only repeating the requirements of Section 130.1(c)6A. The ot her change is to 
renumber the remaining exception.  
Necessity : The change to delete the Exception 1 to Section 130.1(c)6A is necessary 
since LED light source technology which is widely available to be installed for general 
lighting applications including those for warehouse and LED light source s are  capable to 
be reduced of its lighting power beyond 40 percent . The exception is no longer 
necessary for commonly used light sources in warehouses from the past such as metal 
halide light sources and high -pressure sodium light sources . For those occasions  that 
may still use metal halide or high -pressure sodium light sources, Exception 2 serve as 
the provisions for meeting Section 130.1(c)6A.   
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.   
Section  130.1(c)6D  
Specific Purpose : The specific purpose is to add requirement for occupancy sensor 
control zones in offices greater than 250 square feet to be shown on plans and the 
occupancy sensor control zone information is essential information to communicate 
across various parties incl uding designers, installers, building officials and acceptance 
testing agents for showing compliance to the occupancy sensing controls in offices 
greater than 250 square feet.  The change is to add the requirement to Section 
130.1(c)6Di.  
The other specific purpose is to clarify the occupant sensing controls lighting power 
reduction level and to revise with the phrase “to no more than 20 percent” (was “by at 
least 80 percent”) in Section 130.1(c)6Dii.  
Necessity : The change to require occupancy sensor zones to be shown on plans is to 
ensure this essential information is documented for showing compliance to the 
requirements and can be readily communicated across various parties including 
designers, installers, build ing officials and acceptance testing agents and the occupancy 
sensing controls.   
The change to use the phrase “to no more than 20 percent” is to use the same phrase 
in another subsection and using the same phrase can ensure consistency in the code 
language and to provide a code easy to understand.   
 The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  130.1(c)6C  
Specific Purpose : The specific purpose is to consolidate Section 130.1(c)6C and 
Section 130.1(c)7A into one subsection for the occupant sensing controls requirements 
of stairwell and corridor, so that all the occupant sensing controls requirements of 
stairwell and corrido rs (including those that provide access to guestrooms of 
hotel/motels) are contained in Section 130.1(c)6C. The change is to add “lighting in 
stairwells and common area corridors that provide access to guestrooms of 
hotel/motels” to Section  130.1(c)6C and to add that the lighting shall meet requirements 
of this section (Section 130.1( c)6C) instead of complying with Section 130.1(c)1. Lastly, 
the change is to delete Section 130.1(c)7A.  
Necessity : The change to delete Section 130.1(c)7A is to consolidate the code sections 
about the occupant sensing controls requirements of stairwell and corridor so that the 
code is concise and easy to understand. “Stairwells and common area corridors that 
provide access to guestrooms of hotel/motels” of Section 130.1(c)7A can be classified 
as “corridors and stairwells” Section 130.1(c)6C. The occupant sensing controls 
requirements of Section 130.1(c)6C are similar to the occupant sensing controls 
requireme nts of Section 130.1(c)7A that they are both about requiring occupant sensing 
controls to reduce the lighting power by at least 50 percent when the space or area is 
unoccupied.  
The minor differences between Section 130.1(c)7A and Section 130.1(c)6C are detailed 
as follows.  
- Occupant sensing controls of Section 130.1(c)6C are required to be the partial -
OFF or full (full -OFF) type,  whereas the occupant sensing controls of Section 
130.1(c)7A are required to be the partial -OFF type. The effect of moving the 
regulated spaces (stairwells and common area corridors that provide access to 
guestrooms of hotel/motels) to be under Section 130 .1(c)6C would be an 
increase of compliance choice of using partial -OFF or full (full -OFF) occupant 
sensing controls for meeting the requirements of Section 130.1(c)6C.  
- Also,  the occupant sensing controls of Section 130.1(c)6A allows the lighting to 
be partially off when the space is unoccupied,  and this is similar to Section 
130.1(c)7A.  
- The “lighting in stairwells and common area corridors that provide access to 
guestrooms of hotel/motels” is not required to comply with Section 130.1(c)1. 
This requirement is retained in the new Section 130.1(c)6C for the “lighting in 
stairwells and common  area corridors that provide access to guestrooms of 
hotel/motels”.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
   
 Section  130.1(c)6E, 130.1(c)7B and 130.1(c)7  
Specific Purpose : The specific purpose is to move the occupant sensing parking space 
requirements - for parking garages, parking areas and loading and unloading areas - to 
a new subsection, Section 130.1(c)6E, which is within Section 130.1(c)6. The 
requirements of Section 130.1(c)7B not to comply with Section 130.1(c)1 is retained by 
including the phras e “that meet the requirements below instead of complying with 
Section 130.1(c)1” as part of Section 130.1(c)6E - for parking garages, parking areas 
and loadi ng and unloading areas.  
The other specific purpose of the change is to relocate  the subsection  (the classification 
of indoor lighting as appliable to interior areas of parking garages and the classification 
of outdoor lighting as applicable to parking areas on the roof of a parking structure ) from 
Section 130.1(c) 7B to here (Section 130.1(c) 6E. The change does not alter the 
mandatory requirements of occupant sensing controls for the parking garages, parking 
areas and loading and unloading areas covered by Section 130.1(c)6E.  
The other change is to delete Section 130.1(c)7B and 130.1(c)7.  
Necessity : The change to move Section 130.1(c)7B to Section 130.1(c)6E is to reduce 
one less subsection so that the code can be more concise and easier to navigate and 
comprehend.  
The change to clarify the classifications applicable to interior areas of parking garages 
and parking areas on the roof of a parking structure is to avoid any confusions arising 
from the interpretation of parking garages and parking structures for meeting the 
occupancy sensing controls requirements of Section 130.1(c)6E.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code.  
  
Section : 130.1(d)  
Specific Purpose : The specific purpose of the changes is to revise and update the 
daylight responsive controls (also known as automatic daylighting controls) 
requirements of Section 130.1(d) in consideration of the proposal measure (Docket 
document TN#251803, Docket Number 22 -BSTD -01) and with the following changes.  
- To change the section title and the term “automatic daylighting controls” to 
“daylight responsive controls” throughout Section 130.1(d) and other parts of the 
Part 6, California Energy Code. The change is to use the term “daylight 
responsive controls” to mat ch the closely similar term of the national energy 
modal code, IECC.  
- To reduce the general lighting wattage trigger threshold from 120 watts to 75 
watts for skylit daylit zones, primary sidelit daylit zones, and secondary sidelit 
daylit zones to the daylight responsive controls requirements (was “Automatic 
daylighting control s” requirements). Also, the change is to add specified 
language for the code -triggered thresholds of general lighting within skylit daylit 
zones, general lighting within primary sidelit daylit zones and general lighting 
within secondary sidelit daylit zo nes. Further, Exception 3 is revised with wattage 
level of the general lighting luminaires in the secondary sidelit daylit zone for  
 which daylight responsive controls are not required for the secondary sidelit 
zone.  To add a new numbering for locations that shall comply with the daylight 
responsive controls requirements and that are based on the proposed general 
lighting wattage trigg er thresholds.  
- To move the daylight responsive control requirement for parking garages in 
Exception 4 to the main body of Section 130.1(d). The change it to produce the 
code easier to navigate and comprehend.  
- To clarify the daylight responsive controls requirements for long general lighting 
luminaires and the manner that the long general lighting luminaires can be 
controlled for the daylight responsive controls. The change to Section 130.1(d)2 
is to replace the  term “linear LED and other solid -state lighting (SSL) light 
sources” with “general lighting luminaires longer than 8 feet” and to revise the 
daylight responsive controls requirement as “general lighting luminaires longer 
than 8 feet shall be controlled as  segments of 8 feet or less according to the type 
of the daylit zone in which the segment is primarily located”. Allowing general 
lighting luminaire of segments to be up to 8 feet long for meeting the 
requirements would address the likely cost impacts from  using linear luminaires 
of short segment – as linear luminaires typically come in 8 -feet segment.  
- To clarify the daylight responsive controls shall adjust the lighting thru continuous 
dimming. The change to Section 130.1(d)3A is to delete the control type with 
stepped controls and to add the allowance of multilevel controls to adjust the light 
level.  The change is to specify the daylight responsive controls with continuous 
controls in order to align with the ubiquitous usage and installation of LED 
luminaires.   
- To add a new subsection 130.1(d)6, “interactions with other lighting controls”. 
This change is to retain the requirements of Section 130.1(f) related to daylight 
responsive controls (was “Automatic Daylighting Controls”).   
Necessity : The proposed changes to revise and update the daylight responsive 
controls are reasonably necessary as the changes have been demonstrated to be 
technically feasible and cost effective on the docket document (Docket document 
TN#251803, Docket Number 22 -BSTD-01). The reorganization of the text with new 
numbering and other changes with the sign -post language are reasonably necessary to 
provide a code language easy to read and comprehend. The proposed change to revise 
the requirements for long genera l lighting luminaires and the controls manner are 
necessary to lessen unnecessary cost burden of any unnecessary luminaire segments 
shorter than 8 feet. The proposed  change to add a subsection of “interactions with other 
lighting controls” are reasonably necessary to retain the controls interactions 
requirement from the proposed -to-be-deleted language of Section 130.1(f). The 
proposed changes are reasonably necessary to ensure the general clarity and internal 
consistency of the Energy Code . 
   
 Section: 130.1(f)  
Specific Purpose: The specific purpose of the change is to remove the language about 
the manner of a lighting control in interaction with other lighting controls - they are not 
necessary given there are already requirements in 130.1 and 110.9 about mandatory 
indoor lighting  controls. Still, the controls interactions language of automatic daylighting 
controls is retained and moved to the daylighting section (the daylight responsive 
section), and the requirements about occupancy sensing controls as permitted to be 
used in the space -conditioning systems are retained and kept in the section.  
The specific change is to delete Section 130.1(f) except Section 130.1(f)9 and to 
rephrase the section title to “Occupancy Sensing Controls Interactions with Space -
conditioning Systems”. The numbering of the subsection is also removed as it is not 
needed.  
Necessity: This change to delete a set of code language that serve as clarifications for 
lighting controls interactions is necessary to remove redundancy to the requirements 
already in Section 130.1and 110.9 about lighting controls.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code.  
 
Section:  Table 130.1 -A 
Specific Purpose:  The proposed change is to delete Table 130.1 -A. The multilevel 
lighting controls requirements are specified in the body of Section 130.1(b) and 130.1 -A 
is no longer needed to repeat the requirements.  
Necessity:  The change to delete Table 130.1 -A is reasonably necessary to provide 
more concise language that can be easier to read and are less burdensome to 
comprehend.  
  
Section : Exception 8 to 130.2(b)  
Specific Purpose : The specific purpose of the change is to add a new exception for 
luminaires that qualify as exceptions in Part 11 of Title 24 and in Section 140.7(a). This 
is to harmonize the exceptions of the two codes, Part 6 and Part 11 of Title 24.  
Necessity : This change to add a new exception for luminaires that qualify as 
exceptions is necessary to harmonize between Part 6 and Part 11 of Title 24 for the 
backlight, uplight and glare requirements for outdoor luminaires.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section  130.2(c)2  
Specific Purpose: The specific purpose of the change is to clarify the outdoor lighting 
power reduction level of the automatic scheduling controls requirements. The change is 
to add “partially” to the phrase “reducing the outdoor lighting power” and to revise the 
phrase “by  at least 50 percent and no more than 90 percent” as “by 50 to 90 percent”.  
Necessity: This change to clarify the outdoor lighting power reduction level could help 
code users to comprehend the outdoor lighting power reduction level required for the  
 automatic scheduling controls requirements and to avoid confusions of the phrase “no 
more than 90 percent” in the 2022 Energy Code.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section: 130.2(c)3A  
Purpose: The specific purpose of the change is to consolidate the subsection i within 
Section 130.2(c)3A as one article of Section 130.2(c)3A.  The change is to add the 
outdoor locations (including general hardscape, parking lots, and outdoor canopies, 
outdoor sales lots, vehicle service station hardscape, service station canopies, sales 
canopies, and non -sales canopies) required for motion sensin g controls to Section 
130.2(c)3 and to add the phrase “and for which the bottom of the luminaire is mounted 
24 fe et above grade or lower”.  
The other change to the section is to delete the permissible code language about 
motion sensing controls may be installed in combination with other outdoor lighting 
controls. The change to delete the permissible requirement does not change other 
mandatory requirements of the section.  
Necessity: The change to consolidate the subsection i within Section 130.2(c)3A and to 
add the list of outdoor locations required for motion sensing controls is to produce a 
code with more concise language so that the code is easier to navigate and 
comprehend.  
The change to delete the permissible code language are reasonably necessary to 
ensure conciseness and improve clarity of the Energy Code . 
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section 130.2(c)3Aii   
Purpose : The specific purpose of the change is to repeal the motion sensing controls 
requirement of bilaterally symmetric outdoor wall mounted luminaires (“wall packs”) 
providing building façade, ornamental hardscape or outdoor dining. The change is to 
delete Sec tion 130.2(c)3Aii and to add “luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining” to Exception 2 to Section 130.2(c)3.  
The change is to delete the permissible requirement about motion sensing controls 
does not change other mandatory requirements of the section and provide a more 
concise code language for code users to comprehend.  
Necessity : The change to repeal the motion sensing controls requirement of bilaterally 
symmetric outdoor wall mounted luminaires (“wall packs”) providing building façade, 
ornamental hardscape or outdoor dining is to amend the situation where motion sensing 
controls  are inappropriate for the lighting applications of façade lighting, ornamental 
hardscape lighting and outdoor dining lighting.   
The changes are necessary as luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining are different from wall pack luminaires for  
 illuminating building edge parking, walkways, building perimeter identification, entry and 
exit and security.  
Wall pack luminaires is described as “lighting equipment that is typically attached to a 
building wall or other vertical exterior surface and that provides illumination for building 
edge parking, walkways, building perimeter identification, entry and exit and security”. 
(“BBA High Efficiency Wall Pack Lighting Specification & Guidance”, A Better Buildings 
Alliance (BBA) Project, page 1.) (Link: 
https://betterbuildingssolutioncenter.energy.gov/sites/default/files/attachments/high -
efficiency -wall-pack -specification.pdf  ) 
Luminaires providing lighting for building facades serve both functionally and 
decoratively to aim at the façade and to illuminate the façade without obstruction or 
interference. As such, façade luminaires are different from wall pack luminaires.  
Ornamental hardscape lighting is not wall packs and ornamental hardscape lighting is 
defined in the Energy Code as lighting and luminaires installed outdoor and are rated 50 
watts or less that are post -top luminaires, lanterns, pendant luminaires, chandeliers,  and 
marquee lighting.  
Luminaires providing lighting for outdoor dining serve the outdoor eatery and associated 
hospitality activities and the luminaires does not serve the same purpose as wall pack 
luminaires provided, including illumination for parking, walkways, perimeter, 
identification entry and exit security.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section: 130.2(c)3B  
Purpose: The specific purpose of the change is to clarify the outdoor lighting power 
reduction level of the motion sensing controls requirements. The change to Section 
130.2(c)3B is to add “partially” to the phrase “reducing the outdoor lighting power” and 
to revis e the phrase “at least 50 percent and no more than 90 percent” as “50 to 90 
percent”.    
Necessity: The change to clarify the outdoor lighting power reduction level could help 
code users to comprehend the outdoor lighting power reduction level required for the 
automatic scheduling controls requirements and to avoid confusions of the phrase “no 
more than 90 percent” in the 2022 Energy Code. The change is necessary to produce a 
code language easy to read and comprehend.  
   
Section: 130.2(c)3  - Exception 2 to 130.2(c)3  
Purpose: The change is to add “luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining” to Exception 2 to Section 130.2(c)3.   
Necessity: The changes are necessary as luminaires providing lighting for building 
façade, ornamental hardscape or outdoor dining are different from wall pack luminaires 
for illuminating building edge parking, walkways, building perimeter identification, entry 
and ex it and security.   
 The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section  130.4(a)  
Specific Purpose : The specific purpose of the change is to add “Section 120.6(h)5B” 
for the indoor and outdoor lighting controls serving the building, area or site to comply 
with the section and be certified as meeting the acceptance requirements specified by 
the Referenc e Nonresidential Appendix NA7.6 and NA7.8.  
Necessity : The proposed change to add “Section 120.6(h)5B” is necessary to retain the 
requirements of Section 120.6(h)5B for CEH horticultural lighting that time -switch 
lighting controls to comply with Section 130.4(a)4. The proposed change is reasonably 
necessary to ensure and improve the general clarity and internal consistency of the 
Energy Code.  
  
  
  
 
Section: 130.5(d)2  
Specific Purpose: The specific purpose of the change is to clarify the placement of 
controlled receptacle and uncontrolled receptacle at the same location. The specific 
change is to replace the word “splitwired” with “multiple” in the phrase so that the phrase 
reads “multip le receptacle”. The term “multiple receptacle” is defined in California 
Electrical Code, whereas the term “splitwired receptacle” is not.   
Necessity: The proposed change of using the term “multiple receptacle” is to avoid any 
confusions of the term, “splitwired receptacle”. The term “multiple receptacle” is defined 
in the California Electrical Code as two or more contact devices on the same yoke or 
strap, and the term is a more accurate term to be used in Section 130.5(d)2 for the 
scenario where there are two contact devices. The proposed change is also reasonably 
necessary to ensure and improve the general clarity and internal consistency of the 
Energy Code and to ensure and improve the consistency of the Energy Code . 
  
Section: 130.5(d)3  
Specific Purpose: The specific purpose of the change is to delete the word “durable” 
from the part of the marking requirements of controlled receptacle.  
There is no other requirement about the “durable marking requirement of controlled 
receptacles in the Energy Code.  
Necessity: The California Electrical Code requires controlled receptacles to be 
permanently marked, and aligning with the requirements of California Electrical Code 
that controlled receptacles should be permanently marked with the symbol and the word 
as specified in the Electrical Code. The change is necessary to ensure the Energy Code 
and the Electrical Code are in harmony on the marking requirement of controlled 
receptacles.  The proposed change is reasonably necessary to ensure and improve the 
consistenc y of the Energy Code with other provisions of law.   
 The proposed change to repeal part of the marking requirements of controlled 
receptacles is reasonably necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
  
Section:  130.5(d)4  
Specific Purpose : The specific purpose of the change is to revise the time -out period 
of the controlled receptacle controls from “30 minutes” with ‘20 minutes”. The change is 
to align the time -out period to switching off the controlled receptacle in hotel and motel 
guest rooms during vacancy to the time -out period of occupant sensing controls 
specified in Section 110.9(b)4.  
Necessity : The proposed change to revise the time -out period of the controlled 
receptacle requirements is to align the time -out period to switching off the controlled 
receptacle in hotel and motel guest rooms during vacancy to the time -out period of 
occupant sensin g controls specified in Section 110.9(b)4. The proposed change is 
reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code.  
Section:  130.5(d)  
Specific Purpose : The specific purpose of the change is to remove the word “note” and 
move the requirement stating that plug -in strips and plug -in devices cannot be used to 
comply with the requirements of Section 130.5(d) to the beginning of Section 130.5(d).  
Necessity : The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code.  
 
Section : 140.1  
Specific Purpose : The specific purpose of these change s is to clarify that energy 
budgets for nonresidential buildings are now expressed in terms of Long -Term System 
Costs in section 140.1(a). Obsolete language stating that energy budgets are expressed 
in Time Dependent Evaluation and Energy Design Ratings is deleted. Inaccurate 
sections 140.1(b) and 140.1(c) indicating that energ y budgets are separately 
established for the standard design building and the proposed building are eliminated. 
Explanation of how the energy budget is calculated for the standard design building 
using Commission -certified compliance software is stated clearly and succinctly in 
section 140.1, and the redundant section 140.1(c) is eliminated.  
Necessity: These changes are necessary to update the new methods for how the 
energy budget is to be calculated  and provide the terms to be used for establishing 
energy budgets. These changes align  with language that has the same purpose in 
sections 140.1, 150.1(b) and 170.1.  
  
 
 
 
Section: Exception 1 and 2 to 140.3(a)1Aia   
 Purpose:  The specific purpose of this change is to clarify that when meeting Exception 
1 or Exception 2 then the user is not required to comply with Section 140.3(a)1Aia.  
Previous language was deleted since it would otherwise be redunda nt. 
Necessity:  This change is necessary to ensure the exceptions in this section are clear 
and unambiguous to readers. This change improves the general clarity and internal 
consistency of the Energy Code  by adding explicit language  of what i s “not required to 
comply with” Section 140.3(a)1Aia and thus deleting the previous language  that had 
similar intent , as directed by California Government Code, Section 11349 and 11349.1, 
and California Code of Regulations, Title 1, Section 16.  
  
Section:  Exception to Section 140.3(a)5A  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved,  and the correct reference is 
now Section 120.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code  for conditioned greenhouse building envelope . The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 . 
 
Section:  Exception 1 to Section 140.3(a)5 B 
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
 
Section: Exception 2 to Section 140.3(a)5C  and Exception 1 to Section 140.3(a)6B  
Purpose:  The specific purpose of this change is to correct a misspelling of the word 
from “lower -rate“ to lower  rated.”  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 3 to Section 140.3(a)5C  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed  
 revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 120.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section: Exception 3 to Section 140.3(a)5D  
Purpose:  The specific purpose of this change is to correct a misspelling of the word 
from “higher rate “ to “higher rated .” 
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 4 to Section 140.3(a)5D  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 2 to Section 140.3(a)6A  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 2 to Section 140.3(a)6B  
 Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change  
 is reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 2 to Section 140.3(a)6D  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 2 to Section 140.3(a)6 C  
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  Exception 2 to Section 140.3(a)6E   
Purpose:  The specific purpose of this change is to update the section reference. The 
2022 Energy Code correctly references Section 120.6(h)4, but with the proposed 
revision to the 2025 Energy Code this language has moved, and the correct reference is 
now Section 1 20.6(h)3.  
Necessity:  This change is necessary to ensure that correct section is referenced within 
the Energy Code for conditioned greenhouse building envelope. The proposed change 
is reasonably necessary to ensure and improve the general clarity and internal 
consistency of th e Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section: Table 140.3 -B Roofs/ Ceilings  
Purpose:  The specific purpose of these changes is to increase the energy efficiency of 
the building ’s exterior  walls by reducing the prescriptive U -factors of Metal Building  and 
Wood Framed and Other,  roofs/ceilings. A more efficient building envelope results in 
less energy being consumed by space conditioning systems, which leads to energy 
savings and increased energy efficiency.   
 Necessity:  The proposed modifications aim to enhance the energy efficiency of 
roofs/ceilings in newly constructed nonresidential buildings while simultaneously 
demonstrating cost savings for the building owner. These adjustments align with the 
mandated cost -effectiv e building design standards outlined in the California Public 
Resources Code, specifically Sections 25213 and 25402 . 
  
Section: Table 140.3 -B Walls.  
Purpose:  The specific purpose of these changes is to increase the energy efficiency of 
the building ’s exterior  walls by reducing the prescriptive U -factors of Metal Building, 
Mass Light, Mass Heavy, and Wood Framed and Other, exterior walls. A more efficient 
building envelope results in less energy being consumed by space conditioning 
systems, which leads to energy savings  and increased energy efficiency.  
Necessity:   The proposed modifications aim to enhance the energy efficiency of walls  
in newly constructed nonresidential buildings while simultaneously demonstrating cost 
savings for the building owner. These adjustments align with the mandated cost -
effective building design standards outlined in the California Public Resources Code, 
spec ifically Sections 25213 and 25402 . 
 
  
Section: Exception 1 to Section 140.3(c)  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: Exception to Section 140.3(d)2H  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
  
Section: Exception 3 to Section 140.4(a)1  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 140.4(a)2E, F, and G  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
   
 Section: Exception 1 to Section 140.4(a)2  
Purpose: The purpose of deleting the exception to Section 140.4(a)2, which pertains to 
systems utilizing recovered heat for space heating, is to ensure that all applicable 
systems adhere  to the new requirement for mechanical heat recovery  Section 140.4(r).  
Necessity: Deleting the exception to Section 140.4(a)2, specifically concerning systems 
utilizing recovered heat for space heating  prioritize s the optimization of energy usage in 
space heating systems  that implement  mechanical heat recovery .  This is necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
 
Section: 140.4(a)3  
Purpose: The purpose of adding the section titled "  Multizone zone space -conditioning 
system types  " to Title 24, Part 6 is to establish specific and tailored requirements for 
space conditioning systems in office buildings and school buildings not otherwise 
covered by Section 140.4(a)2.  
Necessity: This is necessary to address the energy and operational requirements 
inherent in office and school buildings and to establish clear, targeted requirements for 
these building types.  Which are specif ied in more detail  below.  
  
Section: 140.4(a)3A  
Purpose: The inclusion of specific requirements for space conditioning systems in 
office buildings serves the purpose of advancing energy efficiency and occupant 
comfort. The emphasis is on system features such as variable refrigerant flow, 
dedicated outdoor air systems, and heat recovery systems enhancing both energy 
efficiency and indoor air quality. Additionally, the inclusion of demand -controlled 
ventilation (DCV) and parallel fan pow ered terminal units in specific climate zones 
further contributes to t he overall goal of reducing energy consumption and promoting 
sustainable practices in office buildings.  
Necessity: The proposed additions are necessary to provide a clear and standardized 
framework for compliance . The California prototypical  medium office building adhere to 
standards distinct from those outlined in 140.4(a)2 due to  its unique operational and 
construction  requirements.  A medium office has  features outlined in the Energy Code 
that d efines  the building envelope, lighting systems, systems, and other energy -
consuming components  separate from those outlined in 140.4(a)2. These adjustments 
align with the mandated cost -effective building design standards outlined in the 
California Public Resources Code, specifically Sections 25213 and 25402  
 
Section:  140.4(a)3B  
Purpose:  Purpose is to establish a purposeful and tailored approach to space 
conditioning systems, recognizing the unique requirements of educational facilities by 
prescriptively specifying the use of heating through a hot water loop served by an Air -to-
Water Heat  Pump (AWHP), compliant with Section 140.4(a)3C.   
 Necessity:  This language is necessary to descri be a reasonable  space heating system 
for use in large schools and buildings.  The use of 4 -pipe fan coil systems for hydronic 
heating provides  flexibility , control , and  has been found by staff to be cost effective . 
These hydronic  systems provide a versatile solution that can adapt to the requirements 
of different zones within a large school  building .  The proposed additions are necessary 
to provide a clear and standardized framework for compliance. The documents relied 
upon for this rulemaking show the proposed efficiency standards to be technically 
feasible for buildings in California, cost effective w here they are proposed to be 
required, and likely to save significant energy on an annual statewide basis.  
 
Section: 140.4(a)3C  
Purpose: The purpose of stipulating a minimum heating Coefficient of Performance 
(COP ) at specific outdoor temperatures is to mandate the use of AWHPs that 
demonstrate high efficiency in colder conditions, contributing to reduced energy 
consumption and operational costs. The requirement to maintain the  water temperature 
above the hot water loop's design supply temperature will ensure  effectiveness of the 
heating system while prioritizing occupant comfort. These regulations establish a 
comprehensive and effi cient framework for AWHP space -heating hot water loops, 
promoting energy conservation, sustainability, and the reliable operation of heating 
systems.  
Necessity: The necessity for these regulations is to provide a clear, standardized, and 
efficient framework for AWHP space -heating hot water loops.  Reducing the energy 
usage of space heating systems  will reduce excessive energy use as directed by 
California Public Resources Code 25213 and 25402.  
  
Section: 140.4(a)3D  
Purpose: The purpose of this section is to establish energy -efficient standards for fan 
systems in office  and school buildings served by multi -zone space -conditioning 
systems . By imposing a maximum power consumption limit of 0.35 W/cfm at their 
design airflow rate, this aims to promote the use of technologically advanced, low -
energy -consuming fans. The requirement for a minimum of three different speeds , as 
well as  the ability to turn off  when ther e is no heating or cooling demand in the space  is 
intended t o enhance user flexibility and comfort, allowing for tailored ventilation 
solutions.  
Necessity:  The necessity for the regulations pertaining to indoor fans establishes a 
stringent energy efficiency standard and promote sustainable practices in building 
ventilation systems. There exists a risk of varying energy consumption levels and 
suboptimal performance among indoor fan  systems, potentially leading to unnecessary 
energy expenditures and environmental impacts.  The mandated limit of 0.35 W/cfm at 
the design airflow rate is essential to ensure that indoor fans adhere to energy -efficient 
parameters, contributing to reduced o verall energy consumption within buildings.  
  
Section: 140.4(a)3E   
 Purpose: The purpose of this requirement is to clarify that space conditioning systems 
subject to  this section must  comp ly with Section 140.4(p) and 140.4(q)  emphasiz ing the 
importance of aligning  Dedicated Outdoor Air Systems  (DOAS ) with comprehensive 
guidelines, consistency, and effectiveness in outdoor air management. The 
incorporation of heat recovery systems supports the overarching goal of energy 
conservation by capturing and repurposing energy that would otherwise be wasted.  
Necessity: The necessity for the regulations governing DOAS within Section 140.4 is 
critical to standardize and optimize the performance of these systems. This section 
establishes a clear and standardized guideline for DOAS in this system with AWHP, to 
ensure complia nce with energy efficiency standards contribute to the objectives of 
energy efficiency.  
 
Section : Exception to Section 140.4(a)3E  
Purpose: The purpose of the exception to Section 140.4(a)3E is to provide specific 
conditions under which deviations from the standard design requirements are permitted . 
This provision stipulates that in such scenarios, Dedicated Outdoor Air System (DOAS) 
heating and cooling functionalities must be facilitated through heat pump coils.  
Necessity : The necessity for this exception is to  ensure that alternative design 
configurations adhere to recognized standards, thereby guaranteeing optimal energy 
performance and operational reliability. This change is necessary to ensure and 
improve the general clarity and internal consistency of the Energy Code, as directed by 
California Government Code, Section 11349 and 11349.1, and California Code of 
Regulations, Title 1, Section 16.  
 
Section: Section 140.4(b)3A, Ai, and Aii   
Purpose: The purpose of this change is to  add an alternative  source of outdoor design 
condition from ASHRAE Handbook Equipment Volume, Applications Volume and 
Fundamental Volume.  ASHRAE Handbook is already used for indoor design conditions 
under Section 140.4(b)2A. As part of this addition, the term 99.0 percent Heating Dry 
Bulb is introduced as an alternative to Heating Winter Median of Extreme. This change 
aligns with similar changes in Section s 150.0 (h)2B  and 160.3(b)2 .  
Necessity: The necessity for this exception is to increase flexibility in mechanical 
system design by allowing commonly used design condition from the ASHRAE 
Handbook.  The addition of “ 99.0 percent Heating Dry Bulb ” is a commonly used industry 
term in the ASHRAE handbook to calculate heating load. This change is necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulati ons, Title 1, Section 16  
 
Section: EXCEPTION to 140.4(c)1  
Purpose:  The purpose of this exception is to clarify that the fan power referenced in  
140.4(c) needs  to meet  the requirements of 140.4( a)3.  
Necessity:  The necessity for this change is to clarify  that fan power budget applies to  
140.4(a)3  and establish clear, standardized, and industry -vetted guidelines for the  
 control sequences of variable air volume systems. This ensures that these systems 
operate efficiently, aligning with recognized best practices and contributing significantly 
to the broader objectives of energy conservation and efficiency.  
 
Section : 140.4(c)2Bi -ii  
Purpose: The changes made to this section included breaking section 140.4(c) 2B into 
two subsection s (i. and ii.)  to further assist  comprehension  of the relevant standards . 
The specific purpose for the removal of the example and instead include a ASHRAE 
Guideline 36 compliance requirement for VAV system .  
   
 static pressure setpoint reset control  in subsection ii ., is to provide readers  with a 
specific reference they can rely upon when configuring  these systems.  
Necessity:    These changes are  necessary  to establish clear, standardized, and 
industry -vetted guidelines for the control sequences of variable air volume systems. 
This ensures that these systems operate efficiently, aligning with recognized best 
practices and contributing significantly to the b roader objectives of energy conservation 
and efficiency.  
 
Section: 140.4(d)2Ai  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 140.4(d)2Av  
Specific Purpose:  The specific purpose of the addition is to include a ASHRAE 
Guideline 36 compliance requirement for space -conditioning zones with Direct Digital 
Controls  (DDC ). 
Necessity:  These changes are necessary to increase energy efficiency via cost - 
effective HVAC controls.  The necessity for this change is to establish clear, 
standardized, and industry -vetted guidelines for the control sequences of space 
conditioning zones with DDC. This ensures that these systems operate efficiently, 
aligning with recognized best practices and contributing signifi cantly to the broader 
objectives of energy conservation and efficiency.  
 
Section: Exception 3 to Section 140.4(d)  
Purpose: The purpose of this change is to modify terminology and eliminate  the use of 
the term "exempt" for clarity  without changing the intent  of the Energy Code . The 
Energy Code establishes unique requirements for Covered Process loads as defined in 
Section 100.1. Exception 3 address es process loads that are not covered process 
loads; using the term non -covered process loads is the simplest and least ambiguous 
way to convey  the intent of  the exception . When particular requirements in the Energy 
Code are not applicable to particular construction situations or equipment for specific 
reasons, the Energy Code does provide exceptions that indicate compliance is not 
required in that instance.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity, provide 
consistency with other exceptions in the Energy Code.  
 
Section: Exception 2 to Section 140.4(e)1  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
 Section : 140.4(e)2D  
Specific Purpose: The specific purpose of this addition is to include the ASHRAE 
Guideline 36 compliance requirement for economizers  when they are controlled by a 
direct digital control (DDC) . Additionally, format changes and related references are 
made to adjust for this addition in the subsequent section s, where previous section D 
becomes E , and the previous section E becomes F . 
Necessity: This addition   is necessary to increase energy efficiency via cost - effective 
HVAC controls by standardizing economizer control s predetermined strategies within 
Guideline 36. The proposed change  address es the complexity of economizers and 
ensure s that their control sequences align with industry -recognized best practices 
outlined in ASHRAE Guideline 36. This contributes to overall energy conservation and 
aligns HVAC economizer systems with the latest advancements and recommended 
practices in the in dustry.  
 
Section : 140.4(f)3  
Specific Purpose: The specific purpose of the addition is to include the ASHRAE 
Guideline 36 compliance requirement for supply air temperature reset controls in 
buildings with automated Direct Digital Controls ( DDC ).  
Necessity: These changes are necessary to increase energy efficiency via cost - 
effective HVAC controls.  The necessity for change is to establish clear, standardized, 
and industry -vetted guidelines for the control sequences of supply temperature reset 
controls in systems with DDC. This ensures that these systems operate efficiently, 
aligning with recognized best practices and contributing significantly to the broader 
objectives of energy conservation and efficiency.  
  
Section: Section 140.4(h)5 , Table  140.4H -2, and Exception 2 to Section 140.4(h)5   
Specific Purpose: These proposed change s update  the cooling tower efficiency 
prescriptive requirements  and includ e a new table,  Table 140.4 H -2, based on climate 
zone. It also removes exceptions for climate zone 1 and 16 previously provided in 
exception 2.  
Necessity: The efficiency of cooling towers is now based on climate zone, where areas 
with higher cooling needs are subject to higher efficiencies. The higher cooling loads 
make it more economically feasible for higher efficiency to be installed. Although the 
excepti on for climate zones were removed, the minimum efficiency actually remains the 
same at the minimum mandatory efficiency of the equipment. Reducing the energy 
usage of cooling towers will reduce excessive energy use as directed by California 
Public Resources Code 25213 and 25402.  
  
Section: 140.4(p)  
Purpose: The specific purpose of this change is to add a missing Oxford comma.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
 Section: Exception 1 and 2 to Section 140.4(q)1  
Purpose: The purpose of this change is to  modify  terminology  for clarity , locate 
exceptions as close as possible to the requirement that is the subject of the exception, 
and avoid the use of the term "exempt" Exception 1 and 2 are providing exceptions to 
one specific provision of Section 140.4(q), namely Section 140.4(q)1. Wit hout the 
change these exceptions currently are designated as Exceptions 4 and 5 to the global 
Section 140.4(q). The exceptions need to be moved to follow the directly applicable 
provis ion (similar to Exception to Section 140.4(q)2). As a result, the current Exception 
6 and Exception  7 to Section 140.4(q) are renumbered to be Exceptions 4 and 5 
respectively,  to Section 140.4(q).  
When particular requirements in the Energy Code are not applicable to particular 
construction situations or equipment for specific reasons, the Energy Code does provide 
exceptions that indicate compliance is not required in that instance. Exceptions 1 and 2 
are rewritten to avoid the use of the term "exempt” and to simply and unambiguously 
state that provisions of Section 140.4(q)1 are not required for specific climate zones.  
Necessity:  These change s are necessary to ensure clarity and avoid ambiguity, 
provide consistency with other exceptions in the Energy Code.  
  
Section : 140.4 (r) 
Specific Purpose: The specific purpose of this addition is to include requirement s for 
HVAC systems with DDC t hat align with use of ASHRAE Guideline 36 programming 
libraries.  HVAC systems with DDC shall use controller logic originating from a 
programming library based on sequences of operation from ASHRAE Guideline 36.  
Necessity: These changes are necessary to increase energy efficiency via cost - 
effective HVAC controls.  The necessity for change is to establish clear, standardized, 
and industry -vetted guidelines for the control sequences in systems with DDC. This 
ensures that these systems operate efficiently, aligning with recognized best practices 
and contributing signif icantly to the broader objectives of energy conservation and 
efficiency.  
 
Section : Exception 1 to Section 140.4(r)  
Purpose: The p urpose  of this exception is to allow for adaptation and customization of 
DDC program  logic not provided by ASHRAE Guideline 36.  
Necessity: The necessity for Exception 1 to Section 140.4(r) is to address diverse 
building applications that may require tailored adaptations beyond the standardized 
sequences outlined in ASHRAE Guideline 36. This exception is essential to 
accommodate the inherent variability in application -specific operations, allowing for the 
modification of logic derived from certified programming libraries to meet unique 
operational needs.  
 
Section : Exception 2 to Section 140.4(r)  
Purpose: Provides an exception to healthcare facilities which is not within the scope of 
ASHRAE Guideline 36 .  
 Necessity : Exception 2 to Section 140.4(r) is necessary to address the unique and 
critical operational requirements of systems serving healthcare facilities not outlined in 
ASHRAE Guideline 36.  
 
Section : Exception 1 to Section 140.4(r) 3 
Purpose: This addition provide s an exception for non -programmable (configurable -
only) controllers designated for zone terminal units. This exception is designed to 
address the specific operational characteristics of non -programmable controllers by 
mandating adherence to applicable ASHRA E Guideline 36 zone sequences, as 
referenced in JA18 Table 18.3 -1, while simultaneously excepting  them from the 
programming library requirement outlined in Section 140.4(r)3.  
Necessity: The necessity for Exception 3 is to align regulations with the functional 
limitations of non -programmable controllers for zone terminal units. This exception 
ensures compliance with industry guidelines, acknowledges the relevance of 
standardized zone seque nces, and adopts a practical approach that facilitates the 
effective utilization of non -programmable controllers within their designated scope of 
operation.  
  
Section : 140.4(s)  
Specific Purpose : The specific purpose of this change is to add prescriptive 
requirements for Mechanical Heat Recovery that have simultaneous heating and 
cooling loads for new buildings to recover energy to be used elsewhere in the building 
and prevent wasteful energy. Ex ception 1 to Section 140.4(s)1 applies to   laboratory 
exhaust systems already meeting covered process requirements for heat recovery and 
Exception 2 for 140.4(s)1 is for climate zone 15 where it was not found to be cost 
effective to incorp orate these heat recovery  standards . Global  Exception 1 to Section 
140.1(s) does not require compliance for computer rooms that already incorporate large 
amounts of heat recovery.  
Necessity: For large buildings that have large simultaneous loads, mechanical heat 
recovery has been found to be cost effective. By requiring new buildings with large 
loads to recover heat , it reduce s wasteful energy and recoup s useful energy for use in 
other parts of the building. These changes are necessary to increase energy efficiency 
via cost effective building design standards as mandated by California Public Resources 
Code Sections 25213 and 25402.  
  
Section : 140.4(s)2  
Specific Purpose : The specific purpose of this change is to add prescriptive 
requirements for Mechanical Heat Recovery that have simultaneous heating and 
cooling loads to include heat recovery for service water heating. Another option is 
added here to use recouped energy to heat service hot water instead of space heating 
in the previous section.  
Necessity : For large buildings that have large simultaneous loads, mechanical heat 
recovery has been found to be cost effective in recouping energy to be used in service 
hot water. In addition, when the building also has a certain capacity of service water  
 heating, using heat removed from a space to heat service hot water has been found to 
be cost effective.  These changes are thus necessary to increase energy efficiency via 
cost-effective building design standards, as mandated by California Public Resources 
Code Sections 25213 and 25402  
  
Section  Exception to Section  140.6(a)  
Specific Purpose : This proposed change delete s the Exception to Section 140.6(a) for 
portable lighting in office areas as there is already a provision in Table 140.6 -C for 
portable lighting in offices.  
The change to delete the Exception for portable lighting for office areas is to avoid the 
wasteful allowance of portable lighting for office areas.   
Necessity : The proposed change to delete the exception of up to 0.3 watts of lighting 
power of portable lighting in offices – the Exception in Section 140.6(a) – is to correct 
the situation of double allowances of portable lighting power in offices – one in the 
Excep tion and another one in Table 140.6 -C of the “Area Category Method ”. The 
change is to ensure the allowed portable lighting power for office areas is accounted 
consistently and the lighting power is not allotted more than one instance for the same 
portable lighting. There is already a provision in Table 140.6 -C for portabl e lighting 
power in office areas. The existence of both provisions - one in Table 140.6 -C and 
another thru the Exception for portable lighting – are duplicates to one another. 
Continued use of the exception would be a wasteful allowance as it would allow t he 
power usage to be counted twice in the calculation of indoor lighting power  and thus not 
otherwise align with energy efficient mandates . 
 
Section : 140.6(a)2Iv  
Specific Purpose: This proposed change clarif ies the Power Adjustment Factors (PAF) 
requirements in Section 140.6(a)2.  The change add s a new subsection of Section 
140.6(a)2I to require that occupancy sensor control zones in offices greater than 250 
square feet be shown on plans. Occupancy sensor control zone information is essential 
information to communicate across various parties including designers, installers, 
building officials and accep tance testing agents to show compliance to the occupancy 
sensing controls in offices greater than 250 square feet.   
Necessity : The change to require occupancy sensor zones to be shown on plans is to 
ensure that this essential information is documented to show compliance with the 
requirements and can thus be readily communicated across various parties including 
designers, installers, building officials and acceptance testing agents and the occupancy 
sensing controls.   
  
 
Section:  140.6(a)2Kii  
Specific Purpose:  This change clarif ies the PAF requirements for the demand 
responsive controls receiving the PAF. The change update s, this section ’s reference of 
the illuminance uniformity requirement to Section 130.1(b) (previously it was Table  
 130.1 -A) and add s a statement in Table 140.6 -A, line 5  clarifying  that the PAF are not 
available to demand responsive controls that are mandated under Section 110.12(c).  
Necessity:  
The change to clarify the PAF requirements for the demand responsive controls are to 
ensure the incentivized PAF provisions are allowed for the proper demand responsive 
controls – those demand responsive controls not mandated under Section 110.12(c).  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
    
Section : 140.6(a )3O  
Purpose : The change here r emove s repetitive language that already exists within the 
scope  of the code.  
Necessity:  These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous.  
 
 
 
Section : 140.6(a), 140.6(b), 140.6(c)  and Table s 140.6 -D through G  
Specific Purpose : The purpose of the se change s is to remove the “Tailored Method ” 
as well as any associated language  from Section 140.6 , including revis ing related 
references, and delet ing Section 140.6(a)4C, 140.6(b)3C, 140. 6(b)3D,140.6(b)4B, 
140.6(c)3 and Table 140.6 -D thru G completely  as these sections and tables are directly 
related to the “Tailored Method ”. This change also includes modifications and removal 
of “Tailored  Method”  associated  language in 140.6 (b)3B  and 140.6(c) 2Gv. 
 
 
.  
 
  
Necessity : The proposed change to remove the “Tailored Method ” is to provide a 
simpler compliance approach through the “Area Category Method ” with similar 
additional lighting power allowances for specific lighting application that requires 
additional lighting.  
The “Area Category Method ”, with Table 140.6 -C (and additional modifications 
explained further below) , is a much more straight forward and less  of a cumbersome 
compliance methodology compar ed to the “Tailored Method ”, which required looking up 
multiple tables, Table 140.6 -D, E, F, and G, for the tailored lighting calculation process. 
With the removal of the “ Tailored Method ”, it is no longer necessary to have Table 
140.6 -D, E, F, and G which holds related information . 
 
Section: Section 140.6(a) 2, Tables 140.6 -A and B    
 Specific Purpose : The proposed change here includes moving Table 140.6 -A and 
Table 140.6 -B to the location immediately succeeding the relevant code language 
mentioning the table. Additional small modifications were made within Table 140.6 -A 
that moved previous points a., b., and c., to the bottom of the Table instead being 
presented first. There are also modifications made to line 2 which adds an addition line 
in the Table.  
Necessity:  The proposed change to move Table 140.6 -A and Table 140.6 -B 
succeeding the code language mentioning the table is to allow readers look up them up 
easier.  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal c onsistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
 
Section  140.6(b)4  
Specific Purpose : The specific change  in this section  adds “wall display, floor display; 
task, or very valuable display case” to the list of lighting power allotments that may not 
be increased or traded off when us ed under the “Area Category Method ”. The other 
change s remove “and feature” from “display and feature”  and make minor formatting  
changes for clarity.   
Necessity : The change to add “wall display, floor display; task, or very valuable display 
case” is necessary to align with what is specified in Table 140.6 -C for the qualified 
lighting systems. The change to specify to remove “and feature” from “display and 
feature ” is necessary to align with what is specified in Table 140.6 -C for display lighting . 
   
Section  140.6(c)2Gviii  
Specific Purpose : The specific purpose of this change  is to specify and to retain  the 
requirement about floor display lighting in the new subsection that floor display  lighting  
shall not qualify for wall display lighting power allowances.  
Necessity : The change to specify the requirement that floor display shall not qualify for 
wall display allowances is necessary so that wall display allowances is used only for 
wall display lighting. The change is also necessary to retain energy code stringency for 
floor display lighting , wall display lighting , and the additional  lighting power allowance 
provided under t he area category method.  
  
Section  140.6(c)2Gix  
Specific Purpose : The specific purpose of this change  is to specify and to retain  a 
requirement in the new subsection regarding  criteria for wall lighting that can be eligible 
for wall display lighting allowance.  The criteria are the same criteria for wall lighting 
eligible  under  the Tailored method  for wall lighting . 
Necessity : The change to specify the qualifying criteria for wall lighting that can be 
eligible for wall display lighting allowance is necessary so that wall display lighting 
allowance is used only for qualified wall lighting.  The change is also  necessary  to retain  
 energy  code stringency for wall display lighting and the additional  lighting power 
allowance provided  under the area category method .  
  
Section  140.6(c)2Gx  
Specific Purpose : The specific purpose of this change  is to include  a requirement in 
the new subsection regarding  criteria for wall display lighting that can be eligible for wall 
display lighting allowance. The other purpose is to specify how to determine the length 
of display walls and permanent full heigh t interior partitions.  
Necessity : The change to specify the qualifying criteria for wall display lighting that can 
be eligible for wall display lighting allowance is necessary so that wall display lighting 
allowance is used only for qualified wall lighting. The change to specify how to 
determine the length of display walls and permanent full heigh t interior partitions is 
necessary so that there is a consistent manner of the determination . The change is also 
necessary to retain energy code stringency for wall display lighting, and the additional  
lighting power allowance provided under the area category method.  
  
Section  140.6(c)2Gxi  
Specific Purpose : The specific purpose of this change is to specify how to determine 
mounting height of the luminaire qualified for additional lighting power allowances in 
Table 140.6 -C. 
Necessity : The change to specify how to determine mounting height of the luminaire is 
necessary so that there is a consistent manner of the determination . The change is also 
necessary to retain energy code stringency for floor display lighting,  wall display lighting, 
and the additional lighting power allowance provided under the area category method.  
  
Section:  TABLE 140.6 -C 
Specific Purpose:  The modifications made to Table 140.6 -C retain the additional 
lighting power allowances of the “Tailored Method” by adding comparable allowances 
for lighting applications to the “Area Category Method”. This change adds additional 
lighting power allowances  under Table 140.6 -C for the following applications:  
- convention, conference, multipurpose and meeting area;  
- dining area – bar/lounge and fine dining;  
- retail sales area – grocery sales; and  
- retail sales area –retail merchandise sales.  
 
The additional lighting allowances added to the “qualified lighting systems” column of 
Table 140.6 -C include lighting applications to the following:  
- wall display of mounting height less than or equal to 10 feet 6 inches;  
- wall display of mounting height between 10 feet 7 inches to 14 feet;  
- wall display of mounting height greater than 14 feet;  
- floor display of mounting height less than or equal to 10 feet 6 inches;  
- floor display of mounting height between 10 feet 7 inches to 14 feet;  
- floor display of mounting height greater than 14 feet;  
- valuable display case; and   
 - general lighting in the enclosed space of ceiling height greater than 10 feet.  
Necessity:  The additional lighting power allowances for the applications (functional 
area types including Convention, Conference, Multipurpose and Meeting Area; 
Bar/Lounge and Fine Dining Area; Main Entry Lobby; Retail Sales Area of Merchandise 
Sales; Retail Sales A rea of Grocery) are retained and added to the “Area Category 
Method” as they are the most heavily used for the “Tailored Method” (in accordance to 
the compliance dataset compiled by a NORESCO team and findings presented on a 
public workshop held on February 24, 2023).  Other function area types (also known as 
“space function”) are reported to have less than five (5) instances for their usage of 
“Tailored Method” in the same compliance dataset – with a total of 521 instances of 
reported usage for “ Tailored Method”.  
The presentations of the public workshop (“Stakeholder Workshop -Round 2 
2023.05.16”) and the compliance dataset findings (page 175 of the docket document) 
can be found in a docket document (Docket document TN#250676, Docket Number 22 -
BSTD -01). These modif ications simplify the standards required in conjunction with 
elimination of the “Tailored Method” standards while assuring that the there are no 
compliance gaps in the methodology’s absence.  
 
Section  Table 140 .6-C  
Specific Purpose : The specific purpose of the change is to  add a note  3 to Table 
140.6 -C about MH that it being denoted as the mounting height of the lighting systems.  
Necessity : The change is necessary to specify the information pertaining to the table  in 
the energy code  so that there is a consistent manner of the determination . 
    
Section: Exceptions to Section 140.7(a)  
Purpose: The purpose of this change is to use unambiguous language and  avoid the 
use of the term "exempt"  for clarity without changing the intent  of the Energy Code . 
When particular requirements in the Energy Code are not applicable to particular 
construction situations or equipment for specific reasons, the Energy Code does provide 
exceptions that indicate compliance is not required in that instance.  This section  has 
been rewritten to avoid the use of the term "exempt” and to simply and unambiguously 
state that provisions of Section 140.7(a) are not required for the following exceptions.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity, provide 
consistency with other exceptions in the Energy Code.  
  
Section  Table 140.7 -B  
Specific Purpose : The specific purpose of the change is to clarify how the additional 
lighting power allowance of specific applications (outdoor lighting) could be applied to 
each site or to each specific lighting applications. The change includes adding the 
following gui dance notes to Table 140.7 -B for various lighting applications listed in 
Table 140.7 -B.  
- “Per application”; or  
-  “PER SITE: WATTAGE ALLOWANCE PER  HARDSCAPE  AREA (W/ft²). May be 
used as additional allowance for applicable illuminated hardscape area on the  
 site.” For lighting applications of security cameras and special security lighting for 
retail parking and pedestrian hardscape.”  
Necessity: The changes are reasonably necessary to clarify how the additional lighting 
power allowance for specific applications could be properly applied to the site or to the 
specific applications. The proposed change once adopted can deliver a code language 
easier  to read and comprehend. The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code  of Regulations, Title 1, Section 16.  
 
Section  140.8(b)  
Specific Purpose: The specific purpose of th ese change s is to remove legacy types of 
light sources f rom the list of compliant sign lighting light sources. The change will 
remove the following light sources from subsection 140.8(b)1,2,4 and 6:  
- high pressure sodium lamps ;  
- metal halide lamps;  
- fluorescent lamps; and  
- compact fluorescent lamps.  
Necessity: The changes are reasonably necessary to update the sign lighting light 
source requirements in order to reflect the current availability of sign lighting light 
sources .   The removed legacy light sources are no longer being  manufactured nor will 
they be  replenished once the current stock runs out. The proposed change is 
reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and Calif ornia Code of Regulations, Title 1, Section 16.  
  
Section: Exception 2 to Section 140.9(a)1  
Purpose:  Removed the term ‘e.g.’ and proceeding language  at the end of subsection ii . 
Also updated the grammatical language for clarity and easy understanding.  
Necessity:  These changes are essential to make sure that the provisions in the 
subsection are clear, concise, and unambiguous, enabling non -technical readers to 
easily locate and comprehend the technical requirements.  Removing language that may 
otherwise confuse readers achieves this goal.  
  
Section: 140.9(a)3  
Purpose:  Reformatted the word “air” to bold font to complete subject line for the 
respective regulation.  
Necessity:  The Energy Code follows a specific formatting for subsections. The word 
“air” was bolded to follow this formatting. This is a non-substantive  change made for 
consistency in the Energy Code formatting.  
  
Section: Section 140.9(c)1   
Specific Purpose: This change revises the above referenced requirements to add and 
separate occupied and unoccupied minimum exhaust airflow rate requirements for  
 laboratory exhaust systems. The proposed minimum rates are based on a set minimum, 
rates required for safety or accreditation, or rates needed to meet pressurization, 
whichever is larger. Additionally, airflow reduction requirements will now apply to 
labor atories that have a minimum ventilation rate of 10 air changes or more.  
Necessity: Occupied and unoccupied minimum exhaust airflow rates may differ with 
unoccupied airflow rates typically being lower. The current single minimum airflow rates 
can result in either occupied or unoccupied periods operating at higher than needed 
exhaust rates . Identifying minimum occupied and unoccupied exhaust airflow rates 
ensures that the appropriate airflow rate is used dependent on occupancy condition. 
Applying the airflow reduction requirements to laboratories with ventilation rates of 10 
air changes or more also ensures that a laboratory does not claim a higher ventilation 
rate to avoid the requirement. These revisions to airflow reduction requirements will 
reduce excessive energy use as directed by California Public Resources Code 25213 
and 2 5402.  
  
Section: 140.9(c)1C  
Purpose:  Requirements added to verify the revised airflow reduction requirements.  
Necessity:  New airflow reduction requirements will only result in reduced energy usage 
if the appropriate airflow is implemented during construction. Verification requirements 
are included to compare the proposed design airflow rates against the airflow rates 
implem ented in the building project.  
 
Section: 140.9(c)1C  
Purpose:  Remove exception 1 to 140.9(c)1.  
Necessity:  The exception for lab exhaust syste ms serving authority having  jurisdiction, 
facility environmental health and safety department, or other applicable codes  are now 
included within the code language under 140.9(c)1Aii and 140.9(c)1Bii. This would 
make the exce ption redundant.  
      
Section: Section 140.9(c)3  
Specific Purpose: Extensive edits have been made to the is section. The proposed 
changes update the outdated 2012 ANSI Z9.5 reference to the current 2022 version. 
Section  140.9(c)3B  adds the option for a laboratory exhaust fan system to meet fan 
power requirements provided under Section 140.4(c)1A and 140.4(c)1B. Options for 
wind based and contaminant -based  controls were included in revised language. These 
changes also a dd an option for simple turndown control system s to existing wind 
responsive and monitor ed control systems.  Reference ANSI Z9.5 (2022) Appendix 3 for 
definitions of simple turndown, wind responsive, and monitored control systems are 
added  and specific language that was previously included in the Energy Code was 
removed  as the reader is now pointed to ANSI Z9.5 (2022) Appendix 3 . 
Necessity: Existing code requirements referenced 2012 versions of ANSI Z9.5 and 
updating to 2022 ANSI Z9.5 will keep California in line with national practices. Similarly, 
referencing Appendix 3 of ANSI Z9.5 2022 will align CEC  simple turndown, wind 
responsive and monitored control systems with national practices to simplify designs of  
 laboratory exhaust systems to meet different code requirements. Allowing laboratories 
to meet fan power requirements under Section 140.4(c)1A and 140.4(c)1B, which 
typically result in lower fan powers, provides designers with additional flexibility. These 
revisions to laboratory fan system power consumption provides additional flexibility that 
will perform equivalent to existing options . 
  
Section: Section 140.9(c)5  
Specific Purpose: These proposed changes add prescriptive requirements to limit 
space conditioning systems for laboratory spaces in buildings with greater than 20,000  
cfm that first cool air at the handler and then reheat air when it reaches the zone.  
Necessity: A new reheat limitation will prevent excessive use of energy from reheating 
space conditioning air . Exceptions are provided specifically for systems where 
humidification can affect laboratory spaces, allowing for cooling and reheating to control 
humidity. Including reheat limitation requirements will reduce excessive energy use as 
directed by California  Public Resources Code 25213 and 25402 . 
  
Section : Exceptions 1 -4 to Section 140.9(c)5  
Specific Purpose: Adds exceptions for additions and alterations, specific climate 
zones, and vivarium spaces. Exceptions provided for specific space uses and to ensure 
that humidity does not negatively affect the space.  
Necessity: Exceptions for additions and alterations were provided due to the added 
costs of replacing existing HVAC equipment to meet requirements in section 140.9(c)5. 
Exceptions for climate zones were included due to humidity concerns that may arise at 
these specif ied conditions  specifically allowing for cooling and reheating to control 
humidity . Exception 4  was included for humidity and safety requirements of the 
specified laboratory use.  
  
Section: Section 140.9(c)6  
Specific Purpose: The proposed changes add prescriptive requirements for exhaust 
air heat recovery for laboratory spaces. This includes energy recovery ratio 
requirements, and system specifics to support disabling of heat recovery when not 
needed.  
Necessity: Exhausting air results in energy used to condition this air to the outside 
environment and additional energy is used in the process of  condition ing the  makeup 
air. Including exhaust air heat recovery requirements for laboratory spaces will amend 
this issue  by using some of the energy used to condition the air being ventilated  to 
condition the incoming makeup air . Additionally, requirements for disabling heat 
recovery will ensure that the exhaust systems continue to operate effectively and safely 
even when heat recovery is not necessary. Including heat recovery requirements will 
reduce excessive energy use as direc ted by California Public Resources Code 25 213 
and 25402.  
  
Section: Exceptions 1 -5 to Section 140.9(c)6   
 Specific Purpose: The proposed changes add exceptions for additions and alterations, 
and specific building conditions  to the new exhaust air heat recovery standards 
mentioned above.  
Necessity: Exceptions for additions and alterations were provided due to the added 
costs of replacing existing HVAC equipment to meet requirements in section 140.9(c)6. 
Exceptions were also provided for conditions where the heat recovery requirements in 
140.9(c)6 are  not expected to result in sufficient reduction in energy usage for the 
measure to be cost effective.  
  
Section : 140.10(a)  
Specific Purpose: The purpose of the proposed changes to this section  is to clarify and 
reduce compliance ambiguity by establishing a specific calculation for determining the 
Photovoltaic System  (PV) requirement when solar access roof area (SARA) is limited. 
The calculation provide s separate requirements for buildings with steep -sloped roofs 
and for buildings with low -sloped roofs. Additionally , other  modifications to the section 
language  were made to provide further c ompliance clarity  and/or correct grammatical 
errors.  These additions correct the language in the current Energy Code that does not 
provide a definitive means to determine the PV requirement.    
Necessity: These changes are necessary to ensure reliable reductions in wasteful, 
uneconomic, inefficient, or unnecessary consumption of energy as directed by California 
Public Resources Code Sections 25213 and 25402. This change is necessary to ensure 
and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
 
Section : 140.10(a) 1C 
Specific Purpose: The proposed changes to the section clarify, make specific , and 
reduce administrative burden  in specific  instances where SARA is reduced . This section  
is clarified and is made  more specific by separately addressing compliance with other 
state building codes as a reason for roof area to not be available , or compliance with 
local building codes if confirmed by the Executive Director (ED).  
Necessity: These changes are necessary to improve clarity and specificity and reduce 
administrative burden.  They are needed to make clear that compliance  with state 
building codes would not require ED confirmation , while  compliance with local building 
codes would continue to require ED confirmation.  
 
Section : Equation 140.10 -A and Table 140.10 -A  
Specific Purpose: The purpose of the proposed changes to the equation and the table 
is to revise the PV Capacity Factors used in Equation 140.10 -A is to establish the size 
of the PV systems required for the 2025 Energy Code. The PV system size 
requirements are increased or clarified for building categories for which there are PV 
requirements in the 2022 Energy Code or are established for the first time for additional 
building categories. Increased or new PV requirements reduce building energy  
 consumption, thereby reducing energy bills . The CEC update s the Energy Code  on 3-
year code cycles to reduce as much energy consumption as possible for the state.   
Necessity: These changes are necessary to reduce the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy as directed by California Public 
Resources Code Section 25402.  
 
Section : Section 140.10(a) - Replacement of Exception 5  
Specific Purpose: The purpose of the proposed change is to provide  an exception for 
nonresidential and hotel/motel tenant spaces in multi -tenant buildings that is appropriate 
and consistent with  the CPUC’s Virtual Net Billing Tariff (VNBT) and Net Billing Tariff 
(NBT) rules . Community solar continues to be an alternative to the on -site PV system 
requirements of 140.10(a), as described in the exception to 140.1(a).  
Necessity: This exception is necessary to not require  small tenant spaces in 
nonresidential and hotel/motel that have limited energy consumption loads on their 
electric utility meter  to meet  the PV requirements because those situations are unlikely 
to be feasible or cost effective.  These changes are necessary to reduce the wasteful, 
uneconomic, inefficient, or unnecessary consumption of energy that the CEC 
determines to be cost effective consistent with California Public Resources Code 
Sections 25402 and 25 402(b)3.   
   
Section: 140.10 (b)  
Specific Purpose:  The purpose of the proposed changes is to revise the approach to 
determining the Minimum Rated Useable Energy Capacity using either Equation 
140.10 -B or 140.10 -C, depending on whether or not solar access roof area ( SARA ) is 
limited , and the Minimum Power Capacity using Equation 140.10 -D. These capacity 
determinations set the requirements for the size of the battery energy storage system 
(BESS) required for each building. The energy storag e system size requirements are 
increased or clarified for building categories for which there are PV requirements in the 
2022 Energy Code or are established for the first time for additional building categories. 
Increased or new  energy storage system  requirements reduce building energy 
consumption.  The section also changes the name to energy storage system from 
battery storage used in the 2022 Energy Code.  As explained previously in this ISOR 
that term was changed to clarify that an operative system has multiple components not 
just batteries  and to match up with use of the BESS term within the industry.  
Necessity: These changes are necessary to reduce the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy as directed by California Public 
Resources Code Section 25402.  Additionally, this new term ensures and improves the 
general clarity and internal consistency of the Energy Code as directed by California 
Government Code Sections 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section : Equations 140.10 -B, 140.10 -C and 140.10 -D and Table 140.10 -B  
Specific Purpose:  The energy storage system kWh sizing equation 140.10 -B and 
140.10 -C has been updated to be a function of conditioned floor area, the capacity  
 factor B, which has been updated as required for cost -effectiveness metrics, using 
Long-term System Cost, in addition to roundtrip efficiency. Equation 140.10 -C has been 
introduced to calculate the energy storage sizing when SARA restricts the PV sizing 
with which the energy storage system will be matched. For Equation 140.10 -D, a factor 
C was included in the equation for the 2022 Energy Code; that factor was merely the 
capacity factor, factor B, divided by 4 to capture the expected time (4 hours) for the 
battery to discharge. The revised equation eliminates factor C and instead is based on 
factor B expressly divided by 4. That clarifies and eliminates unnecessary complexity in 
the equation. T he number of building categories in table 140.10 -B have increased 
consistent with revised cost -effectiveness analysis . The changes to these equations and 
tables contribute directly to reducing building energy consumption as explained for the 
proposed changes to section 140.10(b) above, as well as improving the clarity of  the 
Energy Code.  
Necessity: These changes are necessary to reduce the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy as directed by California Public 
Resources Code Section 25402. Additionally, these changes ensure and improve the 
general clarity and internal consistency of the Energy Code as directed by California 
Government Code Sections 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
 
Section : Exception 3 to Section 140.10(b)   
Specific Purpose: The purpose of the change to this exception is to replace the term 
“battery storage system” with “BESS ( Battery Energy Storage System)” as defined in 
Section 100.1(b). This chang e is necessary to clarify the requirements for the energy 
storage system using consistent terminology through the Energy Code . 
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 . 
   
Section : Exception 4 to Section 140.10(b)  
Specific Purpose:  The purpose of this change is  to be consistent with changes to 
Table 140.10 -B, which has been revised to establish BESS requirements for each 
building type and climate zone. The revised Table 140.10 -B indicates NR (not required) 
for office and school buildings, which is the same result as the existing exception that 
“no battery storage system is required for offices, schools ”. The revised Table 140 -10-B 
establishes for the first time that BESS requirements will be required for Warehouses. 
These changes are based on cost effectiveness analysis completed for the 2025 
Energy Code.  
Necessity : This change is necessary to reduce the wasteful, uneconomic, inefficient, or 
unnecessary consumption of energy as directed by California Public Resources Code 
Section 25402. Additionally, this new term ensures and improves the general clarity and 
internal consistency of  the Energy Code as directed by California Government Code 
Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 .  
  
 
Section: Exceptions 4 through 6 to Section 141.0(a ) 
Specific Purpose: The purpose of these changes is to eliminate the use of the term 
"exempt" for clarity without changing the intent of the Energy Code. When particular 
requirements in the Energy Code are not applicable to particular construction situations 
or equipment for specific reasons, the Energy Code does provide exceptions that 
indicate compliance is not required in that instance.  
Necessity: This change is necessary to ensure clarity and avoid ambiguity, provide 
consistency with other exceptions in the Energy Code.  
 
Section: 141.0(b)1E  
Purpose:  The specific purpose of this change is to add a mandatory requirement for 
exterior windows in altered nonresidential buildings to meet a minimum U -factor of U -
0.58.  
Necessity:  This modification is essential to guarantee that exterior windows in existing 
nonresidential buildings undergoing alterations meet, at a minimum, the performance 
standards of the original windows. The goal is to prevent excessive or uneconomical 
energy co nsumption in the process of enhancing or modifying these windows  to 
maximize building energy efficiency .  
   
Section : 141.0(b)2C to 141.0(b)2Ci , 141.0(b)2Cii  and 141.0(b)2Ciii  
Purpose : The purpose of the changes to this section are to ensure that prescriptively 
installed equipment relies on heat pump technology where feasible and cost effective. 
141.0(b)2C was partially  moved to a new subsection,  141.0(b)2Ci, and a new 
141.0(b)2Cii was created to address the new requirements for new or replacement of 
single zone packaged rooftop systems with a direct expansion cooling. 141.0(b)2Ciii was 
added to delineate specific instances where the prescriptive inclusion of an economizer 
is appl icable. This clarifies that single zone system types with a capacity of less than 
65,000 Btu/hr are to have economizer  and that all single packaged unitary air systems  
from 54,000 Btu/hr and greater are to include an economizer.  
Necessity:  The proposed new requirement of the standards for new or replacement 
space conditioning systems for these building types (small schools, small offices, retail 
and library) to have heat pump technology as the baseline are reasonably necessary to 
reduce and prevent wasteful, uneconomic, inefficient, and unnecessary consumption of 
energy by buildings, consistent with the statutory direction in Public Resources Code 
Section 25402 . The documents relied upon for this rulemaking show the proposed 
efficiency standards to be technically feasible for buildings in California, cost effective 
where they are proposed to be required, and likely to save significant energy on an 
annual statewide basis.  
 
Section:  Exception 1 to 141.0(b)2C  
Specific Purpose:   This exception exempts existing buildings from the heat pump 
requirements of 140.4(c)2. The exception was deleted , and i t was relocated to  
 Exception 1 to Section 141. 0(b)2C . The exception also added an exemption to 
140.4(c)3 since they are only applicable to newly constructed buildings .  
Necessity:  The necessity of Exception 1 to Section 141.0(b)2C is to clarify that  new or 
replacement space conditioning systems or components that do not need to comply 
with requirements of Section 140.4(a)2 and Section 140.4(a)3 . 
 
 
Section : Exception to Section 141.0(b)2Cii  
Purpose : This exception serves to clarify that when an alteration surpasses the 
capacity of the existing main service panel or service transformer, the provisions 
outlined in Section 141.0(b)2Cii no longer apply.  
Necessity: The necessity of this  is to address instances where the scale of the 
alteration necessitates distinct considerations, ensuring that regulatory measures align 
with the practical constraints imposed by the capacity limits of the electrical 
infrastructure.  
 
Section: Table 141.0 -E-1  
Purpose: The purpose of this table is to outline specific requirements and specifications 
for different types of HVAC systems based on the type of building and its climate zone. 
The table provides information on the recommended configurations for air conditioning 
systems with various. The table is organized by different building types (Retail and 
grocery, School, Office, financial institution, Library) and climate zones (CZ 1 -15). 
Necessity: The necessity of this table is to provide a reference guide for selecting 
appropriate HVAC configurations tailored to specific building types and climate zones, 
considering factors like energy efficiency, ventilation control, and heating capabilities. It 
aids in ensuring that HVAC systems are designed and installed to meet the unique 
needs of different buildings in CA climate zones  as in 141.0(b)2Cii .  
 
Section : Exception 3 to Section 141.0(b)2C  
Specific Purpose : The specific purpose of this addition is to provide an exception 
which  makes clear  that interlocks are not required on existing windows that did not 
previously have interlocks when replacing the space conditioning system.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  Additionally, this new 
term ensures and improves the general clarity and internal consistency of the Energy 
Code as dire cted by California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.   
  
 
Section: Exception 3 to Section 141.0(b)2C  (removed)  
Specific Purpose:  Removed the exception  3 relating  to single package air -cooled 
commercial unitary air conditioner or heat pumps with capacity less than 54,000 btu/h . 
Section 141.0(b)2Ciii  clarifies that single zone system types with a capacity of less than  
 65,000 Btu/hr are to have economizer and that all single packaged unitary air systems 
from 54,000 Btu/hr and greater are to include an economizer.   
Necessity:  The change is necessary to clearly state what type of system the exception 
applies to.  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 .  
 
Section : Exception 5 to Section 141.0(b)2C  
Specific Purpose: The specific purpose of this addition is to include an exception to 
ensure that sections 140.4(c) 2Bii, 140.4(d)2Av, 140.4(e)2D, and 140.4(f)3, and 140.4(r) 
do not apply to alterations unless the space -conditioning systems are new or 
replacements.  
Necessity:   This change is needed to ensure that when HVAC systems are altered in 
existing nonresidential buildings, sections of the Energy Code that do not apply are 
listed for clarity.   
  
Section : 141.0(b)2Dii  
Purpose : The purpose of this change is to delete field verification and diagnostic testing 
and replace it with acceptance testing.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential duct leakage test to first be 
performed by a certified mechanical ATT and then field verified by an ECC -Rater 
(formerly referred to as a HERS rater). The change is necessary because this is 
duplicative and redundant as written in the 2022 Energy Code where the duct leakage 
test procedure is the same for both tests. The ATTCP program and the ECC  program 
are both intended to ensure equipment are installed in compliance with the Energy 
Code. Functional testing in nonresidential buildings is under the scope of the ATTCP 
program. Removing the field verification and diagnostic requirement will reduce 
confusion moving forward on who needs to perform the  nonresidential duct leakage 
test.  
 
Section:  Exception 2 to Section 141.0(b)2 Dii  
Specific Purpose: The purpose of this change is to use clearer and unambiguous 
language and avoid the use of the term "exempt". This exception is  rewritten to avoid 
the use of the term "exempt” and to simply and unambiguously state th e requirements 
that are not required to comply  with this section .  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
 
Section:  141.0(b)2Diii  
Specific Purpose: The purpose of this change is to use clearer and unambiguous 
language and avoid the use of the term "exempt". This exception is  rewritten to avoid  
 the use of the term "exempt” and to simply and unambiguously state the requirements 
that are not required to comply with Section 141.0(b)2Di or Section 141.0(b)2Di i.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
 
Section:  141.0(b)2 Eii 
Specific Purpose: The purpose of this change is to use clearer and unambiguous 
language and avoid the use of the term "exempt"  and replace with “not required to 
comply” .   
Necessity:  This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
 
 
Section: 141.0(b)2Lii  
Specific Purpose: The specific purpose of the change is to delete the “; and” from 
subsection b and to add “and” to subsection a.  
Necessity: The proposed change to delete the “; and” from subsection b and to add 
“and” to subsection a are necessary to clarify the outdoor lighting alteration 
requirements of Section 141.0(b)2Lii and that both subsection a and subsection b are 
required for meeting the requirements of Section 141.0(b)2Lii.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section Table 141.0 -F 
Purpose:  
The specific purpose of the change is to delete the reference in Table 141.0 -F to 
“130.1(c)1D” as there is no such section in the Energy Code.  
The specific purpose of the change is to delete the reference in Table 141.0 -F to 
“130.1(c)7” as Section 130.1(c)7 is no longer used as requirements in the Energy Code.  
Necessity:  
The change is necessary to delete the reference to Section 130.1(c)1D as Section 
130.1(c)1D does not exist in the Energy Code.  
The change is also necessary to delete the reference to Section 130.1(c)7 as Section 
130.1(c)7 is not used as requirements in the Energy Code.  These changes ensure 
clarity and avoid ambiguity and provide consistency with in the Energy Code.  
 
Section: Section 141.1(a)  
Specific Purpose: Revise language so that all additions and alterations meet 
requirements in Section 140.9(c)  as opposed to only newly installed systems . 
Necessity: The e xisting  code  language was overly broad and allowed for addition and 
alteration projects that were otherwise intended to meet requirements in 140.9(c) to 
avoid these requirements. The  10,000 -cfm limitation included in alterations language  
 pertains to requirements associated with fan system power consumption. This limitation 
is called out specifically in referenced 140.9(c) code language. Additionally, referenced 
language further explains when specific alteration projects would be excepted. Applying 
requirements to additional addition and alteration projects that are not limited in the 
same way that fan system power consumption is limited will reduce energy usage. 
Tightening how additions, alterations, and repairs must meet 140.9(c) requireme nts will 
reduce excessive energy use as directed by California Public Resources Code 25213 
and 25402.  
 
Section: Section 141.1(c) 2 
Specific Purpose: The specific purpose of the changes to this  Section is to correct an 
error in the existing language and to align the requirements with the code language.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
  
Section: Section 141.1(c)3  
Specific Purpose:  The specific purpose of the change s to this Section  is to align  the 
requirement with the code language.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  Section 120.6(h)2 was combined with Section 
120.6(h) 6, now Section 120.6(h)5,  since the lighting requirements for both indoor grows 
and greenhouse s are now the same.  
 
Section: Section 141.1(d)  
Specific Purpose: This addition specifies when insulation requirements apply to 
alteration projects. New insulation requirements will apply to newly installed piping and 
pipes that are relocated as part of an alteration.  
Necessity: This addition clarifies that piping insulation requirements apply only to newly 
installed piping and piping relocated during alterations of covered process piping. These 
scenarios will result in reductions to energy usage at the facility by applying insula tion 
requirements to these projects, while limiting excessive costs from installing insulation in 
piping that cannot be easily insulated or accessed. These requirements for insulation in 
alteration project will reduce excessive energy uses as di rected by California Public 
Resources Code 25213 and 25402.  
  
Section : 150.0(a)1  – Roof Deck Insulation  
Specific Purpose:  The purpose of this change is to more specifically describe the roof 
deck insulation requirements and their applicability to roofs that are above attics that are 
above conditioned space.  
Necessity:  The roof deck insulation requirements are unnecessary for attics that are 
above unconditioned spaces. Where attic space above  unconditioned space is 
separated from attic space above  conditioned space by an air barrier between the two 
spaces, insulation on the roof of the unconditioned side would  not result in energy  
 savings, as the space below that attic area is not conditioned . This change will reduce 
costs  and without resulting in  the wasteful or uneconomical consumption  of energy . 
 
Section: Exception 2 to Section 150.0(a)1  
Specific Purpose: The purpose of the exception is to allow buildings with buried duct 
insulation using the performance path to not have to comply with  the mandatory roof 
deck insulation  requirements . 
Necessity:  This change is to ensure that single family residential buildings have an 
equal alternative to the mandatory minimum roof deck insulation requirement to give the 
builder and designers more options to meet the equal amount of energy efficiency as 
other options.    
 
Section: 150.0(c)1  
Specific Purpose:  The specific purpose this change is to increase the mandatory 
requirement for wall insulation in single -family residential buildings to increase the 
minimum level of energy efficiency for the building envelope.  
Necessity:  This change is necessary to ensure that wall insulation in single -family 
residential buildings meets a minimum level of performance and do not otherwise 
consume a wasteful, or uneconomical amount of energy.  
    
Section: 150.0(c)2  
Specific Purpose:  The specific purpose this change is to increase the mandatory 
requirement for wall insulation in single -family residential buildings to increase the 
minimum level of energy efficiency for the building envelope.  
Necessity:  This change is necessary to ensure that wall insulation in single -family 
residential buildings meets a minimum level of performance and do not otherwise 
consume a wasteful, or uneconomical amount of energy.  
  
Section: 150.0(c)6  
Specific Purpose : The specific purpose of this change is to align the R -values with the 
new U -factor requirements found in Section 150.0(c)2.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 150.0(h)1 and 150.0(h)5 Mandatory Features and Devices, Space -
Conditioning Equipment, Building Cooling and Heating Loads.  
Specific Purpose: The purpose of this change is to define a minimum capacity limit for 
heat pumps that excludes supplementary heating capacity. Additionally, this change 
establishes that there are no limits on minimum space conditioning cooling capacity, or 
maximum limits o n heating or cooling capacity for newly constructed buildings . 
Necessity: This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to under sizing. These sizing requirements for space  
 conditioning systems will reduce excessive energy use via cost -effective building design 
standards, as directed by California Public Resources Code sections 25213 and 25402.  
  
Section: 150.0(h)1 Excep tion 1  
Specific Purpose: The purpose of this exception is to allow block loads to be used for 
the purpose of sizing space conditioning equipment for additions.  
Necessity: This exception is necessary to define when simplified space conditioning 
load calculations can be used. By permitting the use of block loads in this context, the 
exception allows for a holistic approach to achieve optimal sizing, contributing to the 
overal l functionality and performance of space conditioning systems This approach 
involves considering the loads on a block or zone basis rather than individually 
analyzing each room or space separately. The goal is to simplify the calculation process  
while still providing accurate results. This exception will reduce excessive energy use, 
as directed by California Public Resources Code sections 25213 and 25402 . 
  
Section: 150.0(h)2 B, 2C  
Specific Purpose: The purpose of this change is to add alternative sources of outdoor 
design condition from ASHRAE Handbook Equipment Volume, Applications Volume 
and Fundamental Volume , SMACNA Residential Comfort System Installation Standards 
Manual, and ACCA Manual J.  These sources  are already used for calculating cooling 
and heating load  under Section 1 50(h)1 . As part of this addition, the term 99.0 percent 
Heating Dry Bulb is introduced as an alternative to Heating Winter Median of Extreme. 
This change aligns with similar changes in Section s 140.4(b)3 and 160.3(b)2.  
Necessity:  The necessity for this change is to increase flexibility in mechanical system 
design by allowing commonly used design conditions  from the ASHRAE Handbook , 
SMACNA Manual and ACCA Manual J.  The addition of 99.0 percent Heating Dry Bulb 
is a commonly used industry term in the ASHRAE handbook to calculate heating load. 
This change is necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, S ection 16 . 
 
Section: 150.0(h)5  
Specific Purpose: The purpose of this change is to clarify that minimum heating 
capacity requirements apply to furnace/AC systems in addition to heat pumps.  
Necessity:  This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to under sizing. These sizing requirements for space 
conditioning systems will reduce excessive energy use via cost -effective building design 
standards, as directed by California Public Resources Code sections 25213 and 25402.  
  
Section: 150.0(h)6  
Specific Purpose: The purpose of this change is to require that heat pump space 
conditioning systems with defrost delay timers have their delay timers set to no less 
than 90 minutes in order to reduce the frequency and energy use of defrost operation. 
The purpose of exceptions 1 and 2  is to ensure this measure is not required in climate 
zones and dwelling unit types where it is not shown to be cost effective.   
 Necessity: This revision is necessary to reduce the energy consumed during defrost 
operation by heat pump space conditioning systems and the reheat recovery period 
associated with defrost cycles. An exception is necessary  for buildings  Climate Zones 6 
and 7, as well as dwelling units with conditioned floor are a of 500 square feet or less in 
Climate Zones 3, 5 through 10, and 15 due to lack of cost effectiveness  in these 
climates zones and building types . This defrosts  time requirement will reduce excessive 
energy use via cost -effective building design standards, as directed by California Public 
Resources Code sections 25213 and 25402.  
  
Section: 150.0(h)7  
Specific Purpose: The purpose of this change is to require that heat pump space 
conditioning systems with electric resistance heat and dual fuel heat pump space 
conditioning systems do not utilize the systems’ supplementary heating at temperatures 
above 35°F unless the systems  defrost cycle or emergency operation are occurring.  
The purpose of exceptions 2 and 3 is to ensure this measure is not required in climate 
zones and dwelling unit types where it is not shown to be cost effective.  
Necessity: The proposed revision is necessary to reduce the use of heat pump space 
conditioners’ energy intensive supplementary heating systems are not used when the 
heat pump can meet the demand and rely on the more energy -efficient compression 
heat. An exception is necessary for buildings Climate Zones 7 and 15, as well as 
dwelling units with conditioned floor are a of 500 square feet or less due to lack of cost 
effectiveness in these climates zones and building types . This supplementary heat 
cutoff temperature requirement will reduce excessive energy use via cost -effective 
building design standards, as directed by California Public Resources Code sections 
25213 and 25402.  
  
Section: 150.0(h)7 Exception 1 -3 
Specific Purpose: The purpose of  exception  1 is to exempt room-air conditioner heat 
pump s, from the requirements in 150.0(h)7  because the y generally do not have the 
capability to  control supplementary heating cutoff  temperatures or interface with third 
party thermostats that would allow  for users to control supplementary heating cutoff 
temperatures . The purpose of exception 2  and exception 3 in 150.0( h)7 exempts 
buildings  in climate zones 7, 15 and conditioned floor spaces less than 500 square feet 
due to lack of cost effectiveness in these climate  zones .  
Necessity: The proposed exception  1 is necessary  to ensure that the requirements in 
150.0(h)7 only apply to space conditioning systems that are capable of meeting the 
requirements.  Exceptions 2 and 3  to this measure  are necessary  as it is not proven to 
be cost effective  for buildings  in Climate Zone 7 , 15 and as  well as dwelling units with 
conditioned floor area of 500 square feet .  
 
Section: 150.0(h)8  
Specific Purpose: The purpose of this change is to impose capacity limits on heat 
pumps space conditioning systems’ supplemental electric resistance heaters.  
Necessity: The proposed revision is necessary to reduce over reliance upon heat pump 
space conditioners’ energy intensive supplementary heating systems in situations when 
those systems are not needed, and to ensure that heat pump space conditioning  
 systems’ performance is not degraded due to under sizing. This electric resistance 
supplementary heat capacity limit will reduce excessive energy use via cost -effective 
building design standards, as directed by California Public Resources Code sections 
25213 and 25402.  
  
  
Section: 150.0(h)9  
Specific Purpose: The purpose of this change is to require variable and multispeed 
space conditioning systems be capable of responding to heating and cooling loads by 
modulating system compressor speed when the systems are controlled by third party 
thermostats. Additionally , the proposed change ensures that third party thermostats 
controlling variable and multispeed space conditioning systems meet thermostat 
requirements outlined in 150.0(i)2.  
Necessity: This addition is necessary to ensure that variable speed and multi speed 
space conditioning systems’ performance and ability to vary compressor speed to 
match heating and cooling load is not degraded when the systems are controlled by 
third-party thermosta ts. This requirement will reduce excessive energy use, as directed 
by California Public Resources Code sections 25213 and 25402.  
   
Section: 150.0(i)1  
Specific Purpose: The purpose of this change is to make a clarification that this 
subsection only applies to setback thermostats so that the added section for 
thermostats that are applied to heat pumps with supplemental heating is distinct from 
the setback thermostat requirements.  
Necessity: This proposed change is reasonably necessary to ensure that regulations 
will have clear and unambiguous meaning to readers, including the public, and 
particularly to the persons and organizations affected by these regulations.  Additionally, 
this new term ensures and improves the general clarity and internal consistency of the 
Energy Code as directed by California Government Code Sections 11349 and 11349.1, 
and California Code of Regulations, Title 1, Section 16.  
 
Section: 150.0(i)2  
Specific Purpose: The purpose of this change is to require thermostats that are 
applied to heat pumps with supplemental heating be capable of locking out 
supplementary heating when the outdoor air temperature (OAT) is above 35°F, 
receiving and displaying outdoor air tempera ture information, indicating when 
supplementary heat or emergency heat is utilized, allowing defrost supplementary heat 
operation when the OAT is above 35°F, and allowing user enabled emergency 
supplementary heat operation when the OAT is  above 35°F.  
Necessity: The proposed revision is necessary to reduce the use of heat pump space 
conditioners’ energy intensive supplementary heating systems in situations when those 
systems are not needed. This supplementary heat cutoff temperature requirement will 
reduce excessi ve energy use via cost -effective building design standards, as directed 
by California Public Resources Code sections 25213 and 25402.  
 
Section:  150.0(i)2 Exception 1   
 Specific Purpose: The purpose of this exception is to not obligate heat pumps with 
supplementary heaters to comply with  the requirements that necessitate heat pump 
thermostats to both display outdoor air temperature and cut off supplementary heat 
above 35°F if the heat pumps lock out supplementary heat using another control device,  
Necessity: This exception is necessary to ensure only one heat pump supplementary 
heating lockout control device is required by the energy code, eliminating a redundant 
requirement where other devices are used to control the supplementary heating cutoff 
temperature o f a heat pump. This exception is necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code . 
 
Section:  150.0(i)2 Exception 2  
Specific Purpose: The purpose  of this exception is to not obligate room air -conditioner 
heat pumps to comply with the requirements for thermostats that are applied to heat 
pumps with supplementary heating.  
Necessity: This exception is necessary because most room air -conditioner heat pump 
products come with built in manufacturer controls and do not have the ability to operate 
with third party thermostats. It is onerous to apply the requirements surrounding 
thermostats u sed for heat pumps with supplementary heating to room air -conditioner 
heat pump products. This exception is necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code . 
  
Section: 150.0(j)1A  
Specific Purpose: The specific purpose of this change is to update the reference to the 
California Plumbing Code from Section 609.11 to Section 609.12. This section was 
renumbered in the 2022 California Plumbing Code.  
Necessity : This exception is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
 
Section:  150.0(k)1   
Specific Purpose : The specific purpose of the change is to delete Table 150.0 -A and to 
move requirements of Table 150.0 -A to Section 150.0(k)1. Table 150.0 -A contains 
applicable requirements that are required to comply with Joint Appendix JA8 for 
residential light sources  depending on the lighting technology, the form factor of the light 
sources and the lighting applications.  The following sections are revised in order to 
retain requirements of Table 150.0 -A. 
- Section 150.0(k)1A is modified to incorporate substantive elements of Table 
150.0 -A and to point to requirements in JA8;  
- Exception 1 to Section 150.0(k)1A is added with ceiling fan kits subject to federal 
appliance . 
- Exception 4 to Section 150.0(k)1A is added with light source listed, including LED 
light sources installed outdoors; solid state lighting (SSL) luminaires containing 
colored light sources; high intensity discharge (HID) light sources; and luminaires 
with h igh frequency generator and induction lamps.  
- Section 150.0(k)1B is deleted .  
 Necessity : The proposed change to delete Table 150.0 -A and to move its requirements 
to Section 150.0(k)1 would consolidate the residential luminaire and light source 
requirements within the body of Section 150.0(k)1 and without having to look up both 
the Table and the body of the Section in order to determine the requirements. The 
proposed change is reasonably necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code, as directed by California Government 
Code, Section 1 1349 and 11349.1, and California Code of Regulations, Title 1, Section 
16. 
  
Section:  150.0(k)1A  
Specific Purpose : The specific purpose of the changes is to add “light sources” to “All 
installed luminaries” and to replace “Table 150.0 -A” with “Joint Appendix JA8”. The 
specific purpose of the changes is to retain the applicability of Table 150.0 -A to all light 
sources and luminaires except those listed as exceptions to Section 150.0(k)1A.  
Necessity : The proposed change to add “light sources” and to add “Joint Appendix 
JA8” to Section 150.0(k)1A is reasonably necessary as Joint Appendix JA8 is one of the 
mandatory requirements in Table 150.0 -A for all applicable light sources and luminaires 
to comply  with.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section:  150.0(k)1B  
Specific Purpose : The specific purpose of the change is to delete the code language 
about screw -based luminaires that they shall contain lamps that comply with Joint 
Appendix JA8. This change is necessary to delete redundant code language for 
luminaires and light sources to comply with Joint Appendix JA8.  
Necessity : The proposed change is to delete the redundant code language requiring 
light sources to comply with Joint Appendix JA8 as Section 150.0(k)1A already requires 
all installed luminaires and light sources – including light sources in screw -based 
luminaires - to comply with JA8.  The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Re gulations, Title 1, Section 16.  
  
Section:  150.0(k)1C  
Specific Purpose : The specific purpose of the change is to replace the word “Section” 
with “Article”.  
Necessity : The proposed change to use the word “Article” instead of “Section” is 
necessary as the reference, “California Electrical Code” , is organized the language by 
article and not by section. The proposed change is reasonably necessary to ensure and 
improve the general clarity and internal consistency of the Energy Code, as directed by  
 California Government Code, Section 11349 and 11349.1, and California Code of 
Regulations, Title 1, Section 16.  
  
Section:  150.0(k)1D  
Specific Purpose : The specific purpose of the change is to clarify the code language 
by changing the order of the phras e “In enclosed or recessed luminaires” and with 
associated grammatical changes for the requirements of light sources “in enclosed or 
recessed luminaires”.  
Necessity : The proposed change of re -ordering of the phrase “in enclosed or recessed 
luminaries” is necessary to improve the readability of the code language.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section: 150.0(k)1E  
Purpose:  The specific purpose of the change is to replace the term ‘ must‘  with ‘shall’ to 
keep it consistent with the other section of the code that “shall” is used.  
Necessity:  The proposed change to use the term “shall” is to ensure the same term 
“shall” is used on every occasion where the requirements are mandatory. The proposed 
change is reasonably necessary to ensure and improve the general clarity and internal 
consistency o f the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  150.0(k)2B  
Specific Purpose : The specific purpose of the change is to move the code language to 
Section 150.0(k)2D. The code language specifies that no other controls shall bypass the 
controls of dimmer, occupant sensor or vacancy sensor, and the language can be 
consolidated as “Con trols permitted” as part of Section 150.0(k)2D.    
Necessity : The proposed change to move the language to Section 150.0(k)2D is to 
consolidate requirements of “controls permitted” within the same section and the 
change can aide code users in comprehending the Energy Code.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  150.0(k)2C  
Specific Purpose : The specific purpose of the change is to add section heading “All 
lighting controls”.  
Necessity : The proposed change to add a section heading is to aid code users in 
looking up the Energy Code.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California  
 Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section  150.0(k)2D  
Specific Purpose : The specific purpose of the change is to add section heading 
“Controls permitted” and to add the section language of Section 150.0(k)2B to Section 
150.0(k)2D.  
Necessity : The proposed change to add a section heading is to aid code users in 
looking up the Energy Code.  The proposed change to add the language of Section 
150.0(k)2B is to consolidate requirements of “controls permitted” within the same 
section and the change can aide code users in comprehending the Energy Code.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  150.0(k)2F  
Specific Purpose : The specific purpose of the change is to delete the phrase “but not 
limited” to and the change is to clarify without changing the mandatory requirement.  
The phrase “but not limited to” does not impose a mandate and can be deleted without 
changing the ma ndatory requirement.   
The other specific purpose of the change is to add “lighting integral to kitchen range 
hoods and bathroom exhaust fans” to Exception 1. There are already controls to the 
lighting integral to kitchen range hoods and bathroom exhaust fans as part of the 
operations of the kitchen range hoods and bathroom exhaust fans, and the lighting 
integral to kitchen range hoods and bathroom exhaust fans are considered task lighting 
that are more appropriate to be controlled as part of the operations of the kitchen range 
hoods and bathroom exhaust fans.  
Necessity : The proposed change to delete the phrase “but not limited” is to clarify 
without changing the mandatory requirement of lighting dimming controls.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  150.0(k)2F (Exception 3)  
Specific Purpose : The specific purpose of the change is to clarify the requirements 
with editorial changes including break up the long sentence into two shorter sentences.  
The other editorial change is to rearrange the phrase, “rated less than five watts”, after 
“Navigation lighting” in one of the shorter sentences.  
The other editorial change is to rearrange the phrase, “automatic -off controls”, to add 
“Lighting controlled by automatic -off controls and located” to the other shorter sentence, 
and to add “cabinetry with” before “doors”.   
 Necessity : The proposed change to clarify the requirements with editorial changes is 
necessary to clarify requirements of the Exception 3 so that the language and the 
requirements are clear to the code users.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  150.0(k)2G  
Specific Purpose : The specific purpose of the change is to replace the phrase 
“integrated lighting of” by “lighting integral to” and the change is necessary to use a 
more commonly used phrase in the industry.  
Necessity : The proposed change to use the phrase “lighting integral to” is to use a 
more commonly used phrase in the industry and without changing the mandatory 
requirements of the lighting controls.  The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
Section  150.0(k)3  
Specific Purpose : The specific purpose of the change is to clarify the residential 
outdoor lighting controls requirements with editorial changes includes organizing the 
requirements by adding section numbering and by adding sign -post phrase “one of the 
following controls” .   
The other specific purpose of the change is to add two phrases “(EMCS)” and “or other 
controls” and to add a clarifying statement, “no other controls shall bypass the controls 
of dimmer, occupant sensor or vacancy sensor”, for the dimmer or sensor that has  been 
installed to comply with Section 150.0(k)3 for residential outdoor lighting.  
Necessity : The proposed change of the editorial changes is to aid the code users in 
looking up and understanding the Energy Code.   
The proposed change to add the phrases “(EMCS)” is to aid code users that energy 
management control system is also commonly known as EMCS in building industry and 
can be used for meeting the requirements.  
The proposed change to add the phrases “or other controls” is to allow controls other 
than energy management control system to be installed for meeting the residential 
outdoor lighting requirements of Section 150.0(k)3.  
 The proposed change to add the clarifying statement is to ensure no other controls to 
interfere with the controls of dimmer, occupant sensor or vacancy sensor.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
  
 Section : 150.0(m)1Bii  
Specific Purpose : The specific intent of this modification is to ensure that appropriately 
tempered air is effectively received at the register from the source.  
Necessity: These changes are essential to address concerns about the lack of proper 
conditioned air reaching the register when uninsulated ducts are installed in an indirectly 
conditioned attic . By ensuring that all duct systems are insulated, except for those 
systems that are located entirely in conditioned space  below the ceiling separating 
occupiable space from the attic, we ensure that minimal  energy is lost due  to conduction  
caused by higher temperatures in the attic .  
  
Section : 150.0(m)12A Exception 1  
Specific Purpose : The specific purpose of this change is to modify the language for 
clarity without changing the intent . 
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 .  
  
Section : 150.0(m)13 C: Exception 1  
Specific Purpose : The specific purpose of this change is to establish an  exception 
related to  advancements in compressor system technology, particularly those 
employing multispeed or variable speed compressors. Such systems inherently possess 
the capability to modulate fan speed based on the real -time demand from conditioned 
zones. The exception i s intended to offer a practical and verifiable approach for installer 
certification, allowing them to demonstrate compliance by operating the system at 
maximum compressor capacity and system fan speed while all zones are actively 
calling for conditioning.  
Necessity:  This modification  to the exception is needed to ensure  that certified 
installers can effectively demonstrate adherence to airflow and fan efficacy 
requirements while utilizing the latest advancements in multispeed or variable speed 
compressor systems  and will improve energy savings in buildings as directed by 
California Public Resources Code sections 25213 and 25402.  
 
Section : 150.0(n)1Ai  
Specific Purpose : The specific purpose of this change is to modify the existing branch 
circuit requirement from 10 American Wire Gauge (AWG) copper to rating at 30 amps 
minimum.  
Necessity: These changes are necessary to eliminate concerns that the current 
requirement is overly prescriptive and may interfere with electrical code requirements 
for branch circuit sizing in some cases. These changes improve clarity of the 
requirements and thereby  enhance code compliance and enforcement of the standards. 
Making the requirement in terms of ampere instead AWG aligns the electric ready 
requirements in other parts of the Energy Code.  
   
 Section : 150.0(n)2  
Specific Purpose : The specific purpose of this change is to remove subsection 2 and 
renumber subsequent sections.  
Necessity: Subsection referencing water heating recirculation loop serving multiple 
dwelling units is no longer necessary because multifamily language restructuring has 
moved these requirements out of section 150.0, which is only applicable to single -family 
buildings . The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section: 150.0(o)1Civa  
Specific Purpose:  The specific purpose of this change is to add a point iv(a) to include 
IAQ filter and HRV/ERV accessibility requirements within occupiable spaces, 
basements, garages, balconies, and mechanical closets for regular service and not be 
located more than 10 fe et above a walking surface inside a space specified above for 
compliance with this requirement.   
Necessity: These changes are necessary to help improve accessibility for IAQ system 
component replacement and equipment maintenance to ensure ventilation control for 
which has both energy savings and public health and safety benefits. These  changes 
are consistent with Public Resources Code §25402 and §25402.8 on assessment of 
indoor air pollution in new buildings.  
  
Section: Exception to Section 150.0(o)1Civa  
Specific Purpose:  The specific purpose of adding this Exception is to incorporate 
accessibility requirements for systems requiring servicing from inside the attic as Staff 
acknowledged accessibility issues and timely maintenance challenges can persist 
regardless of the typ e of attic space due to unfavorable conditions of attic spaces.  
Necessity: These changes are necessary to help improve accessibility for IAQ systems 
that require servicing from inside the attic to ensure ventilation control for which has 
both energy savings and public health and safety benefits.  These changes are 
consistent with Public Resources Code §25402 and §25402.8 on assessment of indoor 
air pollution in new buildings.  
  
Section: 150.0(o)1Civb  
Specific Purpose:  The specific purpose of this change is to add a point iv.b to include 
IAQ system component accessibility referencing the California Mechanical Code (CMC) 
Section 304.0 .  
Necessity: These changes are necessary to maintain consistency with the CMC 
language and does not change any regulatory obligations for regulated entities.  
  
Section: 150.0(o)1Civc   
 Specific Purpose:  The specific purpose of this change is to add a point iv.c including 
outdoor air intakes referencing the California Mechanical Code (CMC) Section 402.4.1 
requirements.  
Necessity: These changes are necessary to maintain consistency with the CMC 
language  and does not change any regulatory obligations for regulated entities . 
  
Section: 150.0(o)1Civd  
Specific Purpose:  The specific purpose of this change is to add a point iv.d to include 
outdoor air intake location, and accessibility to require access to outdoor air intakes that 
are located not more than 10 feet above a walking surface and if located on roofs shall 
reference California Mechanical Code Section 304.3.1.  
Necessity: These changes are necessary to help improve accessibility for outdoor 
intakes to maintain consistency with the CMC language.  
   
Section:  Exception to Section 150.0(o)1Civd  
Specific Purpose:  The specific purpose of adding this exception is to incorporate 
outdoor air intake serving equipment with a Fault Indicator Display (FID) to meet the 
requirements of Reference Appendix JA 17.  
Necessity: These changes are necessary as JA17 specifies HRV/ERV system FID 
qualification requirements including maintenance and accessibility requirements for 
outdoor intake serving equipment with an FID. These changes are consistent with 
Public Resources Code §2540 2 and §25402.8 on assessment of indoor air pollution in 
new buildings.  
 
Section:  150.1(c)1A  
Specific Purpose: Specify inclusion of cathedral ceiling insulation requirements under 
existing Option C which currently outlines ceiling insulation requirements for vented 
attics referenced by climate zone in Table 150.1 -A. 
Necessity: This change is necessary to enable compliance through a prescriptive 
option for cathedral ceiling construction which will improve energy savings in buildings 
as directed by California Public Resources Code sections 25213 and 25402.  
  
Section : 150.0(p), 150.0(p)1  
Specific Purpose : The specific purpose of revision is to clean up existing code 
language.  
Necessity: These changes are necessary to align with changes to the Title 20 
Appliance Standard.  These terms ensure and improve the general clarity and internal 
consistency of the Energy Code as directed by California Government Code Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.0(p)1A  
Specific Purpose : The specific purpose of this change is to add references to 
dedicated -purpose pool pumps and replacement dedicated -purposed pump motors, as 
well as updates to the applicable appliance standards.   
 Necessity: These changes are necessary to align with changes to the Title 20 
Appliance Standard.  These terms ensure and improve the general clarity and internal 
consistency of the Energy Code as directed by California Government Code Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.0(p)1D -G 
Specific Purpose : The specific purpose of this change is to remove outdated appliance 
standard references and add references to dedicated -purpose pool pumps and 
replacement dedicated -purposed pump motors.  
Necessity: These changes are necessary to align with changes to the Title 20 
Appliance Standard.  These terms ensure and improve the general clarity and internal 
consistency of the Energy Code as directed by California Government Code Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.0(q)  
Purpose:  The specific purpose of this change is to clarify that when meeting Exception 
1 or Exception 2 then the user is not required to comply with Section 150.0(q).  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.0(q)1  
Purpose:  The specific purpose of this change is to reduce the mandatory U -factor 
requirement for all fenestration products, including skylights, to ensure that all 
fenestration products in a newly constructed building meet a minimum U -factor of U -
0.40.  
Necessity:  This change is necessary to ensure that all fenestration products in newly 
constructed buildings performs at a minimum level of performance and do not otherwise 
consume a wasteful, or uneconomical amount of energy consistent with California 
Public Resourc es Code sections 25213 and 25402.  
  
Section : 150.0(q)2  
Purpose:  The specific purpose of this change is to remove the option to use area -
weighted averaging to meet the mandatory U -factor requirement.  
Necessity:  This change is necessary to ensure that all windows in newly constructed 
buildings meet a minimum level of performance, and do not otherwise consume a 
wasteful, or uneconomical amount of energy consistent with California Public 
Resources Code sections 252 13 and 25402.  
  
Section : 150.0(s)  
Specific Purpose: The specific purpose of this addition is to eliminate the energy 
storage ready requirements for the buildings that don’t require large residential service 
(125 A). As a result, small ADUs will not have to upsize the electrical service and put 
extra conduit s to comply with  energy storage ready requirements. Also , the exception  
 has been added to make sure that energy storage ready requirements don’t apply if the 
energy storage system is already installed.  
Necessity:  
These adjustments are essential for providing clarity regarding the intent of the code, 
particularly concerning when the requirement for energy storage readiness must be 
fulfilled . This change is necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.0(s)1A  
Specific Purpose: The specific purpose of this change is to add reference to Section 
150.0(s)2 to the four branch circuits requirements.  
Necessity: This change is necessary to remove ambiguity on whether the four branch 
circuits are the same as the ones specified in Section 150.0(s)2. This change is 
essential for providing clarity regarding the intent of the code, particularly concerning 
when the requ irement for energy storage readiness must be fulfilled.  This change is 
necessary to ensure and improve the general clarity and internal consistency of the 
Energy Code, as directed by California Government Code, Section 11349 and 11349.1, 
and Cal ifornia Code of Regulations, Title 1, Section 16.  
  
Exception to Section : 150.0(s) : Exception  
Specific Purpose: The specific purpose of this change is to add a new exception to the 
BESS  ready requirements if a BESS  is being installed with the newly constructed 
building.  
Necessity: This change is necessary for providing clarity regarding the intent of the 
code, particularly concerning when the requirement for energy storage readiness must 
be fulfilled. This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  Table 150.0 -A 
Specific Purpose : The proposed change is to delete Table 150.0 -A. 
Necessity : The change to delete Table 150.0 -A is necessary to consolidate the 
requirements into an article of Section 150.0(k)1A. The changes improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section: Table 150.0 -E 
Specific Purpose: The specific purpose of this change is to remove the “or 5 ACH 
capacity” compliance criteria applicable to enclosed kitchens.  
Necessity: These changes are necessary to ensure public health and safety for 
occupants of dwelling units complying with the energy efficiency requirements of the 
Energy Code, consistent with State Statutes and policies of protecting and enhancing  
 the indoor environmental quality in buildings. These changes incorporate 2022 
ASHRAE 62.2 Section 5, Table 5 -1 requirements with modifications to clarify airflow 
measurement procedures are necessary to ensure and improve the general clarity and 
internal co nsistency of the Energy Code, as directed by the California Government 
Code Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 
16. 
  
Section : 150.1(b)  
Specific Purpose : The specific purpose of this change is to clarify that energy budgets 
for single family buildings are expressed in terms of Long -Term System Cost (LSC), and 
Source Energy . Obsolete language stating that energy budgets are expressed in Time 
Dependent Valuation and Energy Design Rating is deleted. The breakdown of LSC into 
two sub -budgets, Efficiency LSC and Total LSC , is clarified.  
Necessity: These changes are necessary to clarify and make specific how the energy 
budget is calculated and the use of the terms to be used for establishing energy 
budgets. These changes align language that has the same purpose in sections 140.1, 
150.1(b) and 170.1.   
Long-term System Cost  is similar to T ime Dependent Valuation in that it varies for every 
hour of the year to capture the value of energy and emissions at different time s of the 
day and at different times of the year. Long-term System Cost  is a cost met ric that 
represents long -term marginal costs to the energy system over 30 -years through which 
we hope to better account for , and relay  to the public , the long-term dollar cost impact to 
California’s energy system .  
  
Section : 150.1(b)2  
Specific Purpose : The specific purpose of this change is to remove requirements 
specifically for additions and alterations; the specification of the term for which the 
energy budget is expressed for additions and alterations is properly stated in section 
150.2. The subsequent subsections that follow 150.1(b)2 are renumbered . 
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16. The energy 
budget for ad dition and alterations are already specified in Section 150.2.  
 
Section : 150.1(b)2Bi  
Specific Purpose : The purpose of this change is to align the energy code with updated 
Department of Energy ratings for EER, SEER and HSPF.  
Necessity: These changes are necessary to ensure that the energy code references 
the updated EER, SEER, and HSPF ratings being used by the Department of Energy.  
 
Section:  150.1(c)1A  
Specific Purpose: Specify inclusion of cathedral ceiling insulation requirements under 
existing Option C which currently outlines ceiling insulation requirements for vented 
attics referenced by climate zone in Table 150.1 -A.  
 Necessity: This change is necessary to enable compliance through a prescriptive 
option for cathedral ceiling construction which will improve energy savings in buildings 
as directed by California Public Resources Code sections 25213 and 25402.  
  
Section: 150.1(c)1Aiii  
Purpose: The specific purpose  of this change is (1) to clarify that the requirements of 
Option C apply  to ventilated attics, and (2) to extend  the requirement s to cathedral 
ceilings as well . 
Necessity : (1) This change is  necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
(2) This change is necessary to ensure that buildings with cathedral ceilings, which 
have their ducts  (if any) located within the conditioned space , are compared to buildings 
with ventilated attic configurations which also have their ducts located within the 
conditioned space.    
   
Section : 150.1(c)3A – Exception 1  
Purpose:  The specific purpose of this change is to add an exception for new dwelling 
units with a conditioned floor area of less than or equal to 500 square feet in climate 
zones 5 through 10 and 15 to comply with a maximum U -factor of U -0.30.  
Necessity:  This change is necessary as the analysis for the 2025 code measure 
proposal did  not find it  to be cost -effective to require a U -factor of U -0.27 or U -0.28 for 
dwelling units 500 square feet or less, in those climate zones. Repealing this 
requirement does not have a significant impact on the whole -building energy savings 
resulting from this code update.  
  
Section : 150.1(c)3A – Exception 2  
Purpose:  The specific purpose of this change is to modify the code language to remove 
the word “new”. Since Section 150.1 of the code deals exclusively with newly 
constructed single -family buildings it is redundant to specify here that we are dealing 
with new glaz ing area/skylights.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 150.1(c)3A  – Exception 3  
Purpose:  The specific purpose of this change is to reduce the maximum U -factor 
allowed for newly constructed buildings  to align with the new mandatory maximum U -
factor requirement of Section 150.0(q). Additionally, the SHGC requirement for climate 
zones 1, 3, 5, and 16 were removed to align with the SHGC requirements found in 
Table 150.1 -A. 
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.   
   
Section : 150.1(c)4  
Purpose:  The specific purpose of this change is to clarify that for the SHGC prescriptive 
standard is a maximum value, and not a minimum.   
Necessity:  This change is necessary to ensure energy savings are realized and 
improve the general clarity and internal consistency of the Energy Code, as directed by 
California Government Code, Section 11349 and 11349.1, and California Code of 
Regulations, Title 1, Section 16.  
  
Section : 150.1(c)6  
Specific Purpose : The specific purpose of this change is to remove climate zones 3, 4, 
13, and 14 from the language, therefore making the heat pump space heater 
prescriptive requirement applicable to all climate zones.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code 
Sections 25213 and 25402.  
  
Section:  150.1(c)7Ai  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to better clarify the Energy Code. This better 
aligns the Energy Code  with California Government Code 11349 and 11349.1 and 
California Code of Regulations title 1, Section 16.  
  
Section:  150.1(c)7Aib  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to better clarify the Energy Code. This better 
aligns the Energy Code with  California Government Code 11349 and 11349.1 and 
California Code of Regulations title 1, Section 16.  
 
Section :150.1(c)7AicII  
Specific Purpose : The purpose of this change is to remove the option that allowed for 
refrigerant charge verification through the installation of equipment that utilizes a fault 
indicator display (FID).  
Necessity: These changes are necessary to clean up the energy code by removing a 
section that is no longer needed . Various issues associated with FIDs that may impact 
their effectiveness or reliability  are that industry codes are frequently misinterpreted , 
have limited diagnostic capabilities , sen sor accuracy has been poor, are not sensitive 
enough to detect small leaks or provide timely alerts  and suffer from lack of 
standardization. Removal of the inclusion of the option for refrigerant charge verification 
through FIDs in the energy code can help improve overall system reliability  and safety .  
 
  
  
 
Section : 150.1(c)8 Exception 1  
Specific Purpose : The specific purpose of this change is to remove exception 1 for gas 
instantaneous water heaters in climate zones 3, 4, 13, and 14. Subsequent exceptions 
are renumbered.  Also,  the specific purpose of this change is to remove the note as 
reference the language for clarity without changing the intent . Necessity: These 
changes are necessary to increase energy efficiency via cost -effective building design 
standards, as directed by California Public Resources Code Sections 25213 and 25402  
and is reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349 .1, and California Code of Regulations, Title 1, Section 16.  
  
  
Section : 150.1(c)8 Exception 1 after renumbering  
Specific Purpose : The specific purpose of this change is to remove reference to 
instantaneous electric water heaters, making this exception applicable to all electric 
water heater.  
Necessity: This change allows more flexibility for ADU where small storage electric has 
similar performance to instantaneous electric water heater.   
  
Section : 150.1(c)9B  
Specific Purpose : The specific intent of this modification is to ensure that appropriately 
tempered air is effectively received at the register from the source.  
Necessity: These changes are essential to address concerns about the lack of proper 
conditioned air reaching the register when uninsulated ducts are installed in an indirectly 
conditioned attic .  By ensuring that all duct systems are insulated, except for those 
systems that are located entirely in conditioned space below the ceiling separating 
occupiable space from the attic, we ensure that minimal energy is lost due to conduction 
caused by highe r temperatures in the attic.  
  
Section: Exception 1 and 2 to Section 150.1(c)11  
Purpose: The purpose of this change is to use clearer and unambiguous language and  
avoid the use of the term "exempt". Exceptions 1 and 2 are rewritten to avoid the use of 
the term "exempt” and to simply and unambiguously state that provisions of Section 
140.7(a) are not required for each of the exceptions.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
  
 
Section : 150.1(c)14  
Specific Purpose: The purpose of this change is to clarify and reduce compliance 
ambiguity by establishing a definitive calculation that is applicable for all roofs for 
determining the PV requirement when solar access roof area (SARA) is limited. The  
 calculation establishes separate requirements for buildings with steep -sloped roofs and 
for buildings with low -sloped roofs. The calculation is based on the physical dimensions 
and performance of standard PV arrays rather than on the unfettered discretion of the 
installer. This corrects the language in the current Energy Code that does not provide a 
definitive means to determine the PV requirement.    
Necessity: These changes are necessary to ensure reliable reductions in wasteful, 
uneconomic, inefficient, or unnecessary consumption of energy  as directed by California 
Public Resources Code Sections 25213 and 25402.  This change is necessary to ensure 
and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
 
Section : 150.1(c)14Biii  
Specific Purpose: The purpose of this change is to clarify, make specific and reduce 
administrative burden. Section 150.1(c) 14B was clarified and made more specific by 
separately addressing compliance with other state building codes as a reason for roof 
area to not be available, in addition to compliance with local building codes if confirmed 
by the Executive Director (ED). Compl iance with state building codes would not require 
ED confirmation; compliance with local building codes would continue to require ED 
confirmation.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
This change is necessary to improve compliance with and enforcement of the Energy 
Code by reconciling potential conflicts with other state and local building code 
obligations for how roof area will be used and contribute to the optimum achievement of 
energ y savi ngs due to installation of PV systems.  
 
Section : 150.1(c)14 Equation 150.1 -C and Table 150.1 -C 
Specific Purpose: The purpose of this change is to avoid the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy, and present in a clear and specific 
manner the PV requirement for single family buildings considering both conditioned floor 
area and the EE R2 of cooling equipment.  Revised climate specific coefficients and 
constants for the equation are provided in changes to Table 150.1 -C.   
The equation is designed to avoid increased energy consumption allowed by the current 
2022 Energy Code when heat pumps replace air conditioners. When heat pumps are 
used that have lower EER2 efficiency than allowed for air conditioners, the higher 
cooling energy for the building is offset by a corresponding increase in the size of the 
PV system required for the building.   
Necessity: These changes are necessary to avoid increased energy consumption 
through cost - effective PV requirements consistent with California Public Resources 
Code section 25402. This change is also necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations,  
 Title 1, Section 16.  This change is necessary to improve complianc e with and 
enforcement of the Energy Code by clarifying the specific PV requirement needed to 
avoid increased building energy consumption due to lower EER2 efficiency, thereby 
achieving the energy savings goals of this provision.  
 
Section: Exception 5 to section 150.1(c)14  
Specific Purpose: The term “usable capacity” has been replaced with “cycling 
capacity” as defined in JA12. Also, the term “battery storage system” has been replaced 
with “ESS (Energy Storage System)” as defined in Section 100.1(b). These changes are 
necessary to clarify the requirements for the energy storage system in the exception.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
 
Section: 150.1(c)15  
Specific Purpose: The specific purpose of this change is to add a requirement to 
include ventilation system Fault Indicator Display (FID) requirements for HRV/ERV 
systems.  
Necessity: These changes are necessary to ensure ventilation control for which has 
both energy savings and public health and safety benefits. These changes are 
consistent with Public Resources Codes §25402 and §25402.8 on assessment of indoor 
air pollution in new bui ldings.  
  
Section: Table 150.1 -A 
Purpose:  The specific purpose of this change is to reduce the maximum prescriptive U -
factor to U -0.27 in climate zones 1 -6 and 8 -16, and U -0.28 in climate zone 7.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.  
  
Section: Table 150.1 -A  
Specific Purpose:  The specific purpose of this change is to add a row named 
ventilation systems in Table 150.1 -A to include ventilation system Fault Indicator 
Display (FID) requirements for HRV/ERV systems.  
Necessity: These changes are necessary to ensure ventilation control for which has 
both energy savings and public health and safety benefits. These changes are 
consistent with Public Resources Codes §25402 and §25402.8 on assessment of indoor 
air pollution in new bui ldings.  
   
Section: Table 150.1 -A  
Specific Purpose: Revise table to include prescriptive maximum required cathedral 
ceiling insulation R -value. Revisions and additions are also required in the 
accompanying footnotes.   
 Necessity: This change is necessary to enable compliance through a prescriptive 
option for cathedral ceiling construction , which allows for better compliance and better 
achieves the energy saving goals of the Energy Code . 
    
Section : 150. 2(a) - Exception s 1 and 5  
Specific Purpose : The specific purpose of this change is to modify the language for 
clarity without changing the intent.  
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section : 150.2(a) - Exception 3 
Specific Purpose : The specific purpose of this change is  to modify the language for 
clarity without changing the intent  and to reference 2022 California Residential Code  
303.10 which states the required heating design temperatures for a dwelling unit.   
Necessity:  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section : 150.2(a) - Exception 7  
Specific Purpose : The specific purpose of this change is to remove the exception that 
allows alternatives to a heat pump or gas heating system for space heating. By 
removing this exception, the intent is to establish a more standardized and consistent 
approach to space heating systems, aligning with  the recent changes to the heat pump 
baseline for single fami ly newly constructed buildings.     
Necessity:  This modification is deemed necessary to ensure uniformity and adherence 
to the standards. These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.    
 
Section : 150.2(a)1Aii - Exception  
Specific Purpose : The specific purpose of this change is to add an exception for 
alterations that add fenestration area in climate zone 1 5. Instead of meeting the 
prescriptive SHGC requirement  of Table 150.1 -A, projects can comply with a maximum 
SHGC  of 0.23.  
Necessity:  This change is necessary to ensure that alterations projects in climate zone 
15 that a re adding additional f enestration do not need to install darker tinted windows in 
order to meet the SHGC requirement of 0.20 required of newly constructed buildings.  
 
Section : 150.2(a)1D  
Specific Purpose : The specific purpose of this change is to change reference from 
second water heater to additional water heater.   
 Necessity: These changes are necessary to address the situation for additions to 
existing single -family buildings, when the existing building already has 2 or more water 
heaters . This will  improve  the general clarity and internal consistency of the Energy 
Code, as directed by California Government Code, Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
  
Section : 150.2(a)1Diii  
Specific Purpose : The specific purpose of this change is to remove subsection iii for 
fossil fuel  instantaneous water heaters. Subsequent sections are renumbered.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code 
Sections 25213 and 25402.  
 
Section : 150.2(a)1D iii – After re -numbering   
Specific Purpose : The specific purpose of this change is to remove the word 
“instantaneous”  as a descriptor of the prescriptive option , making this option  applicable 
to all electric water heater. This aligns with similar change in Exception 1 to Section 
150.1(c)8.  
Necessity:  This change allows more flexibility for small addition 500 square feet or less,  
where small storage electric has similar performance to instantaneous electric water 
heater.  
 
Section :150.2(a) 1Ei 
Specific Purpose : The purpose of this change is to establish that the minimum 
capacity requirements for space conditioning systems described in Section 150.0(h)5 
apply to additions.  
Necessity: This change is necessary to improve the general clarity and internal 
consistency of the Energy Code  to and ensure that space conditioning systems  in 
additions adhere to the minimum capacity requirements described in Section 150.0(h) 5.  
 
Section :150.2(a) 1Eii 
Specific Purpose : The purpose of this change  is to require additions ’ maximum heating 
and cooling capacity be based on heating design load, cooling design load, space 
conditioning system type, and duct sizing.  
Necessity: This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to over sizing when ducts are not also sized 
accordingly. These sizing requirements for space conditioning systems will reduce 
excessive energy use via co st-effective building design standards, as directed by 
California Public Resources Code sections 25213 and 25402.  
 
Section :150.2(a) 1Eiii  
Specific Purpose : The purpose of Section 150.2(a)1Ei ii is to require that the envelope 
infiltration assumption used in space conditioning sizing calculations is not larger than a 
maximum value that is dependent on the type of square footage of a dwelling unit.   
 Necessity: This change  is necessary to ensure systems are not sized based on 
overestimated infiltration assumptions , reducing the likelihood that a space conditioning 
systems’ performance will be downgraded due to oversizing. The exception is 
necessary to allow for cases where envelope infiltration values would be determined by 
diagnostic testing, and there would be no  risk of overestimation of infiltration or system 
oversizing as a result. These sizing  calculation  requirements for space conditioning 
system s will reduce excessive energy use via cost -effective building design standards, 
as directed by California Public Resources Code sections 25213 and 25402.  
 
Section : Exception to Section 150.2(a)1Eiii  
Specific Purpose : The purpose of 150.2(a)1E Exception 1 is to allow for envelope 
leakage values higher than the maximum values given in table 150.2 -C when leakage is 
established through field verification and diagnostic testing.  
Necessity: This change  is necessary to ensure systems are sized based on values 
derived from field verification and diagnostic testing instead of being sized based on 
overestimated infiltration assumptions. These sizing requirements for space 
conditioning systems will reduce ex cessive energy use via cost -effective building design 
standards, as directed by California Public Resources Code sections 25213 and 25402.  
 
Section: Table 150.2 -A 
Specific Purpose : The purpose of Table 150.2 -A is to define the maximum allowed 
heating capacity for additions with  various space conditioning system types and various 
design load conditions.  
Necessity: This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to over sizing when ducts are not also sized 
accordingly. These sizing requirements for space conditioning systems will reduce 
excessive energy use via cost -effective building design standards, as directed by 
California Public Resources Code sections 25213 and 25402.  
 
Section: Table 150.2 -B 
Specific Purpose : The purpose of Table 150.2 -B is to define the maximum allowed 
cooling capacity for additions with  various space conditioning system types and various 
design load conditions.  
Necessity: This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to over sizing when ducts are not also sized 
accordingly. These sizing requirements for space conditioning systems will reduce 
excessive energy use via co st-effective building design standards, as directed by 
California Public Resources Code sections 25213 and 25402.  
 
Section: Table 150.2 -C 
Specific Purpose : The purpose of Table 150.2 -C is to define the maximum envelope 
infiltration value that can be assumed during load calculations unless leakage is 
established through field verification and diagnostic testing .  
 Necessity: This change  is necessary to ensure systems are not sized based on 
overestimated infiltration assumptions , reducing the likelihood that a space conditioning 
systems’ performance will be downgraded due to oversizing. These sizing  calculation  
requirements for space conditioning systems will reduce excessive energy use via cost -
effective building design standards, as directed by California Public Resources Code 
sections 25213 and 25402.  
 
 
Section: 150.2(a)2   
Specific Purpose : The purpose of this change is to clarify that for additions projects 
using the performance approach the energy budget will be expressed in terms of Long -
term System Cost.  
Necessity: This change is necessary to ensure consistency with the rest of the Energy 
Code which transitions terminology from Time Dependent Valuation to the L ong-term 
System Cost . 
 
Section: Exception to Section 150.2(a)2B  
Specific Purpose:  The specific purpose of this change is to ensure clarity and improve 
readability  without changing the requirement . 
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section :150.2(a) 2D 
Specific Purpose : The purpose of this change is to add a language that requires 
additions using the performance approach to adhere to requirements in Section 
150.2(a)1E that necessitate additions’  maximum heating and cooling capacity be based 
on heating design load, cooling design load, space conditioning system type, and duct 
sizing. This change  also specifies  maximum values for the envelope leakage to be used 
in load calculations.  
Necessity: This revision is necessary to ensure that space conditioning systems’ 
performance is not degraded due to over sizing when ducts are not also sized 
accordingly. This section is also necessary to ensure systems are not sized based on 
overestimated infiltrati on assumptions. These sizing requirements for space 
conditioning systems will reduce excessive energy use via cost -effective building design 
standards, as directed by California Public Resources Code sections 25213 and 25402.  
  
Section: Section 150.2(b)1A Exception 1  
Purpose:  The specific purpose s of these  change s is (1) to reduce the square footage 
allowance for vertical fenestration added as part of an alteration from 75 square feet to 
16 square feet , and (2) to lower the U-factor and SHGC requirements for sk ylights to 
align with the prescriptive requirements  for newly constructed buildings .  
 Necessity:  (1) This change is necessary to ensure that vertical fenestration added as 
part of an alteration performs at a level consistent with the standards for newly 
constructed buildings , thereby increasing energy savings of existing buildings . However, 
alterations that add up to 16 square feet are not required to comply with  the total and 
west-facing fenestration area requirements of Section 150.1(c)3B and C.  
(2) This change is necessary to ensure that skylights perform at a level consistent with 
the standards for newly constructed buildings , thereby increasing energy savings of 
existing buildings . 
   
Section:  150.2(b)1B – Exceptions 1   
Specific Purpose: The specific purpose of this change  is to replace the symbol for 
through (e.g., -) and instead write it out to ensure that screen readers convey the 
standard accurately when read aloud.  
Necessity:  The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section: Section 150.2(b)1B Exception 2  
Purpose: The specific purpose of this change is to ensure that replacement skylights 
installed as part of an alteration align the new mandatory maximum  U-factor 
requirement found in Section 150.0(q).  
The specific purpose of this change is to reduce the maximum U -factor for replaced 
skylights  to U=0.40.  
Necessity:  This change is necessary to ensure that replacement skylights in existing 
single -family residential buildings that are being altered perform at a minimum level of 
performance and does not otherwise consume a wasteful, or uneconomical amount of 
energy cons istent with California Public Resources Code sections 25213 and 25402.  
 
Section:  150.2(b)1B  – Exception 3   
Specific Purpose: The specific purpose of this change  is to allow vertical fenestration 
to be replaced with a product that has  an SHGC no greater than 0.23 in climate zone 
15, as opposed to the 0.20 prescriptively required in Section 150.1(c)3A  and Table 
150.1 -A. 
Necessity:  This change is reasonably necessary to ensure that the aesthetic of the 
building is not affected by requiring replacement vertical fenestration to use darker glass 
to comply with the prescriptive SHGC requirement . 
 
Section:  150.2(b)1C  
Specific Purpose: The specific purpose of these changes is to add a reference to 
Section 150.2(b)1Fii . Entirely new or complete replacement duct space -conditioning 
systems need to meet the refrigerant charge verification  standard of  Section 
150.2(b)1Fii.   
 Necessity:  This change is necessary to ensure that all applicable requirements are 
accurately referenced, and to reduce any ambiguity.   
 
Section: Table 150.2 D  
Specific Purpose : Table 150.2 A was renamed Table 150.2 D to reflect the addition of 
tables.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
 
Section :150.2(b)1 FiibII  
Specific Purpose : The purpose of this change is to remove the option that allowed for 
refrigerant charge verification through the installation of equipment that utilizes a fault 
indicator display (FID).  
Necessity: These changes are necessary to clean up the energy code by removing a 
section that is no longer needed.  Various issues associated with FIDs that may impact 
their effectiveness or reliability are that industry codes are frequently misinterpreted, 
have limited diagnostic capabilities, senor accuracy has been poor, are not sensitive 
enough to detect small leaks or provide timely alerts and suffer from lack of 
standard ization. Removal of the inclusion of the option for refrigerant charge verification 
through FIDs in the energy code can help improve overall system reliability and safety.  
  
Section: Table 150.2 E  
Specific Purpose : Table 150.2 B was renamed Table 150.2 E to reflect the addition of 
tables.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
 
Section: Table 150.2 F  
Specific Purpose : Table 150.2 C was renamed Table 150.2 F to reflect the addition of 
tables.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code  
 
Section:  150.2(b)1J iv  
Specific Purpose: The specific purpose of this change  is to cite the specific section of 
the California Building Code that pertains to attic ventilation – California Residential 
Code, Title 24, Part 2.5, Section R806.  
Necessity:  This change is necessary to ensure that the correct section  of the California 
Building Code is referenced, and to reduce any ambiguity.  
 
Section:  150.2(b)1K   
 Specific Purpose: The specific purpose of changes to remove  the reference to Table 
150.0 -A as the Table is deleted from the Energy Code  The existing reference to 
luminaire efficacy requirements of Section 150.0(k) still remains to be in effect.   
Necessity:  This change is reasonably necessary to  help ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section: Excepti on 3 to Section 150.2(b)1 Ii 
Specific Purpose : The purpose of this change is to clarify that roofs with a weight of at 
least 25 LB/ft2 do not need to meet the cool roof requirement.   
Necessity: This change is necessary to ensure clarity  within the Energy Code , as 
directed by California Government Code, Section 11349 and 11349.1 . 
 
Section: Exception 3 to Section 150.2(b)1Ii ia 
Specific Purpose : The purpose of this change is to clarify that roofs with a weight of at 
least 25 LB/ft2 do not need to meet the cool roof requirement.   
Necessity: This change is necessary to ensure clarity  within the Energy Code , as 
directed by California Government Code, Section 11349 and 11349. 1. 
 
Section: 150.2(b)2  
Specific Purpose : The purpose of this change is to clarify that for alterations projects 
using the performance approach the energy budget will be expressed in terms of Long -
term System Cost.  
Necessity: This change is necessary to ensure consistency with the rest of the Energy 
Code w hich transitions  terminology from Time Dependent Valuation to Long-term 
System Cost . 
  
Section 150.2(b)2B  
Specific Purpose : The specific purpose of this change is to clarify that third -party 
certification  options must be verified by a field verification and diagnostic testing certified 
ECC -rater.  
Necessity : The proposed change is necessary to provide clarification of the intent of 
verification for specific  construction elements. This will help  improve the general clarity 
and internal consistency of the Energy Code, as directed by California Government 
Code, Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 
16. Using the Performance approach for changes to existing homes may include 
additional energy credits for components that exceed the minimum energy efficiency 
requirements of the Energy Code  and require verification . These additional credits can 
only be taken into account when they are verified but the Energy Cod e was not clear 
about what entity must provide this verification. The intent was that the ECC -Rater 
provided this service; this change is necessary to make that intent clearer .  
  
Section: Table 150.2 -G  
 Purpose:  The specific purpose of these changes is to increase the stringency of the 
standard design for which altered fenestration and window films are compared to when 
third-party verification of the existing condition is not performed. Additionally, the 
language  for fenestration when third -party verification is performed was rewritten to use 
the existing fenestration U -factor and SHGC values as verified by a third -party 
inspector.  
Necessity:  These changes are necessary to ensure that the standard design is met 
accurately when third -party verification of the existing condition is, and is not, 
performed.  By setting the standard  design for altered fenestration components to  a 
lower U -factor and SHGC , we are increasing the energy efficiency  of existing buildings , 
resulting in increased energy savings.    
  
Section: 160.1(b)2  
Purpose:  The specific purpose of this change is to reduce the mandatory requirement 
for metal framed wall insulation in multifamily residential buildings.  
Necessity:  This change is necessary to e stablish a n updated minimum level of 
performance   of insulation for metal framed walls in multifamily residential buildings  as 
standards are assessed and reviewed  periodically  to ensure  these buildings do  not 
otherwise consume a wasteful amount of energy , or uneconomical amount of energy . 
  
Section: 160.1(b)3A and B  
Purpose:  The specific purpose of this change is to reduce the mandatory requirement 
for wood framed wall insulation in multifamily residential buildings.  
Necessity:  This change is necessary to e stablish an updated minimum level  of 
performance of wall insulation for wood framed walls in multifamily residential buildings  
as standards are assessed and reviewed periodically to ensure these buildings do not 
otherwise consume a wasteful, or uneconomical amount of energy.  
 
Section:  Exceptions 1 and 2 to Section 160.1 (e)1 
Specific Purpose : The purpose of th ese change s is to use clearer and unambiguous 
language and avoid the use of the term "exempt". Th ese exception s are rewritten to 
avoid the use of the term "exempt” and to simply and unambiguously state that specific 
existing duct systems are not required to comply.  
Necessity: This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
 
Section:  160.1(g)1 through 4  
Specific Purpose:  The specific purpose of adding this standard for multifamily 
buildings is to ensure that , when slab edge insulation is installed, it meets minimum 
specifications regarding water absorption rate, water vapor permeance, damage 
protection, and ultraviolet protection. These standards already exist in the Energy Code 
for slab edge insulation installed in nonresidential, and single -family buildings . Thus, to 
ensure consistent requirements are met  across the Energy Code , this language was 
added to the requirements for multifamily buildings.   
 Necessity:  Concrete is generally a poor insulator, and slab edge insulation helps to 
slow heat flow between the bottom floor of a building and the earth and air around it.  
These changes are necessary to ensure that materials used for slab perimeter 
insulation are protected, to ensure that these products increase building energy 
efficiency where they are installed, and to ensure consistency with requirements for this 
insulat ion across all building types.  
 
Section:  Exception  to Section 160. 2(b)1 
Specific Purpose:  The purpose of this change is to use clearer and unambiguous 
language and avoid the use of the term "exempt". This exception is rewritten to avoid 
the use of the term "exempt” and to simply and unambiguously state that evapor ative 
coolers  are not required to otherwise comply  with Section 160 .2(b)1 . 
Necessity: This change is necessary to ensure clarity and avoid ambiguity and provide 
consistency with other exceptions in the Energy Code.  
 
Section: 160.2(b)2Aiv(b)  
Specific Purpose:  The specific purpose for the changes to this section are to require 
both balanced ventilation and compartmentalization, with supply -only ventilation to be 
used in lieu of balanced ventilation, updating requirements such that dwelling units shall 
comply with both updated subsectio ns 1 and 2.  
Necessity: These changes are necessary to ensure adequate outdoor air supply and 
reduce pollutant transfer and potential particle infiltration between units to improve and 
maintain adequate indoor air quality.  These changes are consistent with Public 
Resources Codes §25402 and §25402.8 on assessment of indoor air pollution in new 
buildings.  
 
Section: 160.2(b)2Aivb2  
Purpose : The purpose of this change is to mention NA1.9 directly in the Energy Code 
(Title 24, Part 6).  
Necessity : The intent of NA1.9 is to allow an ATT to perform field verification and 
diagnostic testing if an ATT is already on the project performing acceptance tests or if 
the installer is a certified ATT. This alternative procedure is located in the Reference 
Appendices. The change is necessary because it clarifies directly in the Energy Code 
where NA1.9 can be used.  
 
Section: 160.2(b)2Axia  
Specific Purpose:  The specific purpose of this change is to add the point xi a, which 
includes IAQ system filter and HRV/ERV accessibility requirements within occupiable 
spaces, basements, garages, balconies, mechanical closets,  or accessible rooftops for 
regular service and not be located more than 10 feet above a walking surface inside a 
space specified above for compliance with this requirement.  
 Necessity: These changes are necessary to help improve accessibility for IAQ system 
component replacement and equipment maintenance to ensure ventilation control for 
which has both energy savings and public health and safety benefits. Thes e changes  
 are consistent with Public Resources Codes §25402 and §25402.8 on assessment of 
indoor air pollution in new buildings.  
   
Section: Exception to Section 160.2(b)2Axia  
Specific Purpose:  The specific purpose for adding this exception is to incorporate 
accessibility requirements for systems requiring servicing from inside  of an  attic.  
Necessity: These changes are necessary to help address unfavorable accessibility 
conditions of attic spaces that may otherwise exist and tend to cause challenges  for 
timely maintenance  of the systems placed there . This exception thus seeks to improve 
accessibility for IAQ systems that require servicing from inside the attic to ensure 
ventilation control for which has both energy savings and public health and safety 
benefits. These changes are consistent with Public Resources Codes §25402 and 
§25402.8 on assessment of indoor air pollution in new buildings.  
 
Section: 160.2(b)2Axib  
Specific Purpose:  The specific purpose of this change is to add point xib to include 
IAQ system component accessibility which referenc es the California Mechanical Code 
(CMC) Section 304.0.  
 Necessity: The addition is necessary to maintain consistency with the CMC language 
and does not change any regulatory obligations for regulated entities.  
  
Section: 160.2(b)2Biv  
Purpose : The purpose of this change is to mention NA1.9 directly in the Energy Code 
(Title 24, Part 6).  
Necessity : The intent of NA1.9 is to allow an ATT to perform field verification and 
diagnostic  testing if an ATT is already on the project performing acceptance tests or if 
the installer is a certified ATT. This alternative procedure is located in the Reference 
Appendices. The change is necessary because it clarifies directly in the Energy Code 
where NA1.9 can be used.  
  
Section:  Exception to Section 160.2(b)2C  
Specific Purpose:  The specific purpose of this change is to add an exception to 
Section 160.2(b)2C for multifamily buildings with three or fewer habitable stories in 
Climate Zone 7.  
Necessity:  This exception is necessary as th is measure is not currently proven to be 
cost effective in Climate Zone 7. These changes ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Sections 1 to increase energy efficiency via cost -effective building design standards,  as 
mandated by California Public Resources Code Sections 25213 and 25402.  
 
  
Section:  Exception 1 to Section 160.2(c)2  and Exception 2 to Section 160.2(c)2 D  
 Specific Purpose:  The specific purpose of these non -substantial changes is to move 
the Exception 1 to Section 160.2(c) to become Exception 2 to Section 160.2(c)2D. This 
does not change the intent of the code, but will better clarify the requirements.  
Necessity: These changes are reasonably necessary for better clarity of the 
mechanical ventilation requirements when designing a naturally ventilated zone. These 
changes ensure that the regulations will have clear and unambiguous meaning to 
readers, including the pub lic, and particularly to the persons and organizations affected 
by these regulations.  Moving the requirements from the section header into the 
requirements list improves the general clarity and internal consistency of the Energy 
Code as directe d by California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
 
 
Section:  Exception  2 to Section 160.2( c)2 and Exception 1 to Section 160.2(c)2D  
Specific Purpose:  The specific purpose of these non -substantial changes is to move 
the Exception 1 to Section 160.2(c) to become Exception 2 to Section 160.2(c)2D. This 
does not change the intent of the code, but will better clarify the requirements.  
Necessity: These changes are reasonably necessary for better clarity of the 
mechanical ventilation requirements when designing a naturally ventilated zone. These 
changes ensure that the regulations will have clear and unambiguous meaning to 
readers, including the pub lic, and particularly to the persons and organizations affected 
by these regulations.  Moving the requirements from the section header into the 
requirements list improves the general clarity and internal consistency of the Energy 
Code as directe d by California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
 
 
 
 
Section : 160.2(c)2A and B  
Specific Purpose : The specific purpose of these non -substantial changes is aligning  
natural ventilation requirements with ASHRAE 62. 1 – 2022 version. These changes 
make clearer  the requirements of different building openings and correctly cites the new 
sections in ASHRAE 62. 1-2022 version which were unaligned previous code cycle.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  This rewording and 
aligning of cit ations ensure  and improves the general clarity and internal consistency of 
the Energy Code as directed by California Government Code Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
 
  
 
Section : 160.2(c)2, 160.2(c)2D   
 Specific Purpose : The specific purpose of these non -substantial changes is to move 
the mechanical ventilation requirements previously located in the body text header of 
160.2(c)2  into the listed requirements as subsection D ..  
Necessity: These changes are reasonably necessary for better clarity of the 
mechanical ventilation requirements when designing a naturally ventilated zone. In 
previous code languages these requirements were overlooked due to the past format  
and location . These changes ensure that  the regulations will have clear and 
unambiguous meaning to readers, including the public, and particularly to the persons 
and organizations affected by these regulations.  Moving the requirements from the 
section header into the re quirements list improves the general clarity and internal 
consistency of the Energy Code as directed by California Government Code Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
     
  
Section : 160.2(c) 3 
Specific Purpose : The specific purpose of these changes is to revert the language to 
align with 2019 Building Energy Code ventilation logic  where it is intended that code 
users comply  the larger of Equa tion A or B . The exception that was added in the 2022  
Building Energy Code was intended to clarify this section, but instead it had 
unintentionally  been interpreted to  remove this ‘greater than logic’ for ventilation.  
Necessity: These changes  reintroduce the equations and a ‘greater of’ comparison but 
does not change the ventilation rates from previous cycles. This prevents designers 
from taking an exception to only use a designed occupancy when previous cycles 
designed occupancy method and area method had to be compared for  the larger 
ventilation rate.  
 
 
Section : 160.2(c)5Dv  
Specific Purpose : The specific purpose for the changes reflected in the section 
referenced above  including referencing the equation is to align  this section  with the new 
changes made to the minimum ventilation section 160.2(c)3 and Table 160.2 -B, where 
the process for determining ventilation rates have been changed back to a comparison 
greater than equation. This increases clarity and promote s consistency of the 
requirements for minimum ventilation which has been an issue for the last two code 
cycles.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations .This improves the 
general clarity and internal consistency of the Energy Code as directed by California 
Government Code Sections 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section : 160.2(c) 5E  
 Specific Purpose : The specific purpose of these changes is to make clear the 
requirements of this section without changing stringency and for format consistency .  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. In the previous code 
cycle designers are seeming to avoid this r equirement where the requirement language 
is in the intro body of this section. Moving from the intro body into a list format improves 
compliance by showing the requirements explicitly.  
      
 
Section : 160.2(c) 8 
Specific Purpose : The specific purpose of these changes is to update the references 
to the ASHRAE 62.1 document.   
Necessity: These changes are reasonably necessary to ensure that references are 
directing users of the Energy Code to the correct sections of documents incorporated by 
reference.  
      
 
Section : Table 160.2 -A  
Specific Purpose : The specific purpose of these changes is to remove these tables 
entirely. They are not being used and were copied over in the previous cycle to the 
multifamily section by mistake.  
Necessity: These changes are reasonably necessary  to correct a precious error and  to 
ensure that regulations will have clear and unambiguous meaning to readers, including 
the public, and particularly to the persons and organizations affected by these 
regulations.  Additionally, this new term ensures and improves the general clarity and  
internal consistency of the Energy Code as directed by California Government Code 
Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.   
  
Section : Table 160.2 -B 
Specific Purpose : The specific purpose of these changes is to mimic the nonresidential 
tables 120. 1-A which align with the California Mechanical Code. The changes to the 
footnotes of this table align with the nonresidential table changes in reverting the 
ventilation equation back to the greater than comparison described in Section 120.1(c)3 
of this docu ment.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations. This change allows 
designers to see the comparison of ventilation rates between the area method or person 
method which has been a confusion among the industry since the change went into 
effect in 2019. This reverts back to 2016 using a greater than equatio n and provides 
more tran sparency in the ventilation rates and these changes are not intended to affect 
the current minimum ventilation requirements   
 Section : Table 160.2 -C and Table 160.2 -D 
Specific Purpose : The specific purpose of these changes are to align the referenced 
tables above with the table updates provided in the ASHRAE 62. 1 – 2022 version. 
Changes to table 160.2 -C updates  the reference to the same table in ASHRAE 62.1. 
Changes to Table 160.2 -D includes new entries  that provide  air classification .  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  This rewording and 
aligning of cit ations ensure  and improve the general clarity and internal consistency of 
the Energy Code as directed by California Government Code Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section: 160.3(b)2B , 2C 
Specific Purpose: The purpose of this change is to add alternative sources of outdoor 
design condition s from the ASHRAE Handbook , Equipment Volume, Applications 
Volume and Fundamental Volume, SMACNA Residential Comfort System Installation 
Standards Manual, and ACCA Manual J . These sources  are already used for 
calculating cooling and heating load under Section 150(h)1. As part of this addition, the 
term 99.0 percent Heating Dry Bulb is introduced as an alternative to Heating Winter 
Median of Extreme. This change aligns with similar changes in Section s 140.4(b)3 and 
150.0( h)2.  
Necessity:  The necessity for this change is to increase flexibility in mechanical system 
design by allowing commonly used design conditions from the ASHRAE Handbook, 
SMACNA Manual and ACCA Manual J. The addition of “ 99.0 percent Heating Dry Bulb ” 
is a commonly used industry term from the ASHRAE handbook to calculate heating 
load. This change is necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and Cali fornia Code of Regulations, Title 1, Section 16.  
   
Section: 160.3(b)7  
Specific Purpose: The purpose of this change is to add requirements for  heat pumps 
space conditioning systems with defrost delay timers to have their delay timers set to no 
less than 90 minutes in order to reduce the frequency and energy use of the defrost 
operation. An exception is included for dwelling units in climate zones 1, 6, 7, 8, 9, 10, 
15 and 16 because staff’s  analysis did not show cost effectiveness in those climate 
zones.  
Necessity: This revision is necessary to reduce the energy consumed during the 
defrost operation by  heat pump space conditioning systems as well as the energy 
consumed during the reheat recovery period associated with defrost cycles. This defrost 
time requirement will reduce excessive energy use via cost -effective building design 
standards, as directed b y California Public Resources Code 25213 and 25402.  
  
Section: 160.3(b)8  
Specific Purpose: The purpose of this change is to add a requirement  for variable and 
multispeed space conditioning systems  to be capable of responding to heating and 
cooling loads by modulating system compressor speed when the systems are controlled  
 by third party thermostats . This change will also require the installer to test and certify 
the control configuration.   
Necessity: This addition is necessary to ensure that variable speed and multi speed 
space conditioning systems’ performance and ability to vary compressor speed to 
match heating and cooling load is not degraded when the systems are controlled by 
third-party thermostats. This requirem ent will reduce excessive energy use, as directed 
by California Public Resources Code 25213 and 25402  
    
Section : 160.3(c)1Aii  
Specific Purpose : The specific purpose of this change is to add reference of “suction ” 
to the refrigerant line insulation requirement. This matches the refrigerant suction line 
insulation requirement for space cooling system and similar changes made to Section  
120.3(a)2.  
Necessity: This change is necessary to match the intent of the Standard. Existing 
language implies the entire refrigerant distribution system needs to be insulat ed. 
Typically,  only the suction line carrying vapor  would need to be insulated , as it is 
currently required  for space cooling systems.  
 
Section : 160.3(c)2Hi  
Purpose : The purpose of this change is to delete the HERS field verification and 
diagnostic testing from the requirements provided for in the section referenced above 
and replace it with acceptance testing.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires multifamily common area duct leakage test to first 
be performed by a certified mechanical ATT and then field verified by a HERS rater. 
The change is necessary because this is duplicative and redundant as written in the 
2022 Energy Code where the duct leakage test procedure is the same for both tests. 
The ATTCP program and the HERS program are both intended to ensure equipment 
are installed in compliance with the Energy Code. Functional testing in multifamily 
common areas is under the scope of the ATTCP program. Removing the HERS field 
verification and diagnostic requirement will also reduce confusion moving forward on 
who needs to perform the d uct leakage test.  
 
Section:  160.3(d)1  
Specific Purpose:  
The purpose of this change is to correct minor errors in referencing, spelling , and 
grammar.  
Necessity:  
This change is necessary to better clarify or correct minor issues with the Energy Code. 
This benefits the CEC  by complying with California Government Code 11349 and 
11349.1 and California Code of Regulations title 1, Section 16.  
 
Section: Section 160.3(d)1D   
 Purpose: The purpose of this change is to modify terminology and avoid the use of the 
term “exempt” for clarity without changing the intent of the Energy Code. When 
particular requirements in the Energy Code are not applicable to particular construction 
situations or equipment for specific reasons, the Energy Code does provide exceptions 
that indicate compliance is not required in that instance.  
Necessity:  This change is necessary to ensure clarity and avoid ambiguity, and to 
provide consistency with other exceptions in the Energy Code.  
 
Section : 160.3(d)2A  
Purpose : The purpose of this change is to remove acceptance testing for high -rise 
multifamily dwelling unit ventilation systems.  In addition to reformatting the subsequent 
subsections to properly reflect the removal of previous A and B sections.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires dwelling unit ventilation systems to be 
acceptance tested by a certified mechanical ATT and field verified by a HERS rater. The 
change to remove acce ptance testing is necessary because this requirement is 
duplicative and redundant as written in the 2022 Energy Code with the HERS testing 
requirement. Dwelling unit ventilation systems tested by a HERS rater is sufficient to 
ensure compliance.  
 
  
  
 
Section : 160.3(d)2B  
Purpose : The purpose of this change is to remove acceptance testing for high -rise 
multifamily dwelling unit enclosure leakage test.  In addition to re formatting the 
subsequent subsections to properly reflect the removal of previous A  and B  sections.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires dwelling unit ventilation systems to be 
acceptance tested by a certified mechanical ATT and field verified by a HERS rater. The 
change to remove acce ptance testing is necessary because this requirement is 
duplicative and redundant as written in the 2022 Energy Code with the HERS testing 
requirement. Dwelling unit enclosure leakage tested by a HERS rater is sufficient to 
ensure compliance.  
  
     
Section : 160.4(a)  
Specific Purpose : Moving the heat pump water heater ready language in subsection 
160.4 (a) to 160.9(e). Subsequent sections are renumbered.  
Necessity: These changes are necessary to improve clarity of the requirements and 
thereby enhance code compliance and enforcement of the standards. By moving 
subsection a. we are consolidating the electric ready requirements to ensure general 
clarity and internal con sistency of the Energy Code as directed by California  
 Government Code Sections 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section : 160.4(e)1 -3 
Specific Purpose : The specific purpose of these changes is to add a comprehensive 
list of mandatory pipe insulation requirement s, including explicitly naming components 
that would require insulation. These changes provide clarity to the design and 
installation industry to ensure uniform pipe insulation of the heating plant, recirculation 
loop, and branches to the dwelling units, an d result in minimize pipe heat loss.  
Necessity: Bad pipe insulation practices result in excessive pipe heat loss and higher 
energy use.  These changes are necessary to ensure best practice in pipe insulation 
installation and energy efficiency via cost -effective building design standards, as 
mandated by California Public Resources Code Sections 25213 and 25402.  
  
Section : 160.4(e)2  
Specific Purpose : The specific purpose of these changes is to specify alternative 
insulation thickness requirement s if the insulation conductivity is outside the range 
Table 160.4 -A. This language is similar to the existing pipe insulation language in 
Section 120.3(c), this change restates  the requirement in 160.4(e)2A to allow alternative 
insulation thickness requirements.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16. This 
change restates the  requirements originally located in Section 120.3.  
    
Section : 160.4(e)3A  
Specific Purpose : The specific purpose of this change is to add a reference to piping 
appurtenance in the insulation protection requirement s to clarify that the insulation 
protection requirements are also applicable to insulation appurtenance . Additionally , 
staff have added language  to this section to  require that  the appurtenance insulation 
cover shall be removable and re -installable. This  change  is in alignment with the 
requirement in 160.4(e)1H3, where appurtenance insulation is required to be removable 
and re -installab le. Therefore , the cover shall also be removable and re -installable.  
Necessity: Bad pipe insulation practices result in excessive pipe heat loss and higher 
energy use. These changes are necessary to increase energy efficiency via cost -
effective building design standards, as mandated by California Public Resources Code 
Sections 25213 a nd 25402.  
 
Section : 160.4(e) 4 
Specific Purpose : The specific purpose of this change is to add a new mandatory 
requirement for field verification of insulation quality.   
Necessity: This change is necessary to ensure quality installation of pipe insulation. 
Recent study indicate that poor pipe insulation installation is a common practice . For 
example , tees and elbows are often not insulated and this result s in excessive pipe heat  
 loss and higher energy use. These changes are necessary to increase energy efficiency 
via cost -effective building design standards, as mandated by California Public 
Resources Code Sections 25213 and 25402.  
     
Section : 160.4(f)1 - Exception 1  
Specific Purpose : The specific purpose of these changes is to delete this exception 
relating to space conditioning equipment. Pipe insulation requirement for space 
conditioning equipment is already covered under Section 160.3(c)1, therefore this 
exception is not needed.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16. Insulation 
for space con ditioning is specified under Section 160.3(c)1.  
  
Section  160.5(a)1 and Table 160.5 -A 
Specific Purpose : The specific purpose of the change is to delete Table 160.5 -A and to 
move requirements of Table 160.5 -A to Section 160.5(a)1. Table 160.5 -A contains 
applicable requirements for residential light sources depending on the lighting 
technology, the form fact or of the light sources and the lighting applications.  The 
following sections are revised in order to retain requirements of Table 160.5 -A. 
- Section 160.5 (a)1A are modified.  
- Exception 1 to Section 160.5(a)1A is revised with ceiling fan kits subject to 
federal appliance.  
- Exception 4 to Section 160.5(a)1A is added with light source listed, including 
LED light sources installed outdoors; solid state lighting (SSL) luminaires 
containing colored light sources; high intensity discharge (HID) light sources; and 
luminaires with high frequency generator and induction lamps.  
- Section 160.5(a)1B is deleted  
Necessity : The proposed change to delete Table 160.5 -A and to move its requirements 
to Section 160.5(a)1 would consolidate the residential luminaire and light source 
requirements within the body of Section 160.5(a)1 and without having to look up both 
the Table and the body of the Section in order to determine the requirements. The 
proposed change is reasonably necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code, as directed by California Government 
Code, Section 1 1349 and 11349.1, and California Code of Regulations, Title 1, Section 
16. 
  
Section  160.5(a)1A  and Table 160 .5-A 
Specific Purpose : The specific changes made in this section were to add “light 
sources” to “All installed luminaries” and to replace “Table 160.5 -A” with “Joint Appendix 
JA8”.  
Necessity : The proposed change to add “light sources” and to add “Joint Appendix 
JA8” to Section 160.5(a)1A is reasonably necessary as Joint Appendix JA8 is one of the  
 mandatory requirements in Table 160.5 -A for all applicable light sources and luminaires 
to comply with. The change is necessary to retain the applicability of Table 160.5-A to 
all light sources and luminaires except those listed as exceptions to Section 160.5(a)1A.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section 160.5(a) 1A (Exception 1)  
Specific Purpose : The specific purpose of the changes add s, “ceiling fan kits that are 
subject to federal appliance standards” and to make s other  minor editorial changes 
associated with the added phrase.  
Necessity : The proposed change to add “ceiling fan kits that are subject to federal 
appliance standards” that were listed in Table 160.5 -A of the 2022 Energy Code is 
necessary to retain the exception  for ceiling fan kits that are subject to federal appliance 
standards.  
The proposed change to make minor editorial changes associated with the added 
phrase, “ceiling fan kits that are subject to federal appliance standards”, is necessary to 
ensure correctness of the Energy Code.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
   
Section  160.5(a) 1A (Exception 2)  
Specific Purpose : The specific purpose of the changes is to rearrange and revise the 
phrase “less than 5 watts”  and to spell out “5  watts ” as “five  watts” . 
Necessity : The proposed change to rearrange the phrase “less than 5 watts” is to 
clarify the Exception. The proposed change to spell out the numeral, “5”, is to ensure 
consistency in writing style of the Energy Code.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section 160.5(a) 1A (Exception 3)  
Specific Purpose:  
The specific purpose of the change is to rearrange the phrase “with an efficacy of 45 
lumens per watt or greater” to be after “Lighting” and to replace “and” with “or” before 
“linen closets”. This is to clarify the requirements without adding new lighting types to 
the Exception.  
Necessity:   
 The proposed changes to rearrange the phrase “with an efficacy of 45 lumens per watt 
or greater” and other associated editorial changes are to clarify the Exception without 
adding new lighting types to the Exception.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
   
Section 160.5(a) 1A (Exception 4)  
Specific Purpose : The specific purpose of the changes is to add a new Exception for 
the light sources that were listed in Table 160.5 -A of the 2022 Energy Code.  
Necessity : The proposed change to add a new Exception for the light sources that 
were listed in Table 160.5 -A of the 2022 Energy Code is necessary to retain the 
exception  for these lighting sources.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  160.5(a)1B  
Specific Purpose : The specific purpose of the change is to delete the code language 
about screw -based luminaires that they shall contain lamps that comply with Joint 
Appendix JA8. This change is necessary to delete redundant code language for 
luminaires and light sources to comply with Joint Appendix JA8.  
Necessity : The proposed change is to delete the redundant code language requiring 
light sources to comply with Joint Appendix JA8 as Section 160.5(a)1A already requires 
all installed luminaires and light sources – including light sources in screw -based 
luminaires - to comply with JA8 which is required for all installed luminaires and light 
sources.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section  160.5(a)1C  
Specific Purpose : The specific purpose of the change is to replace the word “Section” 
with “Article”.  
Necessity : The proposed change to use the word “Article” instead of “Section” is 
necessary as the reference, California Electrical Code” is organized by article and not 
by section.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 .  
   
Section  160.5(a)1D  
Specific Purpose : The specific purpose of the change is to clarify the code language 
by changing the order of the phrase “ In enclosed or recessed luminaires” and the 
associated grammatical changes for the requirements of “light sources in enclosed or 
recessed luminaires”.  
Necessity : The proposed change of re -ordering of the phrase “in enclosed or recessed 
luminaries” is necessary to improve the readability of the code language.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section 160.5(a)1E  
Specific Purpose: The specific purpose of the change is to replace the term ‘ must‘  with 
‘shall’ to keep it consistent with the other section of the code where “ shall” is used.  In 
addition,  the spelling of five is modified from the use of the numerical.  
Necessity: The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section  160.5(a)2B  
Specific Purpose : The specific purpose of the change is to move the code language 
from this section  to the end of Section 160.5(a)2D. The code language specifies that no 
other controls shall bypass the controls of dimmer, occupant sensor or vacancy sensor, 
and the language can be consolidated as “Controls permitted” as part of Section 
160.5(a)2D.    
Necessity : The proposed change to move the language to Section 160.5(a)2D is to 
consolidate requirements of “controls permitted” within the same section thus aiding 
code users in comprehending the Energy Code with ease.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  160.5(a)2C  
Specific Purpose : The specific purpose of the change is to add section heading “All 
lighting controls”.  
Necessity : The proposed change to add a section heading is to aid code users in 
looking up the Energy Code.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California  
 Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section  160.5(a)2D  
Specific Purpose : The specific purpose of the change is to add section heading 
“Controls permitted” and to add the section language previously located in Section 
160.5(a)2B to the end of this section, Section 160.5(a)2D.  
Necessity : The proposed change to add a section heading is to aid code users in 
looking up the Energy Code.  The proposed change to add the language of Section 
160.5(a)2B is to consolidate requirements of “controls permitted” within the same 
section and the change can aide code users in comprehe nding the Energy Code. The 
change is necessary to clarify types of controls permitted to be installed and to clarify no 
controls shall bypass control functions required for meeting Section 160.5(a)2.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  160.5(a)2F  
Specific Purpose : The specific change is to delete the phrase “but not limited” to clarify 
without changing the mandatory requirement.  The phrase “but not limited to” is 
superfluous in this sentence and can be deleted without changing the mandatory 
requirement.   
Necessity : The proposed change to delete the phrase “but not limited” is to clarify 
without changing the mandatory requirement of lighting dimming controls.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
 
Section  160.5(a)2F - Exception 1  
Specific Purpose :  
The specific change is to add “lighting integral to kitchen range hoods and bathroom 
exhaust fans” to Exception 1.  
Necessity : There are already controls to the lighting integral to kitchen range hoods 
and bathroom exhaust fans as part of the operations of the kitchen range hoods and 
bathroom exhaust fans, and the lighting integral to kitchen range hoods and bathroom 
exhaust fan s are considered task lighting that are more appropriate to be controlled as 
part of the operations of the kitchen range hoods and bathroom exhaust fans.  
  
Section  160.5(a)2F - Exception 3  
Specific Purpose : The specific purpose of the change is to clarify the requirements 
with editorial changes including break ing up the long sentence into two shorter 
sentences.   
 The other editorial change is to rearrange the phrase, “rated less than five watts”, after 
“Navigation lighting” in one of the shorter sentences.  
The other editorial change is to rearrange the phrase, “automatic -off controls”, to add 
“Lighting controlled by automatic -off controls and located” to the other shorter sentence, 
and to add “cabinetry with” before “doors”.  
Necessity : The proposed change to clarify the requirements with editorial changes is 
necessary to clarify requirements of the Exception 3 so that the language and the 
requirements are clear to the code users.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section  160.5(a)2G  
Specific Purpose : The specific purpose of the change is to replace the phrase 
“integrated lighting of” with “lighting integral to”.  
Necessity : The proposed change to use the phrase “lighting integral to” is to replace 
“integrated lighting” with a more commonly used phrase in the industry and without 
changing the mandatory requirements of the lighting controls.   
The proposed change to is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section  16. The proposed change is reasonably necessary to use a phrase 
recognized by industry.  
  
Section  160.5(a)3  
Specific Purpose : The specific changes made in the section  referenced above clarify 
the residential outdoor lighting controls requirements with editorial changes.  
The change to Section 160.5(a)3A delete s the phrase “in items I and the requirements 
in either ii or item ii i” and to add s “following” preceding “requirements”. The other 
changes rephrase subsection ii with the addition of phrases, “one of the following 
controls” (added to subsection ii) and “a photocell and” (added to subsection b).  
The other specific purpose of the change to Section 160.5(a)3C is to add two phrases 
“(EMCS)” and “or other controls” and to add a clarifying statement, “no other controls 
shall bypass the controls of dimmer, occupant sensor or vacancy sensor”, for the 
dimmer or sensor that has been installed to comply with Section 160.5(a)3 for 
residential outdoor lighting.   
Necessity : The changes to Section 160.5(a)3A are editorial and the  changes is to aid 
the code users in looking up and understanding the outdoor lighting controls 
requirements. The changes to add the phrases, “one of the following controls” and “a 
photocell and” retain the existing code requirements and aid the code users in reading 
the language.   
 The proposed change to add the phrases “(EMCS)” is to signal to code users that 
energy management control system is also commonly known as EMCS in the building 
industry and can be used for meeting the requirements.  
The proposed change to add the phrases “or other controls” is to allow controls other 
than energy management control system to be installed for meeting the residential 
outdoor lighting requirements of Section 160.5(a)3.  
The proposed change to add the clarifying statement at the end of section 160.5(a)3C  is 
to ensure no other controls interfere with the controls of dimmer, occupant sensor or 
vacancy sensor.  
The proposed changes are reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16. 
  
Section 160.5(b)4A  
Specific Purpose: The proposed change rename s the heading term as “manual 
controls” (previously “manual area controls”) and another term as “enclosed space” 
(previously “area enclosed by ceiling partitions”). The change t rename s these terms in 
Section 160.5(b)4Ai, the section title and other lighting section locations that have the 
usage of the previous terms.  These terms are used in the national energy modal code, 
IECC, thus using similar terms can provide consistent language across the indust ry.  
The other proposed change in Section 160.5(b)4Aii  modi fies the section for clarity , by 
consolidating Exception 1 into Section 160.5(b)4Aii, and thus eliminating the need for 
the Exception. The change will provide a code language easier to read and 
comprehend.  
Necessity: The change renames  the terms, “manual controls” and “enclosed spaces” 
will provide an easier comprehension to readers who may use both the IECC and 
California Energy Code. The name changes do not alter the mandatory requirements of 
the section for providing manual controls for the mandated locations.  
The change to clarify and revise Section 160.5(b)4Aii and the corresponding exception  
is reasonably necessary to provide more concise language that can be easier to read 
and are less burdensome to comprehend.  
The changes improve the general clarity and internal consistency of the Energy Code, 
as directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
Section 160.5(b)4B  
Specific Purpose: The proposed change is to rename “enclosed space” (previously 
term “enclosed area”). The term is used in the national energy modal code, IECC and 
using similar terms can provide a code language widely available to read and 
comprehend.  
The second proposed change consolidate s the controls requirements of Table 160.5 -B 
and the two subsections into one article of Section 160.5(b)4B. The change also 
removes  Table 160.5 -B. The requirements to maintain “illuminance uniformity” and to  
 provide “continuous dimming from 10 -100 percent” are retained and moved to be part of 
Section 160.5(b)4B. The continuous dimming from 100 -10 percent is retained as the 
continuous dimming requirement is applicable to LED light sources, which is widely 
adopted and used in all commercial and nonresidential lighting applications. The 
controls requirements for fluorescent lamp s as light sources are not proposed to be 
retained as California law (AB -2208) bans the sales and distribution of fluorescent 
lamps as a n ew manufactured product after 2024 and 2025 – banning screw and 
bayonet base type compact fluorescent (CFL) lamps after January of 2024 and banning 
pin-base type CFL) and linear fluorescent lamps after January of 2025.  
The HID and induction light source requirements in Table 160.5 -B is retained and 
moved to a new Exception 3 of Section 160.5(b)4B. Th is change address es the 
scenario for occasions that the light sources may still be used for the lighting 
applications.  
The third proposed change is to clarify the Exception about the enclosed space that has 
only one luminaire and to revise that as long as there is only one luminaire in the space 
it is not required to comply with the multilevel lighting controls requirement s. The 
change is to clarify the requirements related to LED light source technology and LED 
luminaires that they are widely adopted and in used in all commercial and nonresidential 
lighting applications and LED light sources are not in the form factor of l amps.  
Necessity: These changes are reasonably necessary to ensure that the usage of the 
same term “enclosed space” is used consistently and thus  provide an easier 
understanding of the Energy Code  readers and code users,  who may use both the 
IECC and California Energy Code. The name changes do not alter the mandatory 
requirements of the section for providing multilevel lighting controls for the mandated 
locations.  
The changes to revise and consolidate the requirements of Section 160.5(b)4B, 
including removal of Table 160.5 -B and consolidation of the two subsections (previously 
i. and ii.)  into an article of Section 160.5(b)4B, are reasonably necessary to provide 
concise language that can be easier to read and are less burdensome to comprehend.  
The change to clarify and revise Exception 1 of this section, regarding  enclosed space 
that has only one luminaire  is reasonably necessary to address the new form factor of 
LED light source technology and LED luminaires.  
The changes improve the general clarity and internal consistency of the Energy Code, 
as directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
Section : Exception 1 to 160.5(b)4B  
Specific Purpose : The proposed change clarif ies the scenario of an enclosed space 
that has only one luminaire . It revise d to convey  that as long as there is only one 
luminaire in the space it is not required to comply with the multilevel lighting controls 
requirements. The change clarif ies the requirements related to LED light source 
technology and LED luminaires that they are widely adopted and in used in all 
commercial and nonresidential lighting applications and LED light sources are not in the 
form factor of lamps.   
 Necessity : The change to clarify and revise the exception about the enclosed space 
that has only one luminaire is reasonably necessary to address the new form factor of 
LED light source technology and LED luminaires. The changes improve the general 
clarity and inte rnal consistency of the Energy Code.  
 
Section : Exception 3 to 160.5(b)4B  
Specific Purpose : The proposed change adds  a new Exception 3.  
Necessity : The change to add the exception is necessary to address the scenario 
where the light source of HID and induction may still be used for meeting the multilevel 
lighting control requirements  and the installation scenario s of the HID and induction light 
source that meet  the exception . The changes improve the general clarity and internal 
consistency of the Energy Code.  
 
Section : 160.5(b)4C  
Specific Purpose: The specific purpose is to delete “Automatic” from the heading.  
Necessity: The change to delete “Automatic” is necessary to use the same term, “shut -
OFF controls” in both Section 130.1(c ) and 160.5(b)4C for the similar lighting controls 
requirements of shut -OFF controls. The change is necessary to avoid any confusions 
from using different names of the term.  
  
Section : Exception to Section 160.5(b)4C  
Specific Purpose: The specific purpose is to move the means of egress illumination as 
an exception to Section 160.5(b)4C and to revise language to improve the readability of 
the standards . The change to move the means of egress illumination as an exception to 
Section 160.5(b)4C is that the means of egress illumination is a life safety requirement 
taking precedence to the shut -off controls requirement. The exception was an exception 
to Section 160.5(b)4Ci.  The editorial changes include adding the phrase “continuous 
illuminati on” so that it reads “continuous illumination of up to 0.1 watts per square foot in 
any area designated for egress within a building is allowed” and revising the phrase “as 
defined in the California Building Code” (was “as the term is used in the Californi a 
Building Code”).  
Necessity: The change to move the means of egress illumination as an exception to 
Section 160.5(b)4C is needed  because  means of egress illumination is a life safety 
requirement taking precedence to the shut -off controls requirement. The editorial 
changes clarify  the allowance of continuous illumination for the means of egress 
illumination and state s it more accurately to algin the term “means of egress 
illumination” as defined in the California Building Code.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : 160.5(b)4Ci  
Specific Purpose: The specific purpose is to delete the phrase “In addition to lighting 
controls installed to comply with Sections 160.5(b)4A and B”.   
 Another specific purpose is to clarify the time delay requirement of occupant sensing 
controls. The change specifies that the control time -delay setting should be no more 
than a 20 -minute time delay.  
The other specific purpose is to clarify separate shutoff control zones are required for 
each space exceeding 5,000 square feet.  The change revises the term as “separate 
control zones” (previously  “separate controls”).  
Necessity : The proposed change to delete the phrase “In addition to lighting controls 
installed to comply with Sections 160.5(b)4A and B” removes  redundant language as 
Section 160.5(b)4A and B are mandatory for all installed indoor controls and the phrase 
does not provide any new information to the code readers.  
The proposed change to specify the time -delay setting of occupant sensing controls 
clarifies  that the time -delay setting required under Section 110.9 also applies to the 
occupant sensing controls specified under Section 160.5(b)4C. This is reasonably 
necessary to include the time -delay setting requirements in this portion of the code so 
that this impo rtant information related to energy and cost savings from using the 
occupant sensing controls is readily available for readers to comprehend the code 
requireme nts. 
The change is reasonably necessary to clarify by using the phrase “separate control 
zones” to convey the same control system can be used to control a space larger than 
5,000 square feet as long as each control zone is designated for a space not exceeding 
5,000 square feet.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : Exception 2 to Section 160.5(b)4Ci  
Specific Purpose : The specific purpose update s the list of sections for which lighting in 
compliance with each section is not required to comply with the requirements of Section 
160.5(b)4Ci in order to reflect the changes within the shut -OFF controls section of 
Section 160.5(b)4C. The change remove s Section 160.5(b)4Cvii from the list and add s 
Section 160.5(b)4Cvic.  
Necessity : The change to the list of sections in the exception (Exception 2 to Section 
160.5(b)4Ci) is to reflect other changes within the shut -OFF controls section of Section 
160.5(b)4C. The change is necessary to ensure consistency and correctness of the 
code language.  
  
Section : Exception 3 to Section 160.5(b)4Ci (Exception 3 in the 2022 Code)  
Specific Purpose : The specific purpose of the change is to remove and update the 
numbering of the exception s in this section . 
Necessity : The change is reasonably necessary to ensure  the numbering of the section 
is updated as part of the editorial changes to arrangement of the content of the Energy 
Code . 
  
Section : Exception 4 to Section 160.5(b)4Ci (Exception 5 in the 2022 Code)   
 Specific Purpose : The specific purpose is to clarify what is considered to be “lighting 
equipment designated for emergency lighting” and the change is to delete the phrase, 
“connected to an emergency power source or battery supply”, from the Exception to 
Section 160.5(b)4 Ci. 
Necessity : The change to delete the phrase, “connected to an emergency power 
source or battery supply”, is to harmonize standards between California Energy Code 
and California Electrical Code about lighting equipment designated for emergency 
lighting. California Electrical Code specify how emergency systems including 
emergency lighting and “lighting equipment that is designated for e mergency lighting” to 
be connected to emergency source. The change to delete the phrase would  avoid any 
confusions about which  codes to comply with about the connection requirements of 
emergency lighting.   
  
Section : 160.5(b)4Ciii and iv  
Specific Purpose : The specific purpose clarif ies the automatic time -switch control 
requirements.  
The changes include the following:  
- the removal of the phrase “other than an occupant sensing control” from Section 
160.5(b)4Ciii and iv.  
- The addition of a new exception s (Exception to Section 160.5(b)4Ciii, and 
Exception 2 to Section 160.5(b)4Civ) to the automatic time -switch control 
requirements. The exception is for areas where occupant sensing controls are 
installed.  
- The addition of Exception 1 to section 160.5(b)4Ciii regarding shut off features in 
restaurants.  
- The removal of the subsection 160.5(b)4Ciiia.   
Necessity : The change to remove the permissive phrase “other than an occupant 
sensing control” is to avoid an over -burdensome language without altering the 
mandatory automatic time -switch control requirements.  
The change to add the new exception s for areas where occupant sensing controls are 
installed is to clarify that the installation of occupant sensing controls would eliminate 
the obligation for these areas to comply with the automatic time -switch installation 
requirements.   
The editorial changes about the automatic holiday shut -off features of automatic time -
switch control is to clarify with an emphasis the exception refers to the automatic holiday 
shut-off features so that the code requirements are easier to read and comprehend.  
The change to remove subsection 160.5(b)4Ciiia is to remove the redundant language 
about meeting Section 160.5(b)4A as all occupant sensing controls including automatic 
time-switch controls are required to meet Section 160.5(b)4A.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
   
 Section : 160.5(b)4Ciii - Exception to Section 160.5(b)4Ciii  
Specific Purpose : The specific purpose is to add a new exception for "areas where 
occupant sensing controls are installed".  
Necessity : The change to add a new exception for areas where occupant sensing 
controls are installed is necessary to clarify that the installation of occupant sensing 
controls would eliminate the obligation for these areas to comply with the automatic 
time-switch installation requirements.   
  
Section : 160.5(b)4Civ - Exception 1 to Section 160.5(b)4Civ  
Specific Purpose : The specific purpose is to add a new exception for "Automatic 
holiday shut -OFF features are not required in restaurants".  
Necessity : The change to add a new exception for restaurants that "automatic holiday 
shut-OFF features are not required" is necessary  to avoid any confusions about the 
applicable  requirements of automatic time -switch control.  
  
Section  160.5(b)4Civ - Exception 2 to Section 160.5(b)4Civ  
Specific Purpose : The specific purpose is to add a new exception for "areas where 
occupant sensing controls are installed".  
Necessity : The change to add a new exception for areas where occupant sensing 
controls are installed is necessary to clarify that the installation of occupant sensing 
controls would eliminate the obligation for  these areas to comply with  the automatic 
time-switch installation requirements.   
  
Section  160.5(b)4Cv  
Specific Purpose : The specific purpose is to delete the phrase “of any size” from the 
term “conference rooms” and the term “restrooms .” 
The other purpose is to add “and in restrooms” to the regulation about “areas not 
required by Section 160.5(b)4B to have multi -level lighting controls” and to add 
“automatic full -on” to the regulation about occupant sensing controls that are “in areas 
not required by Section 160.5(b)4B to have multi -level lighting controls .” 
Necessity : The change to delete the phrase “of any size” is necessary to delete the 
redundant language as the phrase “of any size” does not add more information about 
the requirement.  
The change to add “and in restrooms” to the regulation about “areas not required by 
Section 160.5(b)4B to have multi -level lighting controls” is necessary as restrooms are 
not required to comply with the multi -level lighting controls requirements as stated in 
Section 160.5(b)4B. The change clarif ies lighting controls required for restrooms.  
  
Section  160.5(b)4Cvi  
Specific Purpose : The specific purpose is to delete the phrase "in addition to 
complying with Section 160.5(b)4Ci”.  
Necessity : The change to delete the phrase "in addition to complying with Section 
160.5(b)4Ci” is to remove the phrase as it is already a mandatory requirement for all  
 indoor lighting controls, including this section (Section 160.5(b)4Cvi and vii) to comply 
with Section 160.5(b)4Ci.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  160.5(b)4Cvib  
Specific Purpose : The specific purpose add s a requirement in section 160.5(b)4CvibI  
that offices greater than 250 square feet will be shown on plans for occupancy sensor 
control zones. The occupancy sensor control zone information is essential information 
to communicate across various parties including designers, installers, building off icials, 
and acceptance testing agents to provide compliance with the occupancy sensing 
controls in offices greater than 250 square feet.   
The other specific change clarifies the occupant sensing controls lighting power 
reduction level. It revises the phrase “to no more than 20 percent” (previously indicated 
as “by at least 80 percent”) in Section 160.5(b)4CvibII.  
Necessity : The change to require occupancy sensor zones to be shown on plans is to 
ensure this essential information is documented for showing compliance to the 
requirements and can be readily communicated across various parties including 
designers, installers, bui lding officials and acceptance testing agents and the occupancy 
sensing controls.   
The change to use the phrase “to no more than 20 percent” is to use the same phrase 
in another subsection and using the same phrase can ensure consistency in the code 
language and to provide a code easy to understand.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  160.5(b)4Cvi c; and Section 160.5(b)4Cvi i 
Specific Purpose : The changes here include removing language from 160.5(b)4Cvii to 
a new section 160.5(b)4Cvic. The specific purpose i move s the occupant sensing 
parking space requirements - for parking garages, parking areas and loading and 
unloading areas currently located as 160.54Cvii - to a new subsection, Section 
160.5(b)4Cvic, which is within 160.5(b)4Cvi. The requirements of the former  Section 
160.5(b)4Cvii regarding compliance with Section 160.5(b)4Ci is retained by including 
the phrase “that meet the requirements below instead of complying with Section 
160.5(b)4Ci” as part of the new Section 160.5(b)4Cvic - for parking garages, parking 
areas and loading and unloading areas.  
The other specific purpose of the change is to clarify the classification of indoor lighting 
as applicable to interior areas of parking garages and the classification of outdoor 
lighting as applicable to parking areas on the roof of a parking structure. The change 
does not alter the mandatory requirements of occupant sensing controls for the parking 
garages, parking areas and loading and unloading areas covered by Section 
160.5(b)4Cvic.   
 Necessity : The change to move Section 160.5(b)4Cvii to Section 160.5(b)4Cvic is to 
reduce o subsection s in the  Energy Code  to be more concise and easier to navigate 
and comprehend.  
The change to clarify the classifications applicable to interior areas of parking garages 
and parking areas on the roof of a parking structure is to reduce any confusion arising 
from the interpretation of parking garages and parking structures meeting the 
occupancy sensing controls requirements of Section 160.5(b)4Cvic.  
The proposed changes are reasonably necessary to ensure the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  160.5(b)4D  
Specific Purpose : The specific purpose of the changes to this section are to revise and 
update the daylight responsive controls (also known as automatic daylighting controls) 
requirements of Section 160.5(b)4D in consideration of a proposal measure received 
(Docket document TN#251803, Docket Numbe r 22-BSTD -01). The changes are listed 
as follows : 
- Change  the section title and the term “automatic daylighting controls” to “daylight 
responsive controls” throughout Section 160.5(b)4D and other parts of the Part 6, 
California Energy Code. The change is to use the term “daylight responsive 
controls” to match a similar term provided by the national energy modal code, 
IECC.  
- Reduce  the general lighting wattage trigger threshold from 120 watts to 75 watts 
for skylit daylit zones, primary sidelit daylit zones, and secondary sidelit daylit 
zones to the daylight responsive controls requirements (was “Automatic 
daylighting controls” requ irements). Also, add specified language for the code -
triggered thresholds of general lighting within skylit daylit zones, general lighting 
within primary sidelit daylit zones and general lighting within secondary sidelit 
daylit zones. Further, Except ion 3  to Section 160.5(b)4D  is revised with wattage 
level of the general lighting luminaires in the secondary side lit  daylit zone for 
which daylight responsive controls are not required for the secondary side lit  
zone I.  To add a new numbering  (Section 160.5 (b)4D.1 thru  5) for locations that 
shall comply with the daylight responsive controls requirements and that are 
based on the proposed general lighting wattage trigger thresholds.  
- Move the daylight responsive control requirement for parking garages in 
Exception 4  (was Exception 4 to Section 160.5(b)4D)  to Section 160.5(b)4D 5. 
The change is to produce the code easier to navigate and comprehend.  
- Clarify  the daylight responsive controls requirements for long general lighting 
luminaires and the manner that the long general lighting luminaires can be 
controlled for the daylight responsive controls. The change to Section 
160.5(b)4D7 c (was Section 160.5(b)4Dii ) is to replace the term “linear LED and 
other solid -state lighting (SSL) light sources” with “general lighting luminaires  
 longer than 8 feet” and to revise the daylight responsive controls requirement as 
“general lighting luminaires longer than 8 feet shall be controlled as segments of 
8 feet or less according to the type of the daylit zone in which the segment is 
primarily l ocated”. Allowing general lighting luminaire of segments to be up to 8 
feet long for meeting the requirements would address the likely cost impacts from 
using linear luminaires of short segment – as linear luminaires typically come in 
8-feet segment.  
- Clarify  the daylight responsive controls shall adjust the lighting thru continuous 
dimming. The change to  Section 160.5(b) 4D8 (was Section 160.5(b)4Diiia ) is to 
delete the control type with stepped controls and to add the allowance of 
multilevel controls to adjust the light level.  The change is to specify the daylight 
responsive controls with continuous controls in order to align with the ubiquitous 
usage and installation of LED luminaires.   
- Add a new subsection 160.5(b)4Dvi 130.1(d) 11, “interactions with other lighting 
controls”. This change is to retain the requirements of Section 160.5(b)4F related 
to daylight responsive controls (was “Automatic Daylighting Controls”).   
Necessity : The proposed changes to revise and update the daylight responsive 
controls are reasonably necessary as the changes have been demonstrated to be 
technically feasible and cost effective on the docket document (Docket document 
TN#251803, Docket Number 22 -BSTD-01). The reorganization of the text with new 
numbering and other editorial changes with the sign -post language are reasonably 
necessary to provide a code language easy to read and comprehend.  
The proposed change to revise the requirements for long general lighting luminaires 
and the controls manner are necessary to lessen unnecessary cost burden of any 
unnecessary luminaire segments shorter than 8 feet. The proposed change to add a 
subsection o f “interactions with other lighting controls” are reasonably necessary to 
retain the controls interactions requirement from the proposed -to-be-deleted language 
of Section 160.5(b)4F. The proposed changes are reasonably necessary to ensure the 
general clari ty and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
Section  160.5(b)4F  
Specific Purpose: The specific changes here remove the language regarding manner 
of a lighting control in interaction with other lighting controls because  they are not 
necessary given there are already requirements in 160.5(b)4 and 110.9 about 
mandatory indoor lighting controls. The controls interaction language for automatic 
daylighting controls is retained and moved to the daylighting section (the daylight  
responsive section), and the requirements about occupancy sensing controls as 
permitted to be used in the space -conditioning systems remain in the section.  
The specific change deletes Section 160.5(b)4F with the exception of the language 
found in Section 160.5(b)4Fix. The section title is revised to “Occupancy Sensing  
 Controls Interactions with Space -conditioning Systems”. The numbering of the 
subsection is also removed as it is not needed.  
Necessity:  
The change to delete a set of code language that serve as clarifications for lighting 
controls interactions is necessary to remove redundancy in requirements already 
present in Section 160.5(b)4 and 110.9 regarding lighting controls.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
 
Section  Table 160.5 -B 
Specific Purpose : The proposed change is to delete Table 160.5 -B. 
Necessity : The change to delete Table 160.5 -B is necessary to consolidate the 
requirements into an article of Section 160.5(a)1A. The changes improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section  11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section : Exception 8 to Section 160.5(c)1  
Specific Purpose : The specific purpose of the change add s a new exception for 
luminaires that qualify as exceptions in Part 11 of Title 24. This is to harmonize the 
exceptions of the two codes, Part 6 and Part 11 of Title 24.  
Necessity : This change to add a new exception for luminaires that qualify as 
exceptions is necessary to harmonize between Part 6 and Part 11 of Title 24 for the 
backlight, uplight and glare requirements for outdoor luminaires.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code  
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
 
Section  160.5(c)2B ii 
Specific Purpose: The specific purpose of the change clarif ies the outdoor lighting 
power reduction level of the automatic scheduling controls requirements. The change 
adds “partially” to the phrase “reducing the outdoor lighting power” and revises the 
phrase “by at least 50 percent and no more than 90 percent” to “b y 50 to 90 percent”.  
Necessity: This change is needed to clarify the outdoor lighting power reduction level, 
assisting code users to comprehend the outdoor lighting power reduction level required 
for the automatic scheduling controls requirements and avoids confusion from the 
phrase “no more than 90 percent” in the 2022 Energy Code.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section  160.5(c)2Ci   
 Specific Purpose: The specific purpose of the change is to consolidate the subsection 
within Section 160.5(c)2Ci (formerly, 160.5(c)2Cia) into one article of Section 
160.5(c)2Ci. The change adds the outdoor locations (including general hardscape, 
parking lots, and outdoor c anopies) required for motion sensing controls to Section 
160.5(c)2Ci and adds the phrase “and for which the bottom of the luminaire is mounted 
24 feet above grade or lower”.  
The other change to the section delete s the permissible code language about motion 
sensing controls installation  in combination with other outdoor lighting controls.  
The specific purpose of the change clarif ies the outdoor lighting power reduction level of 
the motion sensing controls requirements.  
The change to Section 160.5(c)2Cii is to add “partially” to the phrase “reducing the 
outdoor lighting power” and to revise the phrase “at least 50 percent and no more than 
90 percent” as “50 to 90 percent”.  
 The changes in this section delete the permissible requirement about motion sensing 
controls that may be installed in combination with other outdoor lighting controls.  
Necessity : The change to consolidate the subsection within Section 160.5(c)2Ci and to 
add the list of outdoor locations required for motion sensing controls is to produce a 
code with less subsections  and language that is more concise and can be read in a 
straightforward  manner . Also,  the change to delete the permissible requirement does 
not change other mandatory requirements of the section  and it does produce a code 
with more concise language so that the code is easier to navigate and comprehend .        
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section  160.5(c)2Ci a and 160.5(c)2Cib  
Purpose : The specific purpose of the change repeals the motion sensing controls 
requirement of bilaterally symmetric outdoor wall mounted luminaires (“wall packs”) 
providing building façade, ornamental hardscape or outdoor dining. The change deletes 
Section 160.5 (c)2Cia and adds “luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining” to Exception 2 to Section 160.5(c)2C.  
.   
Necessity: The change to repeal s the motion sensing controls requirement of bilaterally 
symmetric outdoor wall mounted luminaires (“wall packs”) providing building façade, 
ornamental hardscape or outdoor dining amends the situation where motion sensing 
controls are inappropriate for the lighting applications of façade lighting, ornamental 
hardscape lighting and outdoor dining lighting.  
The changes are necessary as luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining are different from wall pack luminaires for 
illuminating building edge parking, walkways, building perimeter identification, entry and 
exit and security.  
Wall pack luminaires is described as “ lighting equipment that is typically attached to a 
building wall or other vertical exterior surface and that provides illumination for building 
edge parking, walkways, building perimeter identification, entry and exit and security ”.  
 (“BBA High Efficiency Wall Pack Lighting Specification & Guidance”, A Better Buildings 
Alliance (BBA) Project, page 1.) (Link: 
https://betterbuildingssolutioncenter.energy.gov/sites/default/files/attachments/high -
efficiency -wall-pack -specification.pdf  ) 
Luminaires providing lighting for building facades serve both functionally and 
decoratively to aim at the façade and to illuminate the façade without obstruction or 
interference. As such, façade luminaires are different from wall pack luminaires.  
Ornamental hardscape lighting is not the same as wall packs and ornamental 
hardscape lighting is defined in the Energy Code as lighting and luminaires installed 
outdoor and are rated 50 watts or less that are post -top luminaires, lanterns, pendant 
luminaires, chandeliers and marquee lighting.  
Luminaires providing lighting for outdoor dining serve the outdoor eatery and associated 
hospitality activities and the luminaires do not serve the same purpose as wall pack 
luminaires provided, including illumination for parking, walkways, perimeter, 
identification entry and exit security.  
In summary, luminaires providing lighting for building façade, ornamental hardscape or 
outdoor dining are different from wall pack luminaires for illuminating building edge 
parking, walkways, building perimeter identification, entry and exit and security.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
  
Section: 160.5(c)2Cii  
Purpose: The specific purpose of the change clarif ies the outdoor lighting power 
reduction level for the motion sensing controls requirements. The change to Section 
160.5(c)2Cii add s “partially” to the phrase “reducing the outdoor lighting power” and 
revises  the phrase “at least 50 percent and no more than 90 percent” as “50 to 90 
percent”.     
Necessity: The change to clarify the outdoor lighting power reduction level helps code 
users comprehend the outdoor lighting power reduction level required for the automatic 
scheduling controls and avoid s confusion of the phrase “no more than 90 percent” from 
the 2022 Energy Code. The change is necessary to produce a code language easy to 
read and comprehend.   
  
Section:  Exception 2 to Section 160.2(c)2C  
Purpose: The change is to add “luminaires providing lighting for building façade, 
ornamental hardscape or outdoor dining” to Exception 2 to Section 160.2(c)2C.    
Necessity: The changes are necessary as luminaires providing lighting for building 
façade, ornamental hardscape or outdoor dining are different from wall pack luminaires 
for illuminating building edge parking, walkways, building perimeter identification, entry 
and ex it and security.  
The changes are reasonably necessary to ensure and improve general clarity and 
internal consistency of the Energy Code, as directed by California Government Code 
Section 11349 and 11349.1 and California Code of Regulations, Title 1, Section 16.  
   
 Section  160.6(d)  
Specific Purpose : The specific purpose of the change is to remove  the note language 
previously located  in Section 160.6(d) as well as to add language in the body of this 
section  to the effect that plug -in strips and other plug-in devices cannot be used to 
comply with the requirements of Section 160.6(d).  
The changes include removal of the word “note” preceding the sentence and removal of 
the sentence about hardwired power strip controlled by an occupant sensing control.   
Further, the changes include moving the sentence about “hardwired power strip, plug -in 
strips and plug -in devices” to the beginning of Section 160.6(d).  
Necessity : The proposed change to relocate the note previously provided in Section 
160.6(d) about “hard -wired power strips, plug -in strips and plug in devices” is necessary 
to be clear about what is required in this section as providing it in a note could be 
interpreted  as information al and thus not an official part of the code language.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . 
  
Section 160.6(d)2  
Specific Purpose: The specific purpose of the change is to clarify the placement of 
controlled receptacle and uncontrolled receptacle at the same location. The specific 
change replace s the word “ splitwired ” with “multiple” in the phrase so that the phrase 
reads “multiple receptacle”. The term “multiple receptacle” is defined in California 
Electrical Code, whereas the term “splitwired receptacle” is not.   
Necessity: The proposed change of using the term “multiple receptacle” is to avoid any 
confusion of the term previously used, “splitwired receptacle”. The term “multiple 
receptacle” is defined in the California Electrical Code as two or more contact devices 
on the sa me yoke or strap, and the new term is a more accurate term to be used in 
Section 160.6(d)2 for the scenario where there are two contact devices. The proposed 
change is reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code and to ensure and improve the consistency of the 
Energy Code with other provisions of law, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section  160.6(d)3  
Specific Purpose: The specific purpose of the change is to delete the word “durable” 
from the marking requirements of controlled receptacles.  
Merriam Webster dictionary defines “durable” to mean “able to exist for a long time 
without significant deterioration in quality or value.” There is no other requirement about 
the “durable” marking requirement of controlled receptacles in the Energy Code.  
Necessity: The California Electrical Code requires controlled receptacles to be 
permanently marked, and aligning with the requirements of the California Electrical 
Code that controlled receptacles should be permanently marked with the symbol and 
the word as specified in the Electrical Code. The change is necessary to ensure the  
 Energy Code and the Electrical Code are in harmony on the marking requirement of 
controlled receptacles.  The proposed change  to repeal part of the marking 
requirements of controlled receptacles  is reasonably necessary to ensure and improve 
the consistency  and improve general clarity  of the Energy Code with other provisions of 
law, as directed by California Government Code, Section 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
 
Section:  160.7(b) Pool and Spa Systems  
Specific Purpose:  The specific purpose of this change is to add references to relevant 
requirements for pool and spa systems installed for public use  for internal consistency 
and clarity . 
Necessity:  These changes are necessary to align with changes made to 
Section150.0(p) and to the Title 20 Appliance Standard for the 2025 code cycle  
regarding requirements specific to pool and spa systems .  These terms ensure and 
improve the general clarity and internal consistency of the Energy Code as directed by 
California Government Code Sections 11349 and 11349.1, and California Code of 
Regulations, Title 1, Section 16.  
  
Section:  160.8 End of section NOTE  
Specific Purpose : The authority Sections and  the Public Resources Code sections 
were missing. This section is not considered regulatory text.   
Necessity : Added to provide clarity of the authority  bestowed on the C EC to develop 
this section of the Energy Code.   
 
Section:  160.9(a); (b) -(d) 
Specific Purpose:  Inserted a new subsection at the beginning of Section 160.9 withteh 
specific aim of incorporating general requirements applicable for all electric ready 
requirements  thereby replacing the former  section (a) . This new requirement ensures 
the entire building’s electrical system have sufficient capacity to supply full rated 
amperage for all electric ready appliance in accordance with the California Electrical 
Code. Subsequen t sections are renumbered  to reflect this change . Additional minor non 
substantive changes for clarity.  
Necessity:  These changes align with industry best practice and are necessary to 
ensure the building is fully prepared for future installation of electric appliance. These 
terms ensure and improve the general clarity and internal consistency of the Energy 
Code as directed by California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
 
  
Section:  160.9(d)2A  
Specific Purpose:  The specific purpose of this change is to remove language related 
to conductor sizing.  
Necessity:  This language is superseded by the new electric system sizing 
requirements in 160.9(a), and therefore is no longer needed.   
   
Section:  160.9(e)  
Specific Purpose:  The specific purpose of this newly added subsection  is to relocate 
existing electric ready requirements for individual heat pump water heater from Section 
160.4(a)  to this section and  add a new ventilation requirement  and designate space for 
future location of heat pump water heater . The requirement for the 10 A merican Wire 
Gauge ( AWG ) copper branch circuit has been changed to  rated  30 amps minimum, 
similar to changes made to Section 150.0(n)1Ai.  
Necessity:  These changes are necessary to ensure the building is fully prepared for 
future installation of individual heat pump water heater.  The change to 30 amp s is 
necessary to eliminate concerns that the current requirement is overly prescriptive and 
may interfere with electrical code requirements for branch circuit sizing in some cases. 
These changes improve clarity of the requirements and thereby enhance code 
compliance and enforcement of the standards. Making the requirement in terms of 
ampere inste ad AWG aligns the electric ready requirements in other parts of the Energy 
Code.  
  
Section:  160.9(f)  
Specific Purpose:  The specific purpose of this change is to add electric ready 
requirements for central heat pump water heater. This new requirement includes space 
reserved for heat pump, storage tank  equipment and space , condensate drainage 
piping, and electrical bus.   
Necessity:  These changes are necessary to ensure the building is fully prepared for 
future installation of central heat pump water heater.   
  
Section : 170.1  
Specific Purpose : The specific purpose of this change is to clarify that energy budgets 
for multi -family buildings are expressed in terms of Long -Term System Cost in section 
170.1(a). Obsolete language stating that energy budgets are expressed in Time 
Dependent Evaluation  is deleted. Inaccurate sections 170.1(b) and 170.1(c) indicating 
that energy budgets are separately established for the standard design building and the 
proposed building are eliminated. Explanation of how the energy budget is calculated 
for the standard design building using Commission -certified compliance software is 
stated clearly and succinctly in section 170.1.  
Necessity: These changes are necessary to clarify and make specific how the energy 
budget is calculated and the use of the terms to be used for establishing energy 
budgets. These changes align language that has the same purpose in sections 140.1, 
150.1(b) and 170.1. and the redundant section 170.1(c) is eliminated.  
  
Section: 1170.1(b)2D  
Purpose:  The Thermal Balance Valve requirement was placed in   subsection D 
because  subsection D was initially reserved as a placeholder for future requirements  
and this simplifies the code .  
 Necessity:  These changes are essential to make sure that the provisions in the 
subsection are clear and unambiguous, enabling non -technical readers to easily locate 
and comprehend the technical requirements.  
  
Section: 170.1(b)2F , 170.1(b)2G, and 170.1(b)2J  
Purpose:  The purpose of this change is to remove the performance credit options for 
multifamily buildings for whole house fans, central fan ventilation cooling systems, and 
precooling, a s they are infrequently installed in multifamily buildings . 
Necessity:  This change is needed to simplify requirements and code language relate d 
to multifamily buildings  and streamline those requirements where possible.  
 
Section:  170.2(a)1A – Exceptions 1 and 2  
Purpose:  The specific purpose of this change is to clarify that when meeting Exception 
1 or Exception 2 then the user is not required to comply with Section 170.2(a)1A.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section:  170.2(a)3Aii - Exception 5   
Purpose:  The specific purpose of this change is to clarify that the visible transmittance 
requirements apply to fenestration serving common use areas in all multifamily 
buildings, and not to fenestration in dwelling units.  
Necessity: Daylighting controls are not mandated in dwelling units, though they are 
mandated in other areas of multifamily buildings. This clarification ensures that 
language matches the intent of the Energy Code’s requirements. Increasing a 
fenestration product’s vi sible transmittance ensures that where daylighting controls 
exist, that the natural daylight can be maximized so that illumination from installed lights 
can be reduced and unnecessary consumption of energy can be reduced, as directed 
by Californ ia Public Resources Code Sections 25213 and 25402.  
 
Section: Section: 170.2(a)3iv - Exception  4 
Purpose:   The specific purpose of this change is to clarify that the visible transmittance 
requirements apply to fenestration serving common use areas in all multifamily 
buildings, and not to fenestration in dwelling units.  
Necessity:   Daylighting controls are not mandated in dwelling units, though they are 
mandated in other areas of multifamily buildings. This clarification ensures that 
language matches the intent of the Energy Code’s requirements. Increasing a 
fenestration product’s visible transmittance ensures that where daylighting controls 
exist, that the natural daylight can be maximized so that illumination from installed lights 
can be reduced and unnecessary consumption of energy can be reduced, as directed 
by Califor nia Public Resources Code Sections 25213 and 25402.  
 
Section:  170.2(a)5B    
 Purpose:  The specific purpose of this change is to expand the slab floor perimeter 
requirements to buildings with more than three habitable stories and increase energy 
efficiency in these buildings when they are constructed with slab -on-grade floors.  
Necessity:  This change is necessary to continue to simplify the multifamily building 
requirements, removing delineations between low -rise and high -rise multifamily 
buildings, where requirements are cost effective and technically feasible. Increasing 
energy efficienc y via cost -effective building design standards reduces unnecessary 
consumption of energy, as directed by California Public Resources Code Sections 
25213 and 25402.  
 
Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to increase the prescriptive 
requirement for aged solar reflectance to 0.25  and the Solar Reflectance Index (SRI) to 
23 for High Performance Attic Option B.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.  
  
Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to extend the current aged solar 
reflectance (ASR=0.63), thermal emittance (TE=0.75), and solar reflectance index 
(SRI=75) prescriptive standards to Option D ( Non-Attic Roofs).  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.  
 
Section:  Table 170.2 -A – Slab Perimeter  
Purpose:  The specific purpose of this change is to expand the slab floor perimeter 
requirements to buildings with more than three habitable stories and increase energy 
efficiency in these buildings when they are constructed with slab -on-grade floors.  
Necessity:  This change is necessary to continue to simplify the multifamily building 
requirements, removing delineations between low -rise and high -rise multifamily 
buildings, where requirements are cost effective and technically feasible. Increasing 
energy efficienc y via cost -effective building design standards reduces unnecessary 
consumption of energy, as directed by California Public Resources Code Sections 
25213 and 25402   
 
Section:  Table 170.2 -A – F-Factor Note  
Purpose:  The purpose of this change is to add direction in the form of a footnote for 
designers using alternate depth and R -values when compared to F -factors, to comply 
with the Energy Code’s slab perimeter insulation requirements.  
Necessity : This change is necessary to improve clarity and consistency of the Energy 
Code.  
  
 Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to consolidate the Maximum RSHGC 
prescriptive standards for Curtain Wall/Storefront fenestration for multifamily buildings 
four or more habitable stories with the Maximum RSHGC prescriptive standards for 
multifamily buildings three habitable stories or less.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to consolidate the Maximum RSHGC 
prescriptive standards for NAFS 2019 Performance Class AW fenestration, for 
multifamily buildings four or more habitable stories with the Maximum RSHGC 
prescriptive standards for mult ifamily buildings three habitable stories or less.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to reduce the Maximum U -factor 
prescriptive standard for All Other Fenestration to U -0.28 in climate zones 1, 3 -5, 11, 
and 13 -16. 
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.  
  
Section:  Table 170.2 -A 
Purpose:  The specific purpose of this change is to consolidate the Maximum RSHGC 
prescriptive standards for All Other Fenestration, for multifamily buildings four or more 
habitable stories with the Maximum RSHGC prescriptive standards for multifamily 
buildings thr ee habitable stories or less.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  170.2( c)2C  
Specific Purpose:  The purpose of this change is to add alternative sources of outdoor 
design conditions from the ASHRAE Handbook, Equipment Volume, Applications 
Volume and Fundamental Volume . These sources are already used for calculating 
cooling and heating load under Section 150(h)1. As part of this addition, the term 99.0 
percent Heating Dry Bulb is introduced as an alternative to Heating Winter Median of 
Extreme. This change aligns with sim ilar changes in Sections 140.4(b)3 and 150.0(h)2 . 
Necessity:  The necessity for this change is to increase flexibility in mechanical system 
design by allowing commonly used design conditions from the ASHRAE Handbook,  
 SMACNA Manual and ACCA Manual J. The addition of “99.0 percent Heating Dry Bulb” 
is a commonly used industry term from the ASHRAE handbook to calculate heating 
load.  This change is necessary so that wasteful energy consumption is reduced, as 
directed by PRC 25402 , and  to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section :170.2( c)3BiaIIIB  
Specific Purpose : The purpose of this change is to remove the option that allowed for 
refrigerant charge verification through the installation of equipment that utilizes a fault 
indicator display (FID).  
Necessity: These changes are necessary to clean up the energy code by removing a 
section that is  no longer needed. Various issues associated with FIDs that may impact 
their effectiveness or reliability are that industry codes are frequently misinterpreted, 
have limited diagnostic capabilities, senor accuracy has been poor, are not sensitive 
enough to detect small leaks or provide timely alerts and suffer from lack of 
standardization. Removal of the inclusion of the option for refrigerant charge verification 
through FIDs in the energy code can help improve overall system reliability and safety.  
 
Section: 170.2(c)3Biva and b  
Specific Purpose:  The specific purpose of this change is to update point iv including 
the requirements for balanced ventilation systems with heat/energy recovery ventilation 
systems to revise the prescriptive requirements in all newly constructed multifamily 
dwelling units  in climate zones 1, 2, 4, 11 through 14, and 16 to use balanced ventilation 
with an HRV or ERV.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as mandated by California Public Resources Code 
Sections 25213 and 25402. The measure is cost effective in Climate Zones 1, 2, 4, 11 
through 14, and 16 compared to supply -only ventilation or balanced ventilation without 
an HRV or ERV.  
   
Section:  170.2(c)3Bivb  
Specific Purpose:  
The purpose of this change is to correct minor errors in referencing, spelling and 
grammar.  
Necessity:  This change is necessary to better clarify or correct minor issues with the 
Energy Code. This benefits the CEC  by complying with California Government Code 
11349 and 11349.1 and California Code of Regulations title 1, Section 16.  
  
Section: 170.2(c)3Bivc  
Specific Purpose:  The specific purpose of this change is to strike out climate zone 4 
and add climate zone 15 to require a heat pump space conditioning system installed to 
meet the requirements of Section 170.2(c)3Ai.   
 Necessity: These changes are necessary to ensure and improve the general clarity 
and internal consistency of the Energy code. Requirements for heat pump space 
conditioning system in updated climate zones are to increase energy efficiency via cost -
effective building d esign standards while also maintaining adequate indoor air quality.  
  
Section: 170.2(c)3Bv  
Specific Purpose:  The specific purpose of this change is to include all HRV/ERV 
systems serving an individual dwelling unit to have an FID that is ECC -rater field verified 
as specified in the reference appendix JA17.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as mandated by California Public Resources Code 
Sections 25213 and 25402. JA17 specifies HRV/ERV system FID qualification 
requirements including categor ies, instrumentation and reporting, and manufacturer 
certification.  
  
Section : Exception 6 to 170.2(c)4Ci  
Specific Purpose : The specific purpose of the change is to reorganize language from 
170.2(c) 4N to Exception 6 to 170.2(c)4Ci  and to clarify language.  
Necessity:  These non -substantive changes are reasonably necessary to improve 
clarity on the requirements for the exception to economizing. These revisions were 
made to ensure and improve the general clarity and internal consistency of the Energy 
Code, as directed by  California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
  
Section: Section 170.2(c)4Fv and Exception 2  
Specific Purpose: The purpose of the proposed updates to this section are to  update 
cooling tower efficiency prescriptive requirements based on climate zone and to remove 
exceptions for climate zone 1 and 16.  
Necessity: The efficiency of cooling towers is now based on climate zone, where areas 
with higher cooling needs are subject to higher efficiencies. The higher cooling loads 
make it more economically feasible for higher efficiency to be installed. Although the 
exception for climate zones were removed, the minimum efficiency actually remains the 
same at the mini mum mandatory efficiency of the equipment. Reducing the energy 
usage of cooling towers will reduce excessive energy use as directed by California 
Public Resources Code 25213 and 25402.  
   
Section: Table 170.2 -I 
Specific Purpose: Add table specifying the cooling tower efficiency based on the 
climate zone.  
Necessity: The efficiency of cooling towers is now based on climate zone, where areas 
with higher cooling needs are subject to higher efficiencies. The higher cooling loads 
make it more economically feasible for higher efficiency to be installed. Although the 
excepti on for climate zones were removed, the minimum efficiency actually remains the 
same at the minimum mandatory efficiency of the equipment. Reducing the energy  
 usage of cooling towers will reduce excessive energy use as directed by California 
Public Resources Code sections 25213 and 25402.  
  
Section : 170.2(c)4N  
Specific Purpose : The specific purpose of the change is to provide clarity on the 
requirements of Dedicated Outdoor Air System  for the different configurations and to 
simplify code language by moving requirements related to economizing to the 
economizer section in Exception 6 to 170.2(c)4Ci. This change aligns with the 
Nonresidential section in 140.4(e) and (p ) and removes the greater than 1,000 CFM 
requirement .  
Necessity:  These changes are reasonably necessary to improve clarity and simplify 
code language , as directed by California Government Code Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16 . These changes 
provide consistency between the Nonresidential and Multifamily sections , which was the 
original intent in 2022 code cycle.  
  
Section : 170.2(d)  
Specific Purpose : The specific purpose of this change is to move requirements for 
recirculation systems to subsection 1 and 2.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 170.2(d)1 and Exception 1  
Specific Purpose : The specific purpose of this change is to remove subsection C for 
gas instantaneous water heaters. New exception 1 allows gas instantaneous water 
heaters for high -rise multifamily buildings.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code 
Sections 25213 and 25402.  
  
Section : 170.2(d)1 Exception 2  
Specific Purpose : The specific purpose of this change is to add new exception for 
120V heat pump water heater in place of 240V for dwelling with 1 bedroom or less.  
Necessity: These changes are necessary to add flexibility for small dwellings that might 
not need the capacity of 240V heat pump water heater. This aligns with existing 120V 
exception for single family buildings.  
  
Section : 170.2(d)2  
Specific Purpose : The specific purpose of this change is to reorganize the section to 
clearly separate requirements for individual hot water systems and central hot water 
systems.   
 Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 170.2(d)2A  
Specific Purpose : The specific purpose of this change is to update the prescriptive 
requirements for central heat pump water heaters and add new alternative option for 
NEEA Advanced Water Heater Specification for commercial heat pump water heater 
Tier 2 or higher.  The update limits the prescriptive option to single -pass  heat pump 
water heater , and requirement related to multi -pass systems have been removed.  Multi -
pass system can continue to meet the prescriptive requirement with the new NEEA 
alternative option.  The primary storage tank plumbing configuration requirement has 
been removed to allow design flexibility . The requirement  for a recirculation system and  
the exception for 8 or fewer dwellings have been reorganized and merged with the 
thermostatic mixing valve language in 170.2(d)2D . 
Necessity: These changes are necessary to add flexibility to the prescriptive central 
heat pump water heater requirements and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349. 1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 170.2(d)2B  
Specific Purpose : The specific purpose of this change is to  reorganize  the requirement 
for a recirculation system and the exception for 8 or fewer dwellings  and merged with 
the thermostatic mixing valve language in 170.2(d)2D . Additional minor substantive 
change  and section renumber ed for clarity.  
Necessity:  These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : 170.2(d)2C  
Specific Purpose : The specific purpose of this change is to add new prescriptive 
requirements for hot water distribution piping to be sized in accordance with the 
California Plumbing Code Appendix M.  
Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code 
Sections 25213 and 25402.  
  
Section : 170.2(d)2D  
Specific Purpose : The specific purpose of this change is to add new prescriptive 
requirements for thermostatic master mixing valves for central recirculation systems.  
Additionally, existing requirement for recirculation system and the exception for 8 or 
fewer dwellings have been reorganize d and merged with this section.   
 Necessity: These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code 
Sections 25213 and 25402.  
 
Section : 170.2(d)2G  
Specific Purpose : The specific purpose of this change is to move recirculation 
requirements to new subsection 2D.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : Table 170.2 -K 
Purpose:  The specific purpose of this change is to update the prescriptive HRV/ERV 
requirements in climate zones 04 and 15 in table 170.2 -K on mechanical component 
package requirements for Multifamily standard building design requirements.  
Necessity:  These changes are necessary to align with the prescriptive changes of 
requiring HRV/ERV in climate zone 04 and no longer requiring an HRV/ERV in Climate 
Zone 15 because the added measures are not cost -effective in Climate Zone 15 . These 
changes are necessary to ensure and improve general clarity and internal consistency 
of the Energy Code, as directed by California Government Code Sections 1 to increase 
energy efficiency via cost -effective building design standards, as mandated by  
California Publ ic Resources Code Sections 25213 and 25402.  
  
Section : 170.2(d)2E  
Specific Purpose : The specific purpose of revision is to renumber section references to 
reflect changes in Section 170.2(d)2.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : 170.2(d)2G  (Section Removed)  
Specific Purpose : The specific purpose of this change is to move recirculation 
requirements to new subsection 2D.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.   
 
Section  170.2(e)2B  
Specific Purpose : The specific purpose of the change is to clarify a number of the 
Power Adjustment Factors (PAF) requirements in Section 170.2(e)2B.  
The change is to add a new subsection of Section 170.2(e)2Bixe with requirements to 
specify occupancy sensor control zones in offices greater than 250 square feet to be 
shown on plans. Occupancy sensor control zone information is essential information to 
communicate across various parties including designers, installers, building officials and  
 acceptance testing agents for showing compliance to the occupancy sensing controls in 
offices greater than 250 square feet.   
Another change is to clarify the PAF requirements for the demand responsive controls 
receiving the PAF. The change is to update, in Section 170.2(e)2Bxib, the reference of 
the illuminance uniformity requirement to Section 160.5(b)4B (previously it was Tabl e 
160.5 -B) and to add a clarifying statement in Table 170.2 -L about the PAF is not 
available to demand responsive controls that are mandated under Section 110.12(c).  
Another change is to clarify in Section 170.2(e)2Bxii the PAFs for clerestory 
fenestration, horizontal slats or light shelves and the change is to correct the section 
numbering to Section 170.2(b) (was 140.3(d)).  
Necessity: The proposed change to require occupancy sensor zones to be shown on 
plans is to ensure this essential information is documented for showing compliance to 
the requirements and can be readily communicated across various parties including 
designers, installe rs, building officials and acceptance testing agents and the occupancy 
sensing controls.   
The change to clarify the PAF requirements for the demand responsive controls is to 
ensure the incentivized PAF provisions is allowed for the proper demand responsive 
controls – those demand responsive controls not mandated under Section 110.12(c).  
The change to clarify the PAFs for clerestory fenestration, horizontal slats or light 
shelves is reasonably necessary to correct the section numbering and to improve 
overall clarity and readability of the standards.  
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . Substantive proposed changes are necessary to increase energy 
efficiency via cost -effective building design standards, as directed by California Public 
Resources Code, Sections 25213 and 25402.  
  
Sections 170.2(e)2, 170.2(e)3, and 170.2(e)4  
Specific Purpose : 
The specific purpose of the change is to remove the “Tailored Method ” in Section 
170.2(e)2, 3, and 4, to revise related references, and to delete Section 170.2(e)3D, 
170.2(e)3E, 170.2(e)3F, 170.2(e)4A. v. e, 170.2(e)4B, and Table 170.2 -N thru Q – these 
sections and tables are directly related to the Tailored method.  
The other purpose of the change is to retain the additional lighting power allowances of 
the Tailored method by adding comparable allowances for lighting applications to the 
Area category method. The change is to add additional lighting power allowances Ta ble 
170.2 -M for the following applications:  
- Conference, multipurpose and meeting area;  
- Dining area – bar/lounge and fine dining;  
- Main entry lobby;   
The additional lighting allowances added for the “qualified lighting systems” column of 
Table 170.2 -M include lighting applications to the following:   
 wall display of mounting height less than or equal to 10 feet 6 inches;  
wall display of mounting height between 10 feet 7 inches to 14 feet;  
wall display of mounting height greater than 14 feet;  
floor display of mounting height less than or equal to 10 feet 6 inches;  
floor display of mounting height between 10 feet 7 inches to 14 feet;  
floor display of mounting height greater than 14 feet;  
valuable display case; and  
general lighting in the enclosed space of ceiling height greater than 10 feet.  
Further, the change is to remove Table 170.2 -N, O, P, and Q which are tables 
specifying the tailored method allowances or the tailored method calculations, to 
remove the subsections specifying requirements of the Tailored method and to revise 
related code language associated with Tailored method.  
The other specific purpose of the change is to move Table 170.2 -L and Table 170.2 -M 
succeeding the code language mentioning the table.  
Necessity : The proposed change to remove the Tailored method is to provide a simpler 
compliance approach through the area category method with similar additional lighting 
power allowances for specific lighting application that requires additional lighting.  
The area category method, with one table of Table 170.2 -M, is a much more straight 
forward and less cumbersome compliance methodology in comparison to the tailored 
method, which required multiple tables, Table 170.2 -N, O, P, and Q, to look up for the 
tailored lighting calculation process.  
The additional lighting power allowances for the applications (functional area types 
including Conference, Multipurpose and Meeting Area; Bar/Lounge and Fine Dining 
Area; Main Entry Lobby) are retained and added to the Area Category method as they 
are the most heavily used for the Tailored Method.   
The proposed change to move Table 170.2 -L and Table 170.2 -M succeeding the code 
language mentioning the table is to allow the tables easier to look up.   
The proposed change is reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16 . Substantive proposed changes are necessary to increase energy 
efficiency via cost -effective building design standards, as directed by California Public 
Resources Code, Sections 25213 and 25402.  
  
Section: Table 170.2 -N, O, P, and Q  
Specific Purpose: The specific purpose of the change to delete Table 170.2 -N, O, P, 
and Q.  
Necessity: As the Tailored method is removed, it is no longer necessary to have Table 
170.2 -N, O, P, and Q which holds information related to Tailored method. The change 
to delete the tables is necessary to ensure clarify of the code language. This change 
was necessa ry to ensure clarity and internal consistency within the Energy Code, as 
directed by California Government Code, Sections 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
Section: 170.2(e)2B   
 Specific Purpose: The specific purpose of the change to this section is to make non -
substantive formatting changes to remove unnecessary bolding of text to improve 
consistency and clarity.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 170.2(e)2Bix  
Specific Purpose: The specific purpose of the change to this section is to remove 
reference to “open plan office” and replace with “large office” to be consistent with 
Section 140.6(a)2I.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 170.2(e)2Bixa  
Specific Purpose: The specific purpose of the change to this section is to remove 
reference to “open plan” to be consistent with Section 140.6(a)2I.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 170.2(e)2Diii  
Specific Purpose: The specific purpose of the change is to delete  the tailored method 
display lighting mounting height lighting power adjustment  for the Tailored method .  
Necessity:  This change is necessary to delete  the subsections and requirements 
related to the Tailored method that is to be repealed  and the change is to ensure 
internal consistency within the Energy Code, as directed by California Government 
Code, Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 
16.    
 
Section: 170.2(e)3Ci  
Specific Purpose: The specific purpose of the change to this section is to update the 
section reference from Section 170.2(e)1Ci to Section 170.2(e)4A.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : new  170.2(e)3D (not the existing 170.2(e)3D)  
Specific Purpose: The specific purpose is to specify that additional lighting power 
allowances shall not be used for general lighting unless the additional lighting power 
allowance is specified to be used for general lighting.  
The other purpose is to specify “additional lighting power allowances for display; 
decorative, wall display, floor display, or task” may not be increased as a result of, or 
otherwise traded off against, decreasing any other lighting power allotment.   
 Necessity : The change to specify that additional lighting power allowances shall not be 
used for general lighting is necessary to ensure additional lighting power allowances are 
used only for the qualified lighting. The change to specify “additional lighting power 
allowances for display; decorative, wall display, floor display, or task” is necessary to 
align with what is specified in Table 170.2 -M for the qualified lighting systems.  
 
Section: 170.2(e)4  
Specific Purpose: The specific purpose of the change is to delete Section 
170.2(e)4Ave and 170.2(e)4B – these sections are related to the Tailored method.  
Necessity:  The change was necessary as these sections are directly related to the 
Tailored method that is to be repealed and removed from the Energy Code  and the 
change is necessary for internal consistency . 
 
Section: 170.2(e)4Aii  
Specific Purpose: The specific purpose of the change to this section is to update the 
section references, changing Section 170.2(e)1Ci to Section 170.2(e)4A.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: 170.2(e)4Av  
Specific Purpose: The specific purpose of the change to this section is to update the 
section references, changing “Section 170.2(e)1Cia through f” to “Section 170.2(e)4Ai 
through iv.”  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
   
 
Section 170.2 (e)3D  
Purpose :  
The first specific purpose of the change is to delete existing language about Tailored 
method of Section 170.2(e )3D.  
The second specific purpose of the change adds “display , decorative, wall display, floor 
display, or task” to the list of lighting power allotments (allowances)  that may not be 
increased or traded off when used under the “Area Category Method”.  
Necessity : The change to add “ display , decorative, wall display, floor display, or task” is 
necessary to align with and ensure consistency with  what is specified in Table 140.6 -C 
for the qualified lighting systems. The change is also necessary to retain energy code  
 stringency for the additional lighting power allowance provided under the area category 
method  in order to reduce the unnecessary consumption of energy .      
 
Section 170.2(e)4Avg  
Specific Purpose : The specific purpose of the change  is to specify and to retain the 
requirement about floor display lighting in the new subsection that floor display lighting 
shall not qualify for wall display lighting power allowances.  
Necessity : The change to specify the requirement that floor display shall not qualify for 
wall display allowances is necessary so that wall display allowances is used only for 
wall display lighting , thereby ensuring the intended energy savings .  The change is also 
necessary to retain energy code stringency for the additional lighting power allowance 
provided under the area category method  in order to reduce the unnecessary 
consumption of energy . 
   
Section 170.2(e)4Avh  
Specific Purpose : The specific purpose is to specify the requirement in the new 
subsection about the criteria for wall lighting that can be eligible for wall display lighting 
allowance.  The criteria are the same criteria for wall lighting eligible under the Tailored 
method for wall lighting.  
Necessity : The change to specify the qualifying criteria for wall lighting that can be 
eligible for wall display lighting allowance is necessary so that wall display lighting 
allowance is used only for qualified wall lighting.  The change is also necessary to retain 
energy code stringency for wall display lighting and the additional lighting power 
allowance provided under the area category method  in order to reduce the unnecessary 
consumption of energy . 
   
Section 170.2(e)4Avi  
Specific Purpose : The specific purpose of this change  is to specify determin ation  of 
mounting height of the luminaire s based on whether the  mounting height is the same for 
all qualified luminaires  or of various  mounting height of the qualified luminaires . 
Necessity : The change to specify methods  to determine mounting height of the 
luminaire is necessary so that there is a consistent manner to determine the mounting 
height.  The change is also necessary to retain energy code stringency for floor display 
lighting, wall display lighting, and the additional lighting power allowance provided under 
the area category method  in order to reduce the unnecessary consumption of energy . 
  
Section: Table 170.2 -M 
Specific Purpose:  
The specific purpose of the change is to correct the following values of Table 170.2 -M in 
order to match the allowance values of Table 140.6 -C for similar lighting applications. 
The values included:  
- Allowed lighting power density for general lighting for “storage”, “Health Care / 
Assisted Living - Nurse’s Station", and "Health Care / Assisted Living - Physical 
Therapy Room".   
 - Additional Lighting Power Additional Allowance for “Conference, Multipurpose 
and Meeting Area”.  
 
The specific purpose of the other change is to add a note  3 to Table 140.6 -C about MH 
that it being denoted as the mounting height of the lighting systems.  
Necessity :  
The change to correct the values of Table 170.2 -M is necessary in order to ensure the 
same amount of allowance is provided to the same lighting applications for multifamily 
building spaces as for nonresidential buildings spaces that have to comply with 
applicable allowance values specified in Table 140.6 -C.   
The change is necessary to specify the information pertaining to the table in the energy 
code so that there is a consistent manner of the determination.  
 
Section  170.2(e)6  and Table 170.2 -S 
Specific Purpose : The specific purpose of the change it to clarify how the additional 
lighting power allowance of specific applications (outdoor lighting) could be applied to 
each site or to each specific lighting applications. The change is to add the following 
guidance notes to Table 170.2 -S for various lighting applications listed in Table 170.2 -S.  
- “Per application”; or  
-  “Per site: wattage allowance per AREA (W/ft²). May be used as additional 
allowance for applicable illuminated hardscape area on the site” for lighting 
applications of security cameras and special security lighting for retail parking 
and pedestrian hardsca pe.” 
Necessity: The changes are reasonably necessary to clarify how the additional lighting 
power allowance for specific applications could be properly applied to the site or to the 
specific applications. The proposed change once adopted can deliver a code language 
easier  to read and comprehend resulting in greater energy savings, consistent with 
California Public Resources Code, Sections 25213 and 25402. The proposed change is 
reasonably necessary to ensure and improve the general clarity and internal 
consisten cy of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section  170.2(e)7  
Specific Purpose: The specific purpose of the change is to remove legacy types of 
light sources for sign lighting light sources and the change is to delete the following light 
sources from subsection 170.2(e)7Bi, ii, iv, and vi:  
- high pressure sodium lamps;  
- metal halide lamps;  
- fluorescent lamps; and   
- compact fluorescent lamps.  
Necessity: The changes are reasonably necessary to update the sign lighting light 
sources requirements in order to reflect the current availability of sign lighting light 
sources that the legacy light sources are no longer manufactured or replenished once  
 the current stock runs out. The proposed change is reasonably necessary to ensure and 
improve the general clarity and internal consistency of the Energy Code, as directed by 
California Government Code, Section 11349 and 11349.1, and California Code of 
Regu lations, Title 1, Section 16.  
  
Section  170.2(e)7 – exception 3  
Specific Purpose: The specific purpose of the change is to add an exception for traffic 
signs not to be obligated to comply with  the prescriptive requirements for signs of 
Section 170.2(e)7.  
Necessity: The changes are reasonably necessary to align with the existing exception 
in the Energy Code Section 140.8 – for traffic signs that meet the requirements of the 
California Title 20 Appliance Efficiency Regulations. The proposed change is 
reasonably necessary to ensure and improve the general clarity and internal 
consistency of the Energy Code, as directed by California Government Code, Section 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section : 170.2(f)  
Specific Purpose: The purpose of this change is to clarify and reduce compliance 
ambiguity by establishing a definitive calculation that is applicable for all roofs for 
determining the PV requirement when solar access roof area (SARA) is limited. The 
calculation establishes separate requirements for buildings with steep -sloped roofs and 
for buildings with low -sloped roofs. The calculation is based on the physical dimensions 
and performance of standard PV arrays rather than on the unfettered discretion of th e 
installer. This corrects the language in the current Energy Code that does not provide  a 
definitive means to determine the PV requirement.    
Necessity: These changes are necessary to ensure reliable reductions in wasteful, 
uneconomic, inefficient, or unnecessary consumption of energy as directed by California 
Public Resources Code Sections 25213 and 25402. This change is necessary to ensure 
and improve the general clarity and internal consistency of the Energy Code, as 
direc ted by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16.  
  
 
Section : 170.2(f) , Equation 170.2 -C and Table 170.2 -T 
Specific Purpose: The purpose of th ese change s is to avoid the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy, and present in a clear and specific 
manner the PV requirement for low -rise multifamily buildings considering both 
conditioned floor area and the EER2 of cooling equipmen t. Revised climate specific 
coefficients and constants for the equation are provided in changes to Table 170.2 -T. 
The equation is designed to avoid increased energy consumption allowed by the current 
2022 En ergy Code when heat pumps replace air conditioners. When heat pumps are 
used that have lower EER2 efficiency than allowed for air conditioners, the higher 
cooling energy for the building is offset by a corresponding increase in the size of the 
PV system re quired for the building.  These changes avoid increased energy  
 consumption through cost -effective PV requirements and clarify and make specific the 
requirements.  
Necessity: These changes are necessary to reduc e wasteful, uneconomic, inefficient, 
or unnecessary consumption of energy as directed by California Public Resources Code 
Section  25402. This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 . 
  
 
Section : 170.2( f)Biii 
Specific Purpose: The purpose of this change is to clarify, make specific and reduce 
administrative burden. Section 170.2( f)Biii is clarified and made more specific by 
separately addressing compliance with other state building codes as a reason for roof 
area to not be available, in addition to compliance with local building codes if confirmed 
by the Executive Director (ED). Compliance with state building codes would not require 
ED confirmation; compliance with local building codes would continue to require ED 
confirmation. These changes are necessary to improve clarity and specificity and 
reduce administrative burden.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 . 
  
Section : Exception  2 to 170.2(f)  
Specific Purpose: The purpose of the proposed change is to increase the minimum 
size of the required PV system to 4kWdc for low -rise multi -family buildings that would 
qualify for the exception to the PV requirements that generally apply to these building 
types.  
Necessity:  The change to this exception is necessary to not require low -rise multi -
family buildings that have limited energy consumption loads on their electric utility meter 
to meet the PV requirements because those situations are unlikely to be feasible and 
cost ef fective. The limit of 4 kWdc is necessary to ensure consistency with existing and 
parallel exception for high -rise residential, nonresidential, and hotel/motel buildings. 
These changes are necessary to reduce the wasteful, uneconomic, inefficie nt, or 
unnecessary consumption of energy that the CEC determines to be cost effective 
consistent with California Public Resources Code Sections 25402 and 25402(b)3.    
  
 
Section : Exception 5  to Section 170.2(f)  
Specific Purpose: The purpose of this proposed change is to align throughout the 
Energy Code to use the term “battery energy storage system ” instead of “ battery 
storage ” that was  used in the 2022 Energy Code. That term was changed to clarify that 
an operative system has multiple components not just batteries and to match up with 
use of the BESS term within the industry.    
 Necessity:  This new term ensures and improves the general clarity and internal 
consistency of the Energy Code as directed by California Government Code Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : 170.2(g)  
Specific Purpose:  
The purpose of the proposed changes to this section is to clarify and reduce compliance 
ambiguity by establishing a specific calculation for determining the Photovoltaic System 
(PV) requirement when solar access roof area (SARA) is limited. The calculation  
provides separate requirements for buildings with steep -sloped roofs and for buildings 
with low -sloped roofs. Additionally, other modifications to the section language were 
made to provide further compliance clarity and/or correct grammatical errors. Thes e 
additions correct the language in the current Energy Code that does not provide a 
definitive means to determine the PV requirement.    
Necessity:  These changes are necessary to ensure reliable reductions in wasteful, 
uneconomic, inefficient, or unnecessary consumption of energy as directed by California 
Public Resources Code Sections 25213 and 25402. This change is necessary to ensure 
and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16  
 
Section : 170.2(g)1C  
Specific Purpose: The purpose of this change is to clarify, make specific and reduce 
administrative burden. Section 170.2(g) 1C is clarified and made more specific by 
separately addressing compliance with other state building codes as a reason for roof 
area to not be available, in addition to compliance with local building codes if confirmed 
by the Executive Director (ED). Compliance with state building codes would not require 
ED confirmation; compliance with local building codes would continue to require ED  
confirmation. These changes are necessary to improve clarity and specificity and 
reduce administrative burden.  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16 . 
 
 
Section : Equation 170.2 -D and Table 170.2 -U 
Specific Purpose: The purpose of the proposed changes to the equation and the table 
is to revise the PV Capacity Factors used in Equation 170.2 -U is to establish the size of 
the PV systems required for the 2025 Energy Code. The PV system size requirements 
are increased or clarified for building categories for which there are PV requirements in 
the 2022 Energy Code or are established for the first time for additional building 
categories.   
 Necessity:  These changes are necessary to reduce the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy as directed by California Public 
Resources Code Section 25402.  
 
Section : Exception 5 to 170.2(g)   
Specific Purpose: The purpose of this change is to clarify the exception without using 
the name “Virtual Net Metering (VNEM),” as that name has been changed by the CPUC 
to “Virtual Net Billing Tariff (VNBT).” Instead of using a specific name, the change 
describes the progra m that provides compensation through virtual energy bill credits. 
This change also clarifies that the exception does not apply where the Commission has 
approved a community solar program. The change also clarifies that the exception 
appli es to high -rise multi -family buildings.  
Necessity:  These changes are necessary to ensure that the exception applies  to a 
particular compensation approach , rather than to a name d program . These changes 
also ensure and improve the general clarity and internal consistency of the Energy 
Code, as directed by California Government Code, Section 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
Section : 170.2(h) Equations 170.2 -E, 170.2 -F and 170.2 -G and Table 170.2 -V  
Specific Purpose:  The energy storage system kWh sizing equation s 170.2-E and 
170.2-F have  been updated to be a function of conditioned floor area, the capacity 
factor B, which has been updated as required for cost -effectiveness , in addition to 
roundtrip efficiency. Equation 170.2-F has been introduced to calculate the energy 
storage sizing when SARA restricts the PV sizing  with which the energy storage system 
will be matched . For Equation 1 70.2-G, a factor C was included in the equation for the 
2022 Energy Code; that factor was merely the capacity factor, factor B, divided by 4 to 
capture the expected time (4 hours) for the battery to discharge. The revised equation 
eliminates factor C and instead is  based on factor B expressly divided by 4. That 
clarifies and eliminates unnecessary complexity in the equation. The nu mber of building 
categories in table 170.2 -V have increased consistent with revised cost-effectiveness 
analysis . The changes to these equations and tables contribute directly to reducing 
building energy consumption, as well as improving the clarity of the Energy Code.  
Necessity: These changes are necessary to reduce the wasteful, uneconomic, 
inefficient, or unnecessary consumption of energy as directed by California Public 
Resources Code Section 25402. Additionally, these changes ensure and improve the 
general clarity and internal  consistency of the Energy Code as directed by California 
Government Code Sections 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section : Exception to 180.1(a) 1 
Specific Purpose:  The specific purpose of this change is to amended  the language for 
clarity without changing the intent.  
Necessity : The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California  
 Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section : Exception to 180.1(a)2  
Specific Purpose:  The specific purpose of this change is to add an exception in the 
mechanical ventilation for indoor air quality section to specify dwelling unit air leakage 
test is not required for additions.  
Necessity: These changes are necessary as the language update does not make any 
changes to Section 180. 1(a)2. Adding this exception would help clarify that 
compartmentalization is not required for additions to ensure and improve the general 
clarity and internal consistency of the Energy code.  
  
Section:  Exception to 180.1(a)2Aii  
Specific Purpose:  The specific purpose of this change is to add an exception to 
Section 180.1(a)2Aii that specifies new, or replacement ventilation type shall be supply, 
balanced, or the existing ventilation type when additions are incorporated to an existing 
dwelling unit of which conditioned floor area is 1,000 square feet.  
Necessity: These changes are necessary as the language update does not make any 
changes to additions and specifying in an exception that mechanical ventilation systems 
shall be supply, balanced or the existing ventilation type being use would improve 
general clarity and maintain internal consistency o f the Energy Code, as directed by 
California Government Code Sections 11349 and 11349.1, and California Code of 
regulations, Title 1, Section 16.  
  
Section : 180.1(b) 1 and 180.1(b)2  
Specific Purpose : The specific purpose of this change is to add language to more 
accurately and directly describe the energy budget for additions to multifamily buildings, 
clearly identifying that the energy budget is expressed in terms of Long-term System 
Cost, rather than direct readers to another section.  
Necessity : This change is needed to improve overall clarity and readability of the 
Energy Code.  
  
 
Section: 180.2(b)1A  
Specific Purpose:  The specific purpose of this change is to correct a typo in the 2022 
Energy Code. Where the prescriptive standard currently states “the requirements of i 
and iii below apply” it should have said “the requirements of i through  iii below apply.”  
Necessity:  This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code.  
  
Section: Table 180.2 -B 
Specific Purpose: The specific purpose of this change is to remove the RSHGC 
requirement for Curtainwall/Storefront/Window Wall fenestration in climate zones 1, 3,  
 5, and 16 where modeling has shown that it is actually advantageous to have a higher 
RSHGC due to the larger heating loads in those climate zones.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402. As well as improve the general clarity and internal 
consistency of the Energ y Code.  
  
Section: Table 180.2 -B 
Specific Purpose:  The specific purpose of this change is to remove the RSHGC 
requirement for NAFS 2017 Performance Class AW – Fixed fenestration in climate 
zones 1, 3, 5, and 16 where modeling has shown that it is actually advantageous to 
have a higher RSHGC due to the lar ger heating loads in those climate zones.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402. As well as improve the general clarity and internal 
consistency of the Energ y Code.  
  
Section: Table 180.2 -B 
Specific Purpose:  The specific purpose of this change is to remove the RSHGC 
requirement for NAFS 2017 Performance Class AW – Operable fenestration in climate 
zones 1, 3, 5, and 16 where modeling has shown that it is actually advantageous to 
have a higher RSHGC due to the larger heating loads in those climate zones.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402. As well as improve the general clarity and internal 
consistency of the Energ y Code.  
  
Section: Table 180.2 -B 
Specific Purpose:  The specific purpose of this change is to reduce the prescriptive 
standard maximum U -factor for All Other Windows and Glazed Doors to U -0.28 in 
climate zones 1, 3 -5, 11, and 13 -16, and thus decrease building energy consumption.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402.  
  
Section: Table 180.2 -B 
Specific Purpose:  The specific purpose of this change is to remove the RSHGC 
requirement for All Other Windows and Glazed Doors in climate zones 1, 3, 5, and 16 
where modeling has shown that it is actually advantageous to have a higher RSHGC 
due to the larger heating loads  in those climate zones.  
Necessity:  These changes are necessary to increase energy efficiency via cost -
effective building design standards, as directed by California Public Resources Code, 
Sections 25213 and 25402. As well as improve the general clarity and internal 
consistency of the Energ y Code.   
   
Section :180.2(b)2AivbIIB  
Specific Purpose : The purpose of this change is to remove the option that allowed for 
refrigerant charge verification through the installation of equipment that utilizes a fault 
indicator display (FID).  
Necessity: These changes are necessary to clean up the energy code by removing a 
section that is no longer needed . Various issues associated with FIDs that may impact 
their effectiveness or reliability  are that industry codes are frequently misinterpreted , 
have limited diagnostic capabilities , senor accuracy has been poor, are not sensitive 
enough to detect small leaks or provide timely alerts and suffer from lack of 
standardization. Removal of the inclusion of the option for refrigerant charge verification 
through FIDs in the energy code can help improve overall system reliability  and safety . 
 
Section : Exception 2 to Section 180.2(b)2Bi  
Specific Purpose : The specific purpose of this change is rewriting  this language to be 
clearer  that interlocks are not required on existing windows that did not previously have 
interlocks when replacing the space conditioning system. As previously written, it did not 
explicitly address the applicability of these requirements to existing buildings. This 
change is not substantive.  
Necessity: These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  Additionally, this new 
term ensure s and improves the general clarity and internal consistency of the Energy 
Code.  
  
Section : Exception 3 to 180.2(b)2Bi  
Specific Purpose : The specific purpose of this change is to make a correction and 
clarification to the 2022 Energy Code language. This change seeks to clarify  that the 
exception to the economizer requirement is triggered only when  applicable to systems 
that are a split packaged AC and with a cooling capacity lower than 54,000 Btu/h.     
Necessity:  These changes are reasonably necessary to ensure that regulations will 
have clear and unambiguous meaning to readers, including the public, and particularly 
to the persons and organizations affected by these regulations.  Additionally, this new 
term ensur es and improves the general clarity and internal consistency of the Energy 
Code as directed by California Government Code Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
 
Section : Exception 1 to 180.2(b)2Biib  
Specific Purpose : The purpose of this change is to delete HERS field verification and 
diagnostic testing and replace it with acceptance testing.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires multifamily common area duct leakage test to first 
be performed by a certified mechanical ATT and then field verified by a HERS rater. 
The change is necessary because this is duplicative and redundant as written in the  
 2022 Energy Code where the duct leakage test procedure is the same for both tests. 
The ATTCP program and the HERS program are both intended to ensure equipment 
are installed in compliance with the Energy Code. Functional testing in multifamily 
common areas  is under the scope of the ATTCP program. Removing the HERS field 
verification and diagnostic requirement will also reduce confusion moving forward on 
who needs to perform the duct leakage test.  
 
Section : Exception 2 to 180.2(b)2Biib  
Specific Purpose : The specific purpose of this change is to modify the language for 
clarity without changing the intent.  
Necessity : The proposed change is reasonably necessary to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
 
Section : 180.2(b)2Biic  and 180.2(b)2Biiib  
Specific Purpose : The purpose of this change is to delete HERS field verification and 
diagnostic testing and replace it with acceptance testing.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires multifamily common area duct leakage test to first 
be performed by a certified mechanical ATT and then field verified by a HERS rater. 
The change is necessary because this is duplicative and redundant as written in the 
2022 Energy Code where the duct leakage test procedure is the same for both tests. 
The ATTCP program and the HERS program are both intended to ensure equipment 
are installed in compliance with the Energy Code. Functional testing in multifamily 
common areas is under the scope of the ATTCP program. Removing the HERS field 
verification and diagnostic requirement will also reduce confusion moving forward on 
who needs to perform the d uct leakage test.  
 
  
Section:  180.2(b)2Biiib  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to better clarify or correct minor issues with the 
Energy Code. This benefits the CEC  by complying with California Government Code 
11349 and 11349.1 and California Code of Regulations title 1, Section 16.  
  
Section: 180.2(b)4A  
Specific Purpose : The specific purpose of this change is to remove an unnecessary 
reference to Table 160.5 -A, as it is duplicative. The language in this section already 
directs the reader to section 160.5(a), where Table 160.5 -A resides.  
Necessity : This change is necessary to increase clarity and overall readability of the 
Energy Code.  
   
 Section: Exception to 180.2(b)5  
Specific Purpose:  The specific purpose of this change is to add an exception in the 
mechanical ventilation for indoor air quality section to specify dwelling unit air leakage 
test is not required for alterations.  
Necessity: These changes are necessary as the language update does not make any 
changes to Section  180.2(b)5 . Adding this exception would help clarify that 
compartmentalization is not required for alterations to  ensure and improve the general 
clarity and internal consistency of the Energy code.  
 
Section: Exception to  180.2(b)5A  
Specific Purpose:  The specific purpose of this change is to add an exception to 
Section 180.2(b)5A that specifies new, or replacement ventilation type shall be supply, 
balanced, or the existing ventilation type being replaced.  
Necessity: These changes are necessary as the language update does not make any 
changes to alterations and specifying in an exception that new, or replacement 
ventilation type shall be supply, balanced or the existing ventilation type being use 
would  improve general  clarity and maintain internal consistency of the Energy Code, as 
directed by California Government Code Sections 11349 and 11349.1, and California 
Code of regulations, Title 1, Section 16.  
  
Section: 180.2(b)5Bia  
Specific Purpose:  The specific purpose of this change is to add a requirement for 
whole -dwelling unit ventilation strategy that specifies the altered ventilation system shall 
be supply, balanced, or the existing ventilation type being altered.  
Necessity: These changes are necessary to align with the updated language in Section 
160.2 (b)2Aivb that specifies all new construction multifamily dwelling units shall use the 
same whole -dwelling unit ventilation system type that must be balanced or supply  
ventilation and pass compartmentalization testing  while exempting existing ventilation 
type that is being al tered because the language update does not make changes to 
additions and alterations.  This requirement ensure s and improve s general clarity and 
maintain s the  internal consistency of the Energy Code . These changes are consistent 
with Public Resources Codes §25402 and §25402.8 on assessment of indoor air 
pollution in new buildings.   
  
Section 180.2(c)  
Specific Purpose: The purposed added language to this section is to make it accurate 
and clear that the energy budget is expressed using the term Long -term System Cost.  
Necessity: This clarification  is necessary to specif y how the energy budget is 
calculated and the use of the terms to be used for establishing energy budgets. These 
changes align language that is used other sections of the Energy Code.  
 
Section: Table 180.2 -A  
 Specific Purpose : The goal is to eliminate the distinction between three -story and less 
vs. four -story or greater in a multifamily building. Also, skylight with a U -factor of 0.3 is 
not easily accessible.  
Necessity: To reduce the confusion for builders and designers and to reduce the 
ambiguity of installing a skylight in the multifamily building.  
  
Section: Table 180.2 -E 
Specific Purpose : The specific purpose of the change is to clarify the reference code 
sections in Table 180.2 -E for indoor lighting system alterations for common use areas of 
multifamily buildings. The change is to revise the reference code sections for demand 
responsive controls, and to add “110.12(a) and 110.12(b)”, and to delete “160.5(b)4E”.  
The other specific purpose of the change is to clarify the automatic shutoff controls 
requirements specified in Table 180.2 -E. The change is to add “except for 
160.5(b)4Cvi.b” to the row of “Automatic Shut Off Controls 160.5(b)4Cvi” and on the 
rightmost ce ll of Table 180.2 -E. 
Necessity : The change to revise the reference code sections for demand responsive 
controls is to provide more accurate information so that the code is easier to navigate 
and comprehend.   
The change to add the information about the automatic shutoff controls requirements for 
the alterations is to ensure the automatic shutoff control requirements specified in Table 
180.2 -E align with the requirements specified in Table 141.0 -F (Control Requi rements 
for Indoor Lighting System Alterations).  
  
Section: Appendix 1 -A General comment  
Purpose:  The purpose of this change is to accurately identify all of the documents 
incorporated by reference in Part 6 and update  to the most current version.  
Necessity:  These changes are necessary to ensure that all documents intended to be 
incorporated by reference into the Standards and Reference Appendices are 
adequately incorporated by reference and to provide clarity to the public about the full 
title, date, version, and location of the documents incorporated by reference into the 
Standards or Reference Appendices.  
 
Section : Appendix 1 -A 
Specific Purpose: The specific purpose of this addition is to provide a complete 
reference to ASHRAE Guideline 36 High -Performance Sequences of Operation for 
HVAC Systems (2021).  
Necessity: The addition is necessary to ensure that the users can reference the most 
current Guideline 36 publication from ASHRAE.  
 
Section: Appendix 1 -A 
Purpose:  The purpose of this change is to accurately identify all of the documents 
incorporated by reference in Part 6, including ANSI/AMCA 220  Laboratory Methods of 
Testing Air Curtain Units for Aerodynamic Performance Rating (2021).   
 Necessity:  These changes are necessary to ensure that all documents intended to be 
incorporated by reference into the Standards and Reference Appendices are 
adequately incorporated by reference and to provide clarity to the public about the full 
title, date, and loc ation of the documents incorporated by reference into the Standards 
or Reference Appendices.  
 
Section: Appendix 1 -A 
Specific Purpose : The specific purpose of the change is to add the following 
documents of the Illuminating Engineering Society.  
- ANSI/IES LM -51-20 Approved Method: Electrical and Photometric Measurement 
of High Intensity Discharge Lamps (2020)  
- ANSI/IES LM -66-20 Approved Method: Photometry of induction lamps (2020)   
The specific purpose of the change is to delete the following documents of the 
Illuminating Engineering Society: IES LM -9, IES LM -20, IES LM -45, IES LM -46, IES LM -
80, and IES TM -21. 
Necessity : The change to add the IES documents, including ANSI/IES LM -51-20 and 
LM-66-20, is reasonably necessary as they are the references for the testing 
procedures of Joint Appendix JA8 of the Energy Code.  
The change to delete the IES documents is reasonably necessary as the documents 
are related to legacy light sources or test methods that are no longer required in the 
Energy Code.  
 
 
 
REFERENCE APPENDICES  
 
Section:  JA1 AMCA  definition  
Specific Purpose:  The specific purpose of this change is to add a definition for the Air 
Movement and Control Association (AMCA) document 220, titled “Laboratory Methods 
of Testing Air Curtain Units for Aerodynamic Performance Rating”.  
Necessity:  This change is reasonably necessary to ensure that projects using the 
exception for air curtains are tested in accordance with a specific  and consistent  test 
method ology  – AMCA 220.  
 
Section: JA1 ANSI/AMCA 220 definition  
Purpose:  The specific purpose of adding a definition for ANSI/AMCA 220 220  
Laboratory Methods of Testing Air Curtain Units for Aerodynamic Performance Rating 
(2021)  to the Definitions section is to provide a clean and specific definition for this 
technical term, which is used within other updates to Part 6, aligned with the use of the 
term where it is proposed to occur within the Energy Code. This includes the added 
definition for new industry standards documents that are incorporated by reference into 
the Energy C ode.  
 Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section: ANSI/ASA S12.55 -2012  
Specific Purpose:  The specific purpose of the change is to add the following 
documents of the American National Standards Institute (ANSI).  
- ANSI/ASA S12.55 -2012 Acoustics - determination of sound power levels and 
sound energy levels of noise sources using sound pressure - precision methods 
for anechoic rooms and hemi -anechoic rooms . 
Necessity: The change to add the ANSI documents, ANSI/ASA S12.55 -20212, is 
reasonably necessary as they are the references for the testing procedures of Joint 
Appendix JA8 of the Energy Code.  The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16 . 
 
 
Section:  JA1 Approved  definition  
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by updating several definitions.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The updated  definition “Approved ,” grants  responsibilities and 
requirements to each ECC participant, increasing the robustness of the overall program 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
 
Section:  JA1 Battery System, Stationary Storage and Battery Energy  Storage System  
definition  
Specific Purpose:  This definition  is being merged with the Energy Storage System 
(ESS) and renamed to Battery Energy Storage System (BESS). All Standards 
references to battery storage system and energy storage system are also being 
updated to BESS to reflect this change.  This definition  is added to align with changes 
with the same definition in Part 6.  
Necessity : This change is necessary to align with the more up -to-date industry 
terminology for electro -chemical battery storage systems. Currently the only type of 
ESS recognized by the Standard is BESS, this change clarifies the intent of the 
Standard and ensure that the terms used within the regulations will have clear and  
unambiguous meaning to readers, including the public, and particularly to the persons 
and organizations affected by these regulations.  
 
  
 Section:  JA1 Compliance Cycling Capacity  definition  
Specific Purpose:  The specific purpose of t his change is to add a definition for 
compliance cycling capacity for BESS.   
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building desi gn and construction.  
 
Section:  JA1 Cycling Capacity definition  
Specific Purpose:  The specific purpose of this change is to add a definition for cycling 
capacity for BESS.   
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section:  JA1 EER and HSPF definitions  
Specific Purpose: Add EER2 and HSPF2 to definitions referenced in the Energy Code. 
Necessity: In residential buildings, space conditioning efficiency metrics were updated 
to EER2/SEER2/HSPF2. EER and HSPF definitions were included in JA1 and 
referenced the Energy Code. EER2 and HSPF2 were also added and reference back to 
the Energy Code for consist ency  and clarity . 
 
Section:  JA1 Energy Code Compliance Program definition  
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by adding several new definitions.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The new definitions (ECC -Provider, ECC -Rater, and ECC -Rater 
Company) assign separate responsibilities and requirements to each ECC participant, 
increasing the robustne ss of the overall program so that wasteful energy consumption is 
reduced, as directed by PRC 25402.  
 
Section:  JA1 Field -Assembled BESS  definition  
Specific Purpose:  The specific purpose of this change is to add a definition for 
compliance cycling capacity for BESS.    
Necessity :  This new definition is necessary to distinguish  BESS that are field 
assembled, with combination of components installed to operate as a system , from 
integrated BESS.  These changes are necessary to ensure that provisions in 
subsequent sections are clear and unambiguous, and that non -technical readers are 
able to find and understand the technical meaning of specific terms and technical 
standards relating to building design and construction.  
 
Section:  JA1 Ground Source Heat Pump  definition   
 Specific Purpose: Add EER2 and HSPF2 to definitions referenced in the Energy Code. 
Necessity: In residential buildings, space conditioning efficiency metrics were updated 
to EER2/SEER2/HSPF2. EER and HSPF definitions were included in JA1 and 
referenced the Energy Code. EER2 and HSPF2 were also added and reference back to 
the Energy Code for consistency.  
Section:  JA1 HERS /HERS -Provider /HERS -Provider Data Registry /HERS -Rater 
definition  
Specific Purpose : The purpose of this change is to remove definitions associated with 
the Home Energy Rating System (HERS) program from within the Energy Code.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. This benefits the CEC  in accomplishing its responsibility under 
Statute 25402.  
Section:  JA1 IES-LM-9 definition  
Specific Purpose:  The purpose of this change is to remove  the IES-LM-9 definition . 
Necessity:  This change is necessary as the IES publication no longer being referenced 
in Joint Appendix.  
 
Section:  JA1 IES -LM-20 definition  
Specific Purpose:  The purpose of this change is to remove the IES -LM-20 definition.  
Necessity:  This change is necessary as the IES publication no longer being re ferenced 
in Joint Appendix.  
 
Section:  JA1 IES -LM-45 definition  
Specific Purpose:  The purpose of this change is to remove the IES -LM-45 definition.  
Necessity:  This change is necessary as the IES publication no longer being referenced 
in Joint Appendix.  
 
Section:  JA1 IES -LM-46 definition  
Specific Purpose:  The purpose of this change is to remove the IES -LM-46 definition.  
Necessity:  This change is necessary as the IES publication no longer being referenced 
in Joint Appendix.  
 
Section:  JA1 IES -LM-80 definition  
Specific Purpose:  The purpose of this change is to remove the IES -LM-80 definition.  
Necessity:  This change is necessary as the IES publication no longer being referenced 
in Joint Appendix.  
 
Section:  JA1 IES -TM-21 definition  
Specific Purpose:  The purpose of this change is to remove the IES -TM-21 definition.  
Necessity:  This change is necessary as the IES publication no longer being referenced 
in Joint Appendix.  
 
Sections:  JA1 Inde pendent Identity definition    
 Specific Purpose: The purpose of this change is to help clarify the implementation of the 
new section in the Energy Code, Title 24, Part 1, Section 10 -103.3. This is accomplished 
by replacing "HERS" with "ECC -" or "field verification and diagnostic testing" where 
appropriat e and replacing the reference to the HERS regulations (Title 20) with a 
reference to Title 24, Part 1, Section 10 -103.3. These changes appear throughout the 
Parts 1 and 6 (including the Reference Appendices: Joint Reference Appendix, 
Residential Reference Appendix, and Nonresidential Reference Appendix) of the Energy 
Code and this is intended to identify the purpose and necessity as a consolidated 
grouping.  
Necessity: This change is necessary to maintain a clear intention and implementation 
of the Energy Code with the new section, Title 24, Part 1, Section 10 -103.3. This 
change is consistent with the requirements of California Government Code 11349 and 
11349.1 and Calif ornia Code of Regulations title 1, Section 16.  
 
Section:  JA1 Integrated BESS definition  
Specific Purpose:  The specific purpose of this change is to add a definition for 
Integrated BESS.    
Necessity :  This new definition is necessary to distinguish integrated BESS, that 
contains battery energy storage and inverter into a single model, from field -assembled 
BESS, these  changes are necessary to ensure that provisions in subsequent sections 
are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building design an d construction.  
 
Section: ISO 3745:2012  
Specific Purpose: The specific purpose of the change is to add the following document 
from the International Organization for Standardization (ISO) . 
- ISO 3745:2012 Acoustics - determination of sound power levels and sound 
energy levels of noise sources using sound pressure - precision methods for 
anechoic rooms and hemi -anechoic rooms  
Necessity: The change to add the ISO document, ISO 7574 -4 B.2.1: 1985 is 
reasonably necessary as it is the references for the testing procedures of Joint 
Appendix JA8 of the Energy Code.  The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16 . 
 
Section: ISO 7574 -4:1985  
Specific Purpose: The specific purpose of the change is to add the following document 
from the International Organization for Standardization (ISO).  
- ISO 7574 -4:1985. Acoustics - statistical methods for determining and verifying 
stated noise emission values of machinery and equipment, International 
Organization for Standardization, Geneva, Switzerland.   
 Necessity: The change to add the ISO document , ISO 7574 -4 B.2.1: 1985, is 
reasonably necessary as it is the references for the testing procedures of Joint 
Appendix JA8 of the Energy Code.  The proposed change is reasonably necessary to 
ensure and improve the general clarity and internal consistency of the Energy Code, as 
directed by California Government Code, Section 11349 and 11349.1, and California 
Code of Regulations, Title 1, Section 16 . 
 
Section: JA1 - Long Term System Cost definition  
Purpose:  The specific purpose of adding a definition for the term Long -term System 
Cost to the Definitions section is to provide clean and specific definition for this technical 
term, which is used within other updates to Part 6, aligned with the use of the term 
where it is proposed to occur later in the Energy Code. This includes the added 
definition for new industry standards documents that are incorporated by reference into 
later portions of the Energy Code.  
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction.  
 
Section:  JA1 Low -Sloped Roof definition  
Specific Purpose:  Fixing the inconsistency in the definitions between what it is in the 
Refence Appendices and the Energy Code.   
Necessity: These changes are necessary to ensure that the terms used within the 
regulations will have clear and unambiguous meaning to readers, including the public, 
and particularly to the persons and organizations affected by these regulations  
 
Section:  JA1 Reserve Level  definition  
Specific Purpose:  The specific purpose of this change is to add a definition for 
Reserve Level for BESS.    
Necessity :  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building d esign and construction.  
 
Section:  JA1 Usable Capacity definition  
Specific Purpose:  The specific purpose of this change is to add a definition for Usable 
Capacity  for BESS.    
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building design and construction.  
  
Section:  JA3.1   
 Specific Purpose:  The purpose of this change is to update the scope and purpose of 
JA3 to reflect the terminology changes in energy budget from Time Dependent 
Valuation  to Long-term System Cost .  
Necessity:  This change  is necessary to reflect  the terminology update in energy budget  
from T ime Dependent Valuation to Long-term System Cost and ensure that provisions 
in subsequent sections are clear and unambiguous . 
 
Section:  JA3.1.1 
Specific Purpose:  The specific purpose of this change is to update terminology 
references from T ime Dependent Valuation  to Long-term System Cost . Reference to a 
15-year nonresidential dataset is removed. Additional minor edits for clarity.  
Necessity:  This change  is necessary to reflect  the terminology update in energy budget  
from T ime Dependent Valuation to Long-term System Cost and ensure that provisions 
in subsequent sections are clear and unambiguous. Long-term System Cost is similar to 
Time Depend ent Valuation in that it varies for every hour of the year to capture the 
value of energy and emissions at different times of the day and at different times of the 
year. L ong-term System Cost is a cost metric that represents long -term marginal costs 
to the energy syst em over 30 -years through which we hope to better account for, and 
relay to the public, the long -term dollar cost impact to California’s energy system.  A 15-
year nonresidential dataset is no longer used, and instead will use 30 -year dataset 
similar to single -family and multi -family.  
 
 
Section:  JA3.1.2  
Specific Purpose:  The specific purpose of this change is to add description of the 
Source Energy metric.   
Necessity:  This change  is necessary to reflect  an update in terminology related to 
energy budget  from T ime Dependent Valuation  to Long-term System Cost and ensure 
that provisions in subsequent sections are clear and unambiguous.  
 
Section:  JA3.2 
Specific Purpose:  The specific purpose of this change is to reflect the changes of 
Tables 3 -1 to 3 -6. 
Necessity:  This change  is necessary to reflect  an update in terminology related to 
energy budgets from T ime Dependent Valuation to Long-term System Cost , and ensure 
that provisions in subsequent sections are clear and unambiguous  
 
 
Section:  JA3 Table 3 -1, Table 3-2, Table 3-3, Table 3 -4, Table 3 -5, Table 3 -6 
Specific Purpose:  Tables 3 -1 to 3 -6 were repealed and replaced. The statistical data 
for Time Depend ent Valuation  has been removed and replaced with statistical data for 
Long-term System Cost  and Source Energy. The data includes the statistical summary 
of Long-term System Cost  and Source Energy factors for electricity, natural gas, and  
 propane. Each table has the annual minimum, maximum, and average for each climate 
zone and building type.  
Necessity:  This change is necessary to reflect the update in terminology related to 
energy budgets from T ime Dependent Valuation to Long-term System Cost and Source 
Energy , and ensure that provisions in subsequent sections are clear and unambiguous  
 
Section:  JA6.3 
Specific Purpose:  Language was cleaned up to make it clearer  that certification must 
be done by providing a certification letter to the CEC . 
Necessity:  The certification letter identified in JA6.3 was originally written as an option. 
However, since the CEC  only allows for certification through this letter process and 
certification is a requirement, the language for the identified certification letter was 
revised to be a requirement and not an option. There was also slight cleanup to identify 
that the requir ements in Section 120.2(i)1 -120.2(i)7 must be certified. Section 120.2(i)8 
is the requirement for certification so is not actually certified in the letter.  
 
Section:   JA7.2 Definitions: ENERGY CODE COMPLIANCE  (ECC), ECC -PROVIDER , 
ECC -RATER, AND  ECC -RATER  COMPANY  
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by adding several new definitions.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The new definitions ( Energy Code Compliance (ECC), ECC -
Provider, ECC -Rater, and  ECC -Rater  Company ) assign separate responsibilities and 
requirements to each ECC participant, increasing the robustness of the overall program 
so that wasteful energy consumption is reduced, as directed by PRC 25402.  
Section:  JA7.2 Definitions .  
Specific Purpose : The purpose of this change is to remove definitions associated with 
the Home Energy Rating System (HERS) program from within the Energy Code.  
Necessity : This change is necessary to help implement an improved Energy Code 
Compliance program. The change clarifies the ECC Program is separate from the 
previous program. The name clarification may improve the reputation of the program 
and encourage widespread program adoption. Widespread adoption and broad use of 
the program would help to accurately determine  building energy efficiency standard 
compliance so that wasteful energy consumption is reduced, as directed by PRC 25402.  
Section:  JA7.2 Definitions:  TRIENNIAL CODE CYCLE  
Specific Purpose : The purpose of this change is to aid in the implementation of new 
regulations in Title 24, Part 1, Section 10 -103.3 by adding a new definition.  
Necessity : This change (adding a definition of the Triennial Code Cycle) is necessary 
to help implement an improved Energy Code Compliance program. The ECC -Provider 
may submit an updated application that responds to a newly adopted Energy Code  
 during the triennial code cycle. This definition helps to allow a more streamline 
application process for existing ECC -Providers. This benefits the  CEC  in accomplishing 
its responsibility under Statute 25402.  
 
 
Section:  JA7.2 Definitions: REGISTRATION  
Specific Purpose: Revised definition to reflect repealed regulation. The definition is no 
longer accurate and must be revised to reflect the current regulations.  
Necessity: This revision is necessary because the Energy Code relies on language 
given in California Code of Regulations Sections 22000 through 22005. The California 
Secretary of State adopts definitions and standards for digital signatures that are 
applied to electronic documents used for administering State programs. Document 
registration is such an application. Until 2020, the Secretary of State approved and 
publicly listed certificate authorities that were capable of issuing certificates that met 
digital signature requ irements. In late 2020, California Code of Regulations section 
22004 "Provisions for Adding New Technologies to the List of Acceptable Technologies" 
was repealed. The remaining sections still apply, so the definition for "Registration" 
must omit the list o f approved certificated authorities and acknowledge the remaining 
requirements.  
  
Section:  JA7.3  
Specific Purpose : The specific purpose of this change is to clarify what is required with 
electronic signatures and dates.  
Necessity : This change is necessary to increase clarity and understanding of the intent 
of these requirements.  
  
Section:  JA7.5.6.3  
Specific Purpose : The purpose of this addition is to establish the basic requirements 
for recording photographic evidence that is associated with a registered compliance 
document.  
Necessity : This addition is necessary to ensure that there are minimum required 
elements present in photographs that are used as evidence of field verifications or 
diagnostic testing services performed by ECC -Raters or by ECC -Providers when 
performing a quality ass urance audit. Photographic evidence has been a common 
(voluntary) addition to the ECC Program for several years,  but the photographs used 
often show only generic elements that can be easily modified through existing software. 
There have been sever al cases  investigated by CEC  staff where photographs were 
offered as evidence only to discover that these were taken elsewhere and doctored to 
appear to show compliance. These minimal requirements will help prevent such  
doctoring from successfully evading Energy Code compliance. This benefits the CEC  in 
accomplishing its responsibility under Statute 25402.  
  
Section: JA7.6.2.2.4 Digital Signatures   
 Specific Purpose: Revise description of requirements for the registration provider's 
digital signature. Instead of requiring the services of a Secretary of State -approved 
certificate authority, the provider must comply with Section 22001 " Digital Signatures 
Must Be Created  by an Acceptable Technology." Full requirements are given in 
California Code of Regulations Sections 22000 through 22005.  
Necessity: Correcting this language maintains the intended requirements for digital 
signatures applied to document registration and removes the outdated requirement.  
  
Section:  JA8.3.1  
Specific Purpose : The specific purpose is to update the light source types listed in the 
luminous efficacy test in JA8 and the change is to remove the incandescent lamp types 
(including incandescent and incandescent reflector lamps) and the fluorescent lamp 
types (general  service fluorescent lamps; fluorescent lamps that are not medium base 
compact fluorescent lamps and general service fluorescent lamps) listed as item a, b, c 
and d in Section JA8.3.1. These general service lamp types are banned for the sal es in 
California. The other change is to renumber the remaining light sources typed.  
Necessity: The change to remove the incandescent light sources and the fluorescent 
light sources is to reflect the federal law (DOE new final rules related to general service 
lamps as published in the Federal Register, 10 CFR Parts 429 and 430, and Federal 
Register v olume number 87FR53618) that bans the manufacturing and sale of general 
service incandescent lamps after July 2023 and the California law (AB -2208) that bans 
the sales and distribution of fluorescent lamps as a new manufactured product after 
2024 and 2025 - banning screw and bayonet base type compact fluorescent (CFL) 
lamps after January of 2024 and banning pin -base type CFL) and linear fluorescent 
lamps after January of 2025.  
  
Section:  JA8.3.3  
Specific Purpose : The specific purpose is to delete reference to the ENERGY STAR 
Program Requirements for Lamps 2.1 and to add the reference to Section JA8.7 for 
start time test method.  
Necessity: The change to delete reference to the ENERGY STAR program and to add 
reference to JA8.7 is reasonably necessary to reflect the sunset of the ENERGY STAR 
Program for lamps and luminaires effective December 31, 2024. The change is 
necessary to ensure details  of the start time test method can instead be found in 
Section JA8.7.  
  
Section:  JA8.3.4  
Specific Purpose : The specific purpose is to update the type of light sources listed in 
the color characteristics test of Joint Appendix JA8 and the change is to remove 
“incandescent and halogen reflector lamps”, “incandescent non -reflector lamps”, “single -
ended compact f luorescent lamps” and “fluorescent lamps that are not single -ended 
compact fluorescent lamps” from Section JA8.3.4. These general service lamp types 
are banned for the sales in California. The other change is to renumber the remaining 
light sources typed.   
 Necessity: The change to remove the incandescent light sources and the fluorescent 
light sources is to reflect the federal law (DOE new final rules related to general service 
lamps as published in the Federal Register, 10 CFR Parts 429 and 430, and Federal 
Register v olume number 87FR53618) that bans the manufacturing and sale of general 
service incandescent lamps after July 2023 and the California law (AB -2208) that bans 
the sales and distribution of fluorescent lamps as a new manufactured product after 
2024 and 2025 - banning screw and bayonet base type compact fluorescent (CFL) 
lamps after January of 2024 and banning pin -base type CFL) and linear fluorescent 
lamps after January of 2025.  
  
Section:  JA8.3.7  
Specific Purpose : The specific purpose is to delete reference to the ENERGY STAR 
Program Requirements for Lamps Version 2.1 and to add the reference to Section 
JA8.8 for (audible) noise test method.  
Necessity: The change to delete reference to the ENERGY STAR program and to add 
reference to JA8.8 is reasonably necessary to reflect the sunset of the ENERGY STAR 
Program for lamps and luminaires effective December 31, 2024. The change is 
necessary to ensure details  of the (audible) noise test method can instead be found in 
Section JA8.8.  
   
Section:  JA8.4  
Specific Purpose : The specific purpose is to update the reference in Joint Appendix 
JA8, and the change is to remove the text “Table 150.0 -A” from the list of compliance 
for the light source to certify under JA8.  
Necessity: The change to remove the text “Table 150.0 -A” is reasonably necessary as 
the table is proposed to be removed from the Energy Code and the table is no longer a 
part of the Code. The change is necessary to ensure the code language is up to date.  
  
Section:  JA8.6  - Table JA -8 
Specific Purpose : The specific purpose is to update the light source types listed in data 
reporting of Joint Appendix JA8 and the change is to delete “fluorescent” and 
“incandescent” as listed in Table JA -8. These general service lamp types (“light source 
type”) are banne d for the sales in California.  
Necessity: The change to remove the incandescent light sources and the fluorescent 
light sources is to reflect the federal law (DOE new final rules related to general service 
lamps as published in the Federal Register, 10 CFR Parts 429 and 430, and Federal 
Register v olume number 87FR53618) that bans the manufacturing and sale of general 
service incandescent lamps after July 2023 and the California law (AB -2208) that bans 
the sales and distribution of fluorescent lamps as a new manufactured product after 
2024 and 2025 - banning screw and bayonet base type compact fluorescent (CFL) 
lamps after January of 2024 and banning pin -base type CFL) and linear fluorescent 
lamps after January of 2025.  
  
Section:  JA8.7   
 Specific Purpose : The specific purpose is to add a new subsection for start time test 
method. The new subsection contains the start time test method requirements based on 
the previously referenced document, “ ENERGY STAR program Test Method – Start 
Time”.  
Necessity: The change to add a new subsection for start time test method is 
reasonably necessary to specify the start time test method. The start time test method is 
published under the ENERGY STAR program for lamps and luminaires (also known as 
"ENERGY STAR specific ations for lamps and luminaires") and the program has been 
announced to be sunset effective December 31, 2024. The change is necessary to 
ensure details of the start time test method are retained in Joint Appendix JA8.  
  
Section:  JA8.8  
Specific Purpose : The specific purpose is to add a new subsection for noise test 
method. The new subsection contains the noise test method requirements based on the 
previously referenced document, “ENERGY STAR program Test Method – Noise”.  
Necessity: The change to add a new subsection for noise test method is reasonably 
necessary to specify the noise test method. The noise test method is published under 
the ENERGY STAR program for lamps and luminaires (also known as "ENERGY STAR 
specifications for lamp s and luminaires") and the program has been announced to be 
sunset effective December 31, 2024. The change is necessary to ensure details of the 
noise time test method are retained in Joint Appendix JA8.  
  
Section  JA10.5  
Specific Purpose : The specific purpose is to update the list of reference documents for 
the test procedure for lamp stabilization of Joint Appendix JA10 and following are the 
changes.  
- The change is to delete “IES LM -9 for circle  line, and U -tube fluorescent 
systems” and “Code of Federal Regulations 10 CFR 430.23(q) for linear 
fluorescent systems” from Section JA10.5.  
- The change is to revise the reference document for induction lamps” as “IES -LM-
66 for induction lamps”.  
- The change is to revise the reference document for high intensity discharge 
lamps as “IES -LM-51 for high intensity discharge lamps”.  
These testing reference documents are related to the general service lamp types that 
are banned for the sales in California.  
Necessity: The change to remove the testing reference documents related to the 
general service incandescent light sources and the general service fluorescent light 
sources is to reflect the federal law (DOE new final rules related to general service 
lamps as publishe d in the Federal Register, 10 CFR Parts 429 and 430, and Federal 
Register volume number 87FR53618) that bans the manufacturing and sale of general 
service incandescent lamps after July 2023 and the California law (AB -2208) that bans 
the sales an d distribution of fluorescent lamps as a new manufactured product after 
2024 and 2025 - banning screw and bayonet base type compact fluorescent (CFL)  
 lamps after January of 2024 and banning pin -base type CFL) and linear fluorescent 
lamps after January of 2025.  
The change to revise the reference documents for the test procedure of induction lamps 
and high intensity discharge lamps is reasonably necessary in order to keep the 
reference documents accurate and up to date.  
 
Section : JA12. 1 
Specific Purpose: Remove language  regarding battery storage compliance credit. This 
clarifies that JA12 is not only a compliance credit, but also a prescriptive requirement. 
Added reference to Section 170.2(h), which is the prescriptive BESS requirement for 
newly constructed high-rise multifamily buildings.  
Necessity: These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building desi gn and construction.  
 
Section : JA12.2  
Specific Purpose: Introduced definitions for cycling capacity, compliance cycling 
capacity , reserve level, Integrated BESS, Field Assembled BESS, cycling capacity and 
usable capacity to explain the new requirements for energy storage systems.  These 
definitions are identical to the new definitions added to JA1 and  are added in JA12.2 for 
easy reader access.  
Necessity: These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building desi gn and construction.  
  
Section : JA12.3.1  
Specific Purpose:  Added alterative  inverter safety requirement for UL1741 SB. This 
aligns with updates to CPUC Electric Rule 21  for grid support inverters . 
Necessity: These changes are necessary to ensure the safety standards does not 
conflict with Rule 21  and ensure  the general clarity and internal consistency of the 
Energy Code.  
 
   
Section : JA12.3.2.1 and JA12.3.2.2  
Specific Purpose: Removed the prescriptive requirement for minimum 5 kWh usable 
capacity for the BESS . There is no prescriptive BESS  requirements for single -family . 
Exception 5 to 150.1(c)14  already specifies the minimum  usable capacity of 7.5 kWh to 
qualify for the exception. Similarly , Exception 2 to Section 140.10(b) and Exception 2 to 
Section 170.2(h) specified that no BESS is required if it is less than 10 kWh .  
Necessity: These changes are necessary to clarify the BESS  requirements in JA12.  
  
Section : JA12.3.3(c)  and (d)   
 Specific Purpose: These section s has been removed and subsequent  section 
renumbered. The specific purpose of this change is to remove  the existing  power shut -
off requirements . 
Necessity: These changes are necessary to clarify the BESS  requirements in JA12.  
Based on industry feedback. BESS typically do not have a separate backup mode , 
rather the backup behavior described in JA12.3.3(c) is already  embedded within the 
control strategies in JA12.4. As a result , this language is no longer necessary.  
  
Section : JA12.3.3( c) and (d)  after renumbering  
Specific Purpose: The specific purpose of this change is to add a new 72 -hour reset 
requirement for BESS  in single -family applications. This new requirement will reset the 
cycling capacity back to the compliance cycling capacity after 72 -hour as a result of 
changes in reserve level. This reset requirement exclude reserve level changes due to 
severe weather or Public Safety Power Shutoff events.  
Necessity: These changes are necessary to ensure the load shifting capability  and 
Long-term System Cost  benefits of the BESS will be preserved  throughout the life of the 
BESS . At the same  time, this change allows  some user flexibility with the 72 -hour reset . 
  
 
Section : JA12.4.5  
Specific Purpose: Price Optimization Control strategy is introduced for BESS  installed 
for non -residential buildings to mimic the operation of the real non -residential energy 
storage systems.  
Necessity: These changes are necessary to provide flexibility for BESS manufacturers 
with an additional option to comply with the JA12 control requirements.  
  
Section : JA12.4. 6 
Specific Purpose:  This section has been edited for clarity. Section numbers have been 
updated and added references to “applications” for the alternative control strategies.  
Necessity:  These changes are necessary to ensure and improve the general clarity 
and internal consistency of the Energy Code . The reference to “applications” clarifies 
that the Executive Director may approve the application to the alternative control option.  
 
Section : JA12.5  
Specific Purpose: System labeling has been introduced for BESS installation in single -
family buildings to provide information for the installed BESS. Minimum information 
required on the label includes the JA12 compliance cycling capacity  and total capacity.   
Necessity: These changes are necessary to document the installed information of the 
BESS and  is an essential part of the verification step specified in JA12.6. The label also 
provides useful information for the building owner on the specification of the installed 
BESS.  
  
Section : JA12 .6  
 Specific Purpose: The section has been removed because of potential redundancy 
with other California Public Utilities Commission and Publicly Owned Utility 
interconnection requirements. Also, the load serving entities already have the 
interconnection procedures in place.  Subsequent  sections renumbered.  
Necessity: These changes are necessary to remove the potential redundant 
requirements for interconnection.  
  
Section : JA12.6  after renumbering  
Specific Purpose: Additional  language has been added to clarify the  additional 
verification of the new BESS label and compliance cycling capacity  requirements for 
newly constructed single -family installations.  
Necessity: These changes are necessary to  provide clear guidance to the enforcement 
agency  for verification of JA12 BESS  for single -family buildings.   
  
Section : JA12.7  after renumbering  
Specific Purpose: The specific purpose of this change is to specify  the minimum 
documentation requirements for BESS manufacturers for JA12 certification. The 
required documentation includes BESS specifications sheet, documentation on control 
strategies, and documentation on the 72 -hour reset specified in JA12.3.3 (d). 
Necessity: These changes are necessary to provide clear guidance for manufacturers  
for JA12 certification.  
   
Section:  JA13.3.2  
Specific Purpose: The specific purpose of this change is to update the Northwest 
Energy Efficiency Alliance (NEEA) Advanced Water Heater Specification version to 8.0, 
and remove exclusion language to Appendix A.  
Necessity: This appendix is necessary to align with the most recent version of the 
Northwest Energy Efficiency Alliance (NEEA) Advanced Water Heater Specification.  
  
Section:  JA13.3.3(g)  
Specific Purpose: The specific purpose of this change is to clarify that this requirement 
to provide data remotely is only for the capability, and not requiring the JA13 heat pump 
water heater to provide this information.  
Necessity: This change is essential for providing clarity regarding the intent of the code 
regarding JA13 certification.  
   
Section:  JA15  
Specific Purpose: The specific purpose of adding this ap pendix i s to support updates 
to the Standard language relating to central heat pump water heater ready. This 
provides  sizing requirements,  for electric ready infrastructure installed with gas or 
propane water heating systems to meet the requirement for electric readiness specified 
in Title 24, Part 6, Section 160.9(e)  
Necessity: This appendix is necessary to describe in specific detail the qualification 
requirements for central heat pump water heater ready specified in Section 160.9(e).   
   
 
  
Section:  JA16  
Specific Purpose: The specific purpose of adding this appendix is to support updates 
to the Standard language relating to installation of pool and/or spa heating systems. The 
appendix provides eligibility criteria for the mandatory pool heater requirements in 
Section 110.4(c), which includes solar pool and/or spa heating system certification 
requirements, heat pump pool heater methodology, and documentation requirement for 
on-site renewable or r ecovered energy.  
Necessity: This appendix is necessary to describe in specific detail the eligibility 
requirements for heat source sizing for pool heaters specified in Section 110.4(c).  
These changes are necessary to increase energy efficiency via cost -effective building 
design standards, as directed by California Public Resources Code Sections 25213 and 
25402. These additions reduce L ong-term System Cost  and Source Energy  use via the 
use of cost -effective solar thermal swimming pool applications, properly sized heat 
pump pool heater, or alternative energy efficient pool heating technologies.  
  
Section:  JA17  
Specific Purpose:  The specific purpose of this change is to add a new joint appendix 
JA17 to the reference appendices that includes qualification requirements for HRV/ERV 
system fault indicator system displays.  
Necessity: This addition is necessary to provide manufacturers or controls suppliers a 
method to verify and comply with the Title 24, Part 6, Section 150.1c.15 HRV/ERV 
ventilation system fault indication display requirements  including the fault indication 
categories, instrumentation and reporting, and manufacturer certification s  
 
Section:  JA18 Guideline 36 Programming Library Certification Submittal Requirements  
Specific Purpose : The specific purpose of this additional appendix is to define the 
certification requirements for the programming libraries to be used for HVAC control 
systems as stated in Section 140.4(r). Each Building Automation System (BAS) 
manufacturer or controls s upplier wishing to certify their G36 libraries should conform to 
the G36 library requirements of Title 24, Part 6. The manufacturers or controls suppliers 
can refer to JA18 for the programming library certification requirements, certificati on 
process, and declaration form.  
Necessity:  These changes are necessary to provide BAS manufacturers or controls 
suppliers a method to comply with the Title 24, Section 140.4(r) certification 
requirement. They provide compliant pathway for stakeholders in meeting Title 24 
Requirements.  
  
Section:  RA 
Specific Purpose: Replace EER and SEER with EER2 and SEER2.   
 Necessity: In residential buildings, space conditioning efficiency metrics were updated 
to EER2/SEER2/HSPF2. The residential appendix was updated to reflect that these 
new metrics are now used in place of the original EER and SEER metric.  
  
Section : Table RA2 -1 
Specific Purpose : The specific purpose of this change is to reflect changes in the 
RA3.6 sections , to remove performance credit options for multifamily buildings for whole 
house fans, central fan ventilation cooling systems,  and precooling,  and general clean 
up changes .  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code. The performance options listed were removed from 
multifamily buildings because they were infrequently installed in these buildings, and 
removing them simplifies our code language requirements, and simplifies compliance as 
it relates to these buildings.  
  
Section:  RA2.1  
Specific Purpose:  The purpose of this change is to address existing issues with 
identifying ECC -Raters as special inspectors for residential construction  by removing 
that designation . 
Necessity:  This change is necessary to clarify the ECC -Rater's role and to limit the 
restrictions that local jurisdictions can place of legitimate ECC -Rater activities. The 
designation as a special inspector requires more training than an ECC -Rater would 
receive as well as approval by a local jurisdiction to provide inspection services in its 
jurisdiction. This benefits the CEC  in accomplishing its responsibility under Statute 
25402.  
 
Section:  RA3 - Change from Low -Rise Residential to Single -Family and Multifamily.  
Specific Purpose:  The purpose of this change is to replace language that limited this 
section to only low -rise residential buildings with language that more accurately 
described the applicability of these requirements to single -family and multifamily 
buildings.  These changes appear  and apply  throughout RA3 therefore this is intended to 
identify the purpose and necessity as a consolidated grouping.  
Necessity:  This change is needed to ensure that this language accurately accounts for 
scenarios where these requirements may apply to multifamily buildings above 3 
habitable stories. Where these measures are applicable to multifamily buildings 
regardless of building height, this change ensures consistency exists.  
   
Section:  RA3.2.3 .1 Weigh -In Charging Procedure  
. 
Purpose: This section is changed to apply to heat pumps . This would extend 
verification requirements to heat pumps in all climate zones except 6 and 7.  
Necessity: These changes are required to  ensure the weigh -in charging procedure can 
be applied to heat pumps , increasing energy saving s.  
  
 Section:  RA3.2.3 .1.5 Weigh -In Procedure  
Purpose: The purpose of t he changes in this section are to add to and  improve upon 
the clarity of the weigh -in procedure . These changes  retain existing methods but adds 
rigor to the weigh -in method . 
Necessity: These changes are required to describe the enhanced requirements for 
documentation and adds increased rigor to the weigh -in method to make charge 
verification more accurate, increasing energy savings  
 
Section:  RA3.2.3 .1.5 Weigh -In Procedure  
Purpose: The purpose of the deletions in this section are to improve upon the clarity of 
weigh -in procedure.  Indoor coil inclusion  and line set length and diameter vary by 
manufacturer . The added language improves upon the removed language ’s clarit y by 
referencing the need to utilize manufacturer instructions .  
Necessity: These changes are required to describe the enhanced requirements for 
documentation and add clarity  to the weigh -in method to make charge verification more 
accurate, increasing energy savings  
 
Section:  RA3.2.3 .2 ECC -Rater – Observation of Weigh -In Charging Procedure  
Purpose: The purpose of the changes in this section is to update  the ECC -Rater 
verification  procedure  related to  weigh -in charge verification  so that it conforms with the 
new charge verification requirements .  
Necessity: These changes are required to describe the enhanced requirements for 
documentation and adds increased rigor to the weigh -in method to make charge 
verification more accurate, increasing energy savings.  
 
Section:  RA3.2.3 .2 ECC -Rater – Observation of Weigh -In Charging Procedure  
Purpose: The purpose of the deletions in this section is to reflect the changes that have 
been made to the weigh -in method in RA3.2.3 .1.5. 
Necessity: These changes are required to add clarity  to the weigh -in method to make 
charge verification more accurate, increasing energy savings.  
 
Section: RA 3. 3.3  
Purpose: brokeout the term low-rise to single -family and multifamily  
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous  for the specific building type.   
 
 
Section: RA 3.5.1  
Purpose: Added subsection 170.2(a)6 to RA 3.5.1. Per Section 170.2(a)6 Multifamily 
building with 3 stories of less do need to meet QII requirements in RA 3.5.  
Necessity:  These changes are necessary to ensure that provisions in subsequent 
sections are clear and unambiguous, and that non -technical readers are able to find and 
understand the technical meaning of specific terms and technical standards relating to 
building des ign and construction   
    
Section : RA3.6.2  
Specific Purpose : The specific purpose of this change is to reflect pipe insulation 
changes in Section 150.0(j) and consolidate pipe insulation verification procedure 
preciously in both RA3.6.2 and RA3.6.3. RA section renamed to apply to single dwelling 
system only.   
Necessity: These changes are necessary to provide procedures for ECC raters to 
check pipe insulation quality. These changes are necessary to improve the general 
clarity and internal consistency of the Energy Code.  
  
Section : RA3.6.3  
Specific Purpose : The specific purpose of this change is to create a new verification 
procedure to reflect pipe insulation changes specified in Section 160.4 for central water 
heating systems. The new procedure requires visual inspection of the heating plant, 
horizontal s upply heater, and return piping to verify that the mandatory pipe insulation 
requirements in Section 160.4 are met. Previous procedure for single dwelling has been 
consolidated to RA3.6.2.  
Necessity: These changes are necessary to provide procedures for ECC raters to 
check pipe insulation quality. These changes are necessary to improve the general 
clarity and internal consistency of the Energy Code.  
  
Section : RA3.6.8  
Specific Purpose : The specific purpose of this change is to remove the verification 
procedure for multiple recirculation loop and renamed section to “Reserved”. This 
change aligns with removal of the same compliance credit reference in RA4.4.19.  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code. Multiple loop credit has been removed as a 
compliance credit because of uncertainty about the actual performance. This change 
aligns with changes in RA4 .4.19 and the compliance software.  
  
Section: RA3.8.3(c)  
Specific Purpose:  The specific purpose of this change is to add a multi -point 
airtightness test as specified in RESNET 380 section 4.4.2.  
Necessity: Single -point test is done at 50 Pa or close whereas a multipoint test is done 
at several different pressures which helps increase test accuracy results in blower door 
tests. The addition of a multi -point airtightness test is necessary to increase energy 
efficiency, ensure ventilation control for public health and safety, and is consistent with 
the California Public Resources Code Sections §25402 and §25402.8 on assessment of 
indoor air pollution in new buildings.  
  
Section: RA3.8.4(a)  
Specific Purpose:  The specific purpose of this change is to add the word ‘if’ 
determined by a one -point airtightness test as specified in RESNET 380 section 4.5.1. 
equation 5(a).   
 Necessity: These changes are necessary as there is an addition of an option for a  
multi -point airtightness test in RA3.8.3 and thus adding the word ‘if’ would improve 
general clarity and internal consistency of the Energy code, as directed by California 
Government Code Sections 11349 and 11349.1 and California Code of Regulations, 
Title 1, Section 16.  
 
Section:  RA3.9.1  
Specific Purpose:  This addition is necessary to clearly state that RA3.9.1 is intended 
to measure WHF systems . 
Necessity:  This change is necessary to improve general clarity and internal 
consistency of the E nergy Code, as directed by California Government Code Sections 
11349 and 1134 9.1, and California Code of Regulations, Title 1, Section 16.  
 
Section : RA4.4.1  
Specific Purpose : The specific purpose of this change is to update the reference to the 
California Plumbing Code from Section 609.11 to Section 609.12. This section was 
renumbered in the 2022 California Plumbing Code. In addition, the phrase “Unless 
otherwise stated” is r emoved and “must” changed to “shall” for clarity. All insulation shall 
meet the mandatory requirements in Section 150.0(j).  
Necessity : These terms ensure and improve the general clarity and internal 
consistency of the Energy Code.  
  
Section : RA4.4.3  
Specific Purpose : The specific purpose of this change is to create new qualification 
criteria to receive compliance credit for thermostatic balancing valve. The criteria 
include  calculation that the return pipe portion of the recirculation loop does not exceed 
160 feet, the installation of a variable speed pump, and start -up procedure for the 
installer.  
Necessity: These changes are necessary to implement this compliance credit by 
providing procedures for installers and inspectors. The procedures ensure the 
thermostatic balancing valves performs properly and that the energy savings claimed by 
the compliance credit would be realized. These changes are necessary to increase 
energy efficiency via cost -effective building design standards, as directed by California 
Public Resources Code Sections 25213 and 25402, and to improve the general clarity 
and internal consistency of the Energy Code.  
  
Section : RA4.4.14  
Specific Purpose : The specific purpose of this change is to update reference to single 
dwelling and RA3.6.2 to reflect changes in the RA3.6 sections.  RA3.6.2 has been 
updated to reflect pipe insulation changes in Section 150.0(j) and consolidate pipe 
insulation verification procedure preciously in both RA3.6.2 and RA3.6.3  
Necessity: These changes are necessary to improve the general clarity and internal 
consistency of the Energy Code. This change reference the correct RA3.6 section.  
   
 Section : RA4.4.19  
Specific Purpose : The specific purpose of this change is to create new qualification 
criteria for master mixing valves. Previous reference to HERS -Verified multiple 
recirculation loop has been removed to align with changes in RA3.6.8.  The building 
designers and contractors are required to provide minimum MMV specification, 
installation, and commissioning requirements.  
Necessity: These changes are necessary to provide procedures for installers and 
inspectors  and to  support the new master mixing valve requirement specified in Section 
170.2(d)2D.  These changes ensure the master mixing valves are properly installed and 
to increase energy efficiency via cost -effective building design standards, as directed by 
California Public Resources Code Sections 25213 and 25402 , and to improve the 
general clarity and internal consistency of the Energy Code . 
   
 
 Section : Table NA1 -1 
Purpose : The purpose of this change is to delete field verification and diagnostic testing 
and replace it with acceptance testing for the nonresidential and multifamily common 
area duct leakage test. NA2 is reserved ECC  field verification and diagnostic tests and 
NA7 is reserved for acceptance tests. This language was moved from NA2.1 to 
NA7.5.3.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential and multifamily common area duct 
leakage test to first be performed by a certified mechanical ATT and then field verified 
by an ECC -rater. The change is necessary because this is duplicative and redundant as 
written in the 2022 Energy Code where the duct leakage test procedure is the same for 
both tests. The ATTCP program and the ECC  program are both intended to ensure 
equipment  are installed in compliance with the Energy Code. Functional testing in 
nonresidential buildings and multifamily common areas is under the scope of the 
ATTCP program. Removing the ECC  field verification and diagnostic requirement will 
also reduce confusion moving forward on who needs to perform the duct leakage test.  
 
Section : NA1. 2.2 
Purpose:  The purpose of this change is to conform with the new requirements 
restricting duct acceptance testing to  certified Acceptance Test Technicians .  
Necessity:  The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential and multifamily common area duct 
leakage test to first be performed by a certified mechanical ATT and then field verified 
by an ECC -rater. The  change is necessary because this is duplicative and redundant as 
written in the 2022 Energy Code where the duct leakage test procedure is the same for 
both tests. The ATTCP program and the ECC program are both intended to ensure 
equipment are instal led in compliance with the Energy Code. Functional testing in 
nonresidential buildings and multifamily common areas is under the scope of the 
ATTCP program. Removing the  ECC  field verification and diagnostic requirement will 
also reduce confusion moving forward on who needs to perform the duct leakage test.  
  
 Section : NA1.6.3  
Purpose:  This purpose of this addition was to clarify existing procedures regarding the 
use of Certificates of Acceptance and ECC -Raters  performing field verification and 
diagnostic testing.  
Necessity:  This addition is necessary to reinforce the current practices of ATTs and 
ECC -Raters as they interact in the field. Currently, ECC -Raters are not required to 
register Certificates of Acceptance completed by ATTs , but this requirement Is not 
explicit. This addition will help to streamline compliance in accordance with California 
Public Resources Code Sections §25402.  
 
Section : NA1.9.1  
Purpose : The purpose of this change is to remove the condition that the enforcement 
agency must approve the alternative procedure for field verification by the ATT as 
specified in NA1.9.  
Necessity : The intent of NA1.9 is to allow an ATT to perform field verification if an ATT 
is already on the project performing acceptance tests or if the installer is a certified ATT. 
NA1.9 is only applicable to nonresidential buildings, common areas of multifamily  
buildings, and high -rise multifamily buildings. To have the enforcement agency approve 
this process may be overly onerous because NA1.9 is not commonly used so the 
enforcement agency is likely not familiar with this procedural alternative regulat ion. The 
requirements in NA1.9.2 for compliance documentation will be sufficient to ensure the 
tests were performed.  
 
Section : NA2.1  
Purpose : The purpose of this change is to delete HERS field verification and diagnostic 
testing and replace it with acceptance testing for the nonresidential and multifamily 
common area duct leakage test. NA2 is henceforth  reserved field verification and 
diagnostic tests and NA7 is reserved for acceptance tests. This language was moved 
entirely from NA2.1 to NA7.5.3.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential and multifamily common area duct 
leakage test to first be performed by a certified mechanical ATT and then field verified 
by an ECC  rater. The change is necessary because this is duplicative and redundant as 
written in the 2022 Energy Code where the duct leakage test procedure is the same for 
both tests. The ATTCP program and the ECC  program are both intended to ensure 
equipment are installed in compliance with the Energy Code. Functional testing in 
nonresidential buildings and multifamily co mmon areas is under the scope of the 
ATTCP program. Removing the field verification and diagnostic requirement will also 
reduce confusion moving forward on who needs to perform the duct leakage test.  
 
Section:  Table NA2.2 -1 
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.   
 Necessity:  This change is necessary to better clarify or correct minor issues with the 
Energy Code. This is done to be consistent with California Government Code 11349 
and 11349.1 and California Code of Regulations title 1, Section 16. Section NA2.2.4.2 
was reorgani zed and renumbered to NA2.2.4.1.3, unfortunately Table NA2.2 -1 was not 
updated to reflect this minor change in the 2022 Energy Code.  
   
Section:  NA2.2.4.1.5  
Specific Purpose:  The specific purpose of this change is to update Home Ventilating 
Institute (HVI) Certified Home Ventila ting products directory link for the Heat Recovery 
Ventilation (HRV) or Energy Recovery Ventilation (ERV) rated performance verification . 
Also, Home Ventilating Institute (HVI) Certified Home Ventilating Products Directory  
website link to the program has been updated.  
Necessity:  These changes are necessary as the HRV/ERV rated performance 
verification relies upon  the HVI certified home ventilating products directory or another 
directory of certified product performance ratings approved by the CEC  for compliance.  
 
Section: NA2.3.3(3)  
Specific Purpose:  The specific purpose of this change is to add a multi -point 
airtightness test as specified in RESNET 380 section 4.4.2.  
Necessity: Single -point test is done at 50 Pa or close whereas a multipoint test is done 
at several different pressures which helps increase test accuracy results in blower door 
tests. The addition of a multi -point airtightness test is necessary to increase energy 
efficiency, ensure ventilation control for public health and safety, and is consistent with 
the California Public Resources Code Sections §25402 and §25402.8 on assessment of 
indoor air pollution in new buildings.  
   
Section: NA2.3.4(1)  
Specific Purpose:  The specific purpose of this change is to add the word “if” 
determined by a one -point airtightness test as specified in RESNET 380 Section 4.5.1 
equation 5(a).  
Necessity: These changes are necessary as there is an addition of an option for multi -
point airtightness test in NA2.3.3(3) and thus, adding the word ‘if’ would improve the 
general clarity and internal consistency of the Energy code, as directed by California 
Governm ent Code Sections 11349 and 11349.1 and California Code of Regulations, 
Title 1, Section 16.  
  
 
 
Section:  NA4. 4 
Specific Purpose : The specific purpose of the change is to correct minor typographical 
errors or to update references throughout NA4.4  
Necessity : The changes are necessary to ensure the code can be read without any 
confusions. The changes are reasonably necessary to ensure and improve the general 
clarity and internal consistency of the Energy Code.   
 Section; Table NA4 -1 
Purpose:  The specific purpose of this change is to reflect the change in terminology 
from T ime Dependent Valuation to Long-term System Cost  in all locations in the Energy 
Code and associated documents.  Long -term System Cost is similar to Time Dependent 
Valuation in that it varies for every hour of the year to capture the value of energy and 
emissions at different times of the day and at different times of the year. Long -term 
System Cost is a cost metric  that represents long -term marginal costs to the energy  
system over 30 -years through which we hope to better account for, and relay to the 
public, the long -term dollar cost impact to California’s energy system.  
Necessity: This change is needed to ensure consistency with the updates to the 2025 
Energy Standards and Reference Appendices.  
 
Section:  NA4.5(a) and NAA4.5(a)1(a) Optional Features  
Specific Purpose: Add EER2 and SEER2 to HVAC equipment examples.  
Necessity: Nonresidential projects still have the option of using residential or 
commercial equipment to provide space conditioning. Residential space conditioning 
efficiency metrics have been updated to EER2/SEER2/HSPF2 and are reflected in 
these examples. This chan ge will ensure internal consistency and will help reduce the 
unnecessary consumption of energy via cost -effective building standards.  
 
Section: NA5.9.3  
Purpose: The specific purpose of this change is to correct usage of the word 
“assembly” to improve readability; in this instance it should be singular and not plural.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: NA6.5.3.1  
Purpose: The specific purpose of this change is to remove the word “also” to improve 
readability.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.1  
Specific Purpose:  The specific purpose of this change is to clarify that the procedures 
of NA7.1 can apply to all multifamily buildings, and not just high -rise residential 
buildings.  
Necessity:  This change is reasonably necessary to ensure that all multifamily buildings  
comply with the applicable  requirements of NA7.1, and to ensure and improve the 
general clarity and internal consistency of the Energy Code, as directed by California 
Government Code, Section 11349 and 11349.1, and California Code of Regulations, 
Title 1, Section 16.  
  
 Section:  NA7.2  
Specific Purpose:  The purpose of this change is to delete field verification and 
diagnostic testing and replace it with acceptance testing for the nonresidential and 
multifamily duct leakage test.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential and multifamily common area duct 
leakage test to first be performed by a certified mechanical ATT and then field verified 
by an ECC -rater. The change is necessary because this is duplicative and redundant as 
written in the 2022 Energy Code where the duct leakage test procedure is the same for 
both tests. The ATTCP program and the ECC program are both intended to ensure 
equipment  are installed in compliance with the Energy Code. Functional testing in 
nonresidential buildings and multifamily common areas is under the scope of the 
ATTCP program. Removing the ECC field verification and diagnostic requirement will 
also reduce confusio n moving forward on who needs to perform the duct leakage test.  
 
Section:  NA7.4.6.3(g)  
Specific Purpose:  
The purpose of this deletion is to remove a verification that is applicable to a different 
type of installation.  
Necessity:  
This deletion is necessary to remove what appears to be a reference to operable 
shading control having nothing to do with light shelves and will improve clarity and 
readability of the regulations in furtherance of California Government Code 11349 and 
11349 .1 and California Code of Regulations title 1, Section 16. This change does not 
impact the compliance obligations of regulated entities.  
 
Section:  NA7.5.1.1.1(f)  
Specific Purpose:  The specific purpose of this change is to allow a newly installed 
HVAC system to pre -purge 1 hour prior to occupation using the methods as provide d in 
Section 120. 1(d)2.  
Nece ssity: This change is necessary to refrain from inadvertently restricting the 1-hour 
pre-purge requirement for occupied spaces at the rate prescribed by Section 120.1(c) . 
Section 120.1(d)2 allow s pre-purge to be lesser of the minimum rate of outdoor air 
required by Section 120.1(c) or three complete air changes supplied to the entire 
building during the one -hour period immediately before the building is normally 
occupied.  The alternative “three complete air changes ” was inadvertently restricted by 
the directions in NA7.5.1.1.1(f).  This change  is consistent with California Public 
Resources Code Sections 25213 and 25402 . 
 
Section:  NA7.5.1.2.1(c)  
Specific Purpose:  The specific purpose of this change is to allow a newly installed 
HVAC system to pre -purge 1 hour prior to occupation using the methods as provide d in 
Section 120.1(d)2.   
 Necessity: This change is necessary to refrain from inadvertently restricting the 1 -hour 
pre-purge requirement for occupied spaces at the rate prescribed by Section 120.1(c). 
Section 120.1(d)2 allows pre -purge to be lesser of the minimum rate of outdoor air 
required by Section 120.1(c) or three complete air changes supplied to the entire 
building during the one -hour period immediately before the building is normally 
occupied. The alternative “three complete air changes” was inadvertently restricted by 
the d irections in NA7.5.1.2.1(c). This change is consistent with California Public 
Resources Code Sections 25213 and 25402.  
 
Section:  NA7.5.2.1(a)  
Specific Purpose:  The purpose of this change modifies language related to an 
unintended curtailment of compliance paths regarding thermostat locations  and adds 
the appropriate Energy Code reference . 
Necessity:  This change is necessary to address an unintended curtailment of 
compliance paths regarding thermostat locations  and improve readability and clarity of 
the regulations by allowing builders to implement compliance pathways already 
provided in the Energy Code. This is necessary to comply with California Government 
Code 11349 and 11349.1 and California Code of Regulations t itle 1, Section 16.  
 
Section : NA7.5.3  
Purpose : The purpose of this change is to delete HERS field verification and diagnostic 
testing and replace it with acceptance testing for the nonresidential and multifamily 
common area duct leakage test. NA2 is here forth  reserved field verification and 
diagnostic tests and NA7 is reserved for acceptance tests. This language was moved 
from NA2.1 to NA7.5.3.  
Necessity : The mechanical ATTCP program became effective as of October 2021. The 
2022 Energy Code language requires nonresidential and multifamily common area duct 
leakage test to first be performed by a certified mechanical ATT and then field verified 
by a rater. The change is necessary because this is duplicative and redundant as 
written in the 2022 Energy Code where the duct leakage test procedure is the same for 
both tests. The ATTCP program and the  ECC  program are both intended to ensure 
equipment are installed in compliance with the Energy Code. Functional testing in 
nonresidential buildings and multifamily common areas is under the scope of the 
ATTCP program. Removing the HERS field verification and diagnostic requirement will 
also reduce confusion mo ving forward on who needs to perform the duct leakage test.  
  
Section:  NA7.5.4.1(a)  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to improve readability and clarity of the 
regulations by allowing builders to implement compliance pathways already provided in 
the Energy Code. This is necessary to comply with California Government Code 11349 
and 11349.1 and Cali fornia Code of Regulations title 1, Section 16.  
   
 Section:  NA7.5.4.2  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to improve readability and clarity of the 
regulations by allowing builders to implement compliance pathways already provided in 
the Energy Code. This is necessary to comply with California Government Code 11349 
and 11349.1 and Californi a Code of Regulations title 1, Section 16.  
 
Section:  NA7.5.5.1  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to improve readability and clarity of the 
regulations by allowing builders to implement compliance pathways already provided in 
the Energy Code. This is necessary to comply with California Government Code 11349 
and 11349.1 and Cali fornia Code of Regulations title 1, Section 16.  
  
Section: NA7.5.9.2(h)  
Purpose: The specific purpose of this change is to remove the word “either” to improve 
readability  and clarify that there is only one option.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.5.10.2  
Specific Purpose : The changes to this section add step 3 for clarity of a action that 
already takes place in the field. The purpose of this change is to correct minor errors in 
referencing, spelling and grammar.  
Necessity:  This change is necessary to better clarify or correct minor issues with the 
Energy Code. The addition of the final step (step 3) to return the system to normal 
operating condition is necessary to ensure consistency with most acceptance tests. This 
benefits  the CEC  by complying with California Government Code 11349 and 11349.1 
and California Code of Regulations title 1, Section 16.  
  
Section:  NA7.5.14.2  
Specific Purpose:  The changes in this section add and modify language for clarity of 
an established acceptance  test. The purpose of this change is to correct minor errors in 
referencing, spelling and grammar.  
Necessity:  This change is necessary to better clarify or correct minor issues with the 
Energy Code.  This benefits the CEC  by complying with California Government Code 
11349 and 11349.1 and California Code of Regulations title 1, Section 16. The 
acceptance test NA7.5.14.2 included references to a “second part” and a “step 2” 
neither of which is expressly specified in the acce ptance testing procedures. These 
changes correct this minor oversight.  
   
 Section: NA7.5.17.2, Step 2  
Purpose: The specific purpose of this change is to correct a minor grammatical error to 
improve readability; it should read as “detects” and not “detect”.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: NA7.5.18, NA 7.5.18.1, NA 7.5.18.2  
Specific Purpose:  These changes add requirements for construction inspection of 
blowdown controls and functional testing of overflow alarm, as applied to all open - and 
closed -circuit cooling towers.  
Necessity: Water savings associated with blowdown controls are dependent on the 
functionality of the controls. Inspection and testing of controls and overflow alarm will 
ensure that controls are operating properly and reductions in water usage are realized. 
These tes ting requirements for blowdown controls will reduce excessive water use and 
avoid the unnecessary consumption of energy, consistent with California Public 
Resources Code Sections 25213 and 25402. These parameters are based on the 
typical industr y practice and ensure that the operation of the cooling tower is not 
degraded based on water quality.  
  
Section: Table NA -7 
Specific Purpose: These changes add a table to specify blowdown parameters for 
cooling towers.  
Necessity: Water savings for cooling towers are achieved through reduced water loss 
from blowdowns. Parameters identified in Table -NA-7 are used to determine when 
cooling tower blowdown is required. These parameters are the same parameters 
included in Section 110.2(e ) of the Building Efficiency Standards.  
  
Section: NA7.6.1.1  
Specific Purpose: The specific purpose of the change to this section is to make non -
substantive formatting changes and subdivision heading changes necessary to 
effectively communicate the requirements and standards in a precise and clear manner.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: NA7.6.1.4(e)  
Purpose: The specific purpose of this change is to remove the word “aforementioned” 
to improve readability.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Sectio n: NA7.6.2.5(d)   
 Purpose: The specific purpose of this change is to correct a minor grammatical error to 
improve readability; it should read as "are” instead of “is”.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section: NA7.6.2.6(b)  
Purpose: The specific purpose of this change is to delete “exempt” and to add “that are 
not required to comply” about areas that are not required to comply for the automatic 
time switch lighting controls functional testing. There are no substantiative changes to 
the functional testing requirements and the change will improve readability of the code 
language.  
Necessity: This change is necessary to ensure and improve the general clarity and 
internal consistency of the Energy Code, as directed by California Government Code, 
Section 11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
   
Section: NA7.6.3.1  
Specific Purpose: The specific purpose of the change to this section is to make non -
substantive grammatical changes necessary to effectively communicate the 
requirements and standards in a precise and clear manner.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
There are also non -substantive grammatical changes and subdivision heading changes 
necessary to effectively communicate the requirements and standards in a precise and 
clear manner.  
  
Section: NA7.6.5.1  
Specific Purpose: The specific purpose of the change to this section is to update the 
demand responsive controlled receptacle construction inspection requirements to be 
consistent with the construction inspection requirements for demand responsive lighting 
controls found in  NA7.6.3.1.  
There are also non -substantive grammatical changes and subdivision heading changes 
necessary to effectively communicate the requirements and standards in a precise and 
clear manner.  
Necessity: These changes are necessary to provide specific procedures that 
technicians must follow during the construction inspection and to ensure clarity and 
internal consistency within the Energy Code, as directed by California Government 
Code, Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 
16. 
Section: NA7.6.5.2  
Specific Purpose: The specific purpose of the change to this section is to make non -
substantive grammatical changes, formatting changes, and subdivision heading 
changes necessary to effectively communicate the requirements and standards in a 
precise and clear manner.   
 These changes include relocating language from subsections NA7.6.5.2.1, NA7.6.5.2.2, 
and NA7.6.5.2.3 and moving it to NA7.6.5.2  
The other change to this section is to replace the term ‘lighting controls’ with ‘controlled 
receptacles.’ This change is necessary to ensure that sampling procedures are based 
on the number of enclosed spaces required to have demand responsive controlled 
receptacles, which will result in greater compliance and, therefore, avoid the 
unnecessary consumption of energy.  
Necessity: The change to relocate the subsections to within the section help aid the 
reader understand the requirements and improve readability.  
The change to replace the term “lighting controls” with “controlled receptacles” is to 
update the test requirements with the requirements of Section 110.12 about controlled 
receptacles.  
This change is necessary to ensure clarity and internal consistency within the Energy 
Code, as directed by California Government Code, Sections 11349 and 11349.1, and 
California Code of Regulations, Title 1, Section 16.  
  
Section: NA7.6.5.2.1, NA7.6.5.2.2, NA7.6.5.2.3 (removed)  
Specific Purpose: The specific purpose of the change to this section is to make non -
substantive formatting changes and subdivision heading changes necessary to 
effectively communicate the requirements and standards in a precise and clear manner.  
Language from these subsections was relocated to NA7.6.5.2. These subsections were 
removed.  
Necessity: This change was necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.10.3.2 .2 Step 7  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to ensure all relevant original settings are reset. 
This change is necessary to ensure clarity and internal consistency within the Energy 
Code, as directed by California Government Code, Sections 11349 and 11349.1, and 
California C ode of Regulations, Title 1, Section 16.  
  
Section:  NA7.10.3.3.1d  
Specific Purpose:  The purpose of this change is to add an apostrophe to make 
“manufacturer” possessive to ensure grammatical accuracy and clarity.  
Necessity:  This change is necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
Section:  NA7.11.1.1  
Specific Purpose:  The purpose of this change is to update the reference to the current 
Table number, Table 140.9 -C.  
 Necessity:  This change is necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.15.2h   
Specific Purpose:  
The purpose of this change is to correct minor errors in referencing, spelling and 
grammar.  
Necessity:  The instruction in step h was inadvertently mixed up with the instructions in 
the previous step. The corrections are consistent with current practice in the field and 
will result in more clear code language . This change is necessary to ensure clarity and 
internal consistency within the Energy Code, as directed by California Government 
Code, Sections 11349 and 11349.1, and California Code of Regulations, Title 1, Section 
16.  
 
Section: NA 7.16.1 Construction Inspection for VAV Lab Exhaust System with 
Occupancy Control  
Specific Purpose: These changes itemize requirements for construction inspection of 
VAV lab exhaust system. Provide specifics for what minimum requirements should be 
based on what equipment is used in the lab exhaust system.  
Necessity: This section is necessary to list what measurements should be made on the 
VAV lab exhaust system, and how to use these measured results, to verify whether or 
not the equipment meets requirements identified in Section 140.9(c). This inspection is 
needed to ensure that equipment meets requirements and energy savings are realized. 
Verifying installation of requirements will ensure energy savings of measures as 
directed by California Public Resources Code Sections 25213 and 25402.  
  
Section: NA7.16.2 Functional Testing for VAV Lab Exhaust System with Occupancy 
Control  
Specific Purpose: These changes  include adding  steps for functional testing of 
occupancy controls.  
Necessity: Energy savings for occupied and unoccupied flowrates for laboratory 
exhaust systems are dependent on the functionality of the controls. Inspection and 
testing of controls, and fan power under different occupancy conditions will ensure that 
controls are ope rating properly and reductions in energy usage are realized. Simulating 
occupancy conditions and verifying the effects on space conditioning equipment is 
similar to other functional testing requirements for mechanical systems. These testing 
for controls will reduce excessive energy use as directed by California Public Resources 
Code Sections 25213 and 25402.  
  
Section: NA 7.16.3 Construction Inspection for Simple Turndown Control and NA 
7.16.4 Functional Testing for Simple Turndown Control   
 Specific Purpose: These changes  itemize requirements for construction inspection and 
functional testing of simple turndown controls. They also  provide specifics for comparing 
minimum requirements for fan power and airflow rates at various conditions.  
Necessity: This section is necessary to list what measurements should be made on the 
lab exhaust fan system when a simple turndown control is used, and how to use these 
measured results to verify whether or not the equipment meets requirements identified 
in Section 1 40.9(c). Conditions at minimum occupancy, and 60% design airflow are 
compared to performance and design conditions. This inspection is needed to ensure 
that equipment meets requirements and energy savings are realized. Verifying 
installation of requirements will ensure energy savings of measures as directed by 
California Public Resources Code Sections 25213 and 25402.  
  
Section: NA 7.16.5 Construction Inspection for Wind/Speed Direction Responsive 
Control and NA 7.16.6 Functional Testing for Wind Speed/Direction Responsive Control  
Specific Purpose: These changes  update requirements for construction inspection and 
functional testing of wind/speed direction responsive controls. Provide specifics for 
comparing minimum requirements for fan power and airflow rates at various conditions.  
Necessity: This section is necessary to list what measurements should be made on the 
lab exhaust fan system when a simple turndown control is used, and how to use these 
measured results to verify whether or not the equipment meets requirements identified 
in Section 1 40.9(c). Conditions at minimum occupancy and 60% of design airflow are 
compared to performance at design conditions. Existing test requirements were 
removed or revised as these requirements did not specify how the minimum airflow 
rates are compa red to the maximum airflow rates. This inspection is needed to ensure 
that equipment meets requirements and energy savings are realized. Verifying 
installation of requirements will ensure energy savings of measures as directed by 
California Public Resource s Code Sections 25213 and 25402.  
  
Section: NA 7.16.7 Construction Inspection for Monitored Contaminant Control and NA 
7.16.8 Functional Testing for Monitored Contaminant Control  
Specific Purpose: Update requirements for construction inspection and functional 
testing of monitored contaminant controls. Provide specifics for comparing minimum 
requirements for fan power and airflow rates at maximum and minimum conditions.  
Necessity: This section is necessary to list what measurements should be made on the 
lab exhaust fan system when a monitored contaminant control is used, and how to use 
these measured results to verify whether or not the equipment meets requirements 
identified in Sec tion 140.9(c). Conditions at minimum occupancy and 60% of design 
airflow are compared to performance at design conditions. Existing test requirements 
were removed or revised as these requirements did not specify how the minimum 
airflow rates are  compared to the maximum airflow rates. This inspection is needed to 
ensure that equipment meets requirements and energy savings are realized. Verifying 
installation of requirements will ensure energy savings of measures as directed by 
California Public Re sources Code Sections 25213 and 25402.  
   
 Section:  NA7.18.3  
Specific Purpose:  The purpose of this change is to update the reference to the most 
up-to-date test procedure for total duct leakage.  
Necessity:  This change is necessary to ensure the Energy Code is up to date  with the 
most recent industry -accepted test procedure. This change is necessary to ensure 
clarity within the Energy Code, as directed by California Government Code, Sections 
11349 and 11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.18.4  
Specific Purpose:  The purpose of this change is to correct minor errors in referencing, 
spelling and grammar.  
Necessity:  This change is necessary to ensure clarity and internal consistency within 
the Energy Code, as directed by California Government Code, Sections 11349 and 
11349.1, and California Code of Regulations, Title 1, Section 16.  
  
Section:  NA7.20.1  
Specific Purpose:  The purpose of this change is to address an error from the last code 
cycle by remov ing the reference to the operation of typical transcritical refrigeration 
systems in relation to other mechanical refrigeration systems.  
Necessity:  This change is necessary to avoid misleading local enforcement agencies 
when approving or inspecting installations of transcritical refrigeration systems . This will 
result in a clearer and easier  to enforce Energy Code, helping to avoid the unnecessary 
consumption of energy consistent with California Public Resources Code Section 
25402.  
  
Section:  NA7.20.1.1.1(f)  
Specific Purpose:  The specific purpose of this change is to address an error from  the 
last code cycle by remov ing the language that allow ed for the ambient dry bulb 
temperature sensor to be installed between two other specified components.  
Necessity:  This change is necessary to prevent transcritical refrigeration systems from 
sub-optimal operation due to an inaccurate sensor placement . This will result in a 
clearer and easier  to enforce Energy Code, helping to avoid the unnecessary 
consumption of energy consistent with California Public Resources Code Section 
25402.  
  
Section:  NA7.20.1.1.3 Step 2(a)  
Specific Purpose:  The purpose of this change is to remove instructions for technicians 
related to fan speed allowances that may have unintended consequences.  
Necessity:  This change is necessary to remove a recommendation to technicians that 
may, if followed, result in suboptimum performance of gas cooler fans in a refrigeration 
system , and the inefficient or wasteful use  of energy . This will result in a clearer and 
easier  to enforce Energy Code, helping to avoid the unnecessary consumption of 
energy consistent with California Public Resources Code Section 25402.  
 TECHNICAL, THEORETICAL, AND EMPIRICAL STUDIES, REPORTS, OR SIMILAR 
DOCUMENTS RELIED UPON  
The CEC relied on input from various stakeholders, subject matter experts, and 
interested parties that provided information, feedback, and subject matter expertise.  
In addition, the CEC relied upon the following documents:  
2025 CASE Re port - 2022 Refrigeration Addendum 
2025 CASE Re port - Buried Duc ts and Roofs with Cathedral Ceilings 
2025 CASE Re port - Commercial Kitchens 
2025 CAS E Re port - Control led Environme nt Horticulture 
2025 CASE Re port - Cooling Towers 
2025 CASE Re port - Daylighting 
2025 CASE Re port - Multifamily Domestic Hot Water 
2025 CASE Re port - Multifamily Envelope 
2025 CASE Re port - Multifamily Indoor Air Quality 
2025 CASE Re port - Multifamily Restructuring 
2025 CASE Re port - Nonresidential Envelope 
2025 CASE Re port - Nonresidential HVAC Control s - Guideline 36 
2025 CASE Re port - Nonresidential HVAC Space Heating 
2025 CASE Re port - Nonresidential Laboratories 
2025 CASE Re port - Process Load Pipe Insulation 
2025 CASE Re port - Residential HVAC Performance 
2025 CASE Re port - Single-Family High-Perfor mance Windows and Walls 
2025 CASE Report - Swimming Pool and Spa Heating 
2025 Single Family Dual Heat Pump Baseline 
2025 Nonresidential HVAC Heat Pump Baseline 
2025 Energy Code Accounting Methodology 
2025 Energy Code Measure Proposal - Photovoltaic and Battery Update 
and Expansion 
2025 Multifamily Individual Heat Pump Water Heater Baseline 
Final Staff Report: 2025 Update of Field Verification and Diagnostic Testing 
Requirements. November 2023. CEC number 400-2 023-0 11. 
The listed documents have been filed in this proceeding’s docket  number 24 -BSTD -01. 
In addition,  upon request,  all documents  are available at the California CEC , located at 
715 P Street, in Sacramento, California.  
STATEMENT OF JUSTIFICATION FOR PRESCRIPTIVE STANDARDS  
The proposed chan ges to the prescriptive standards have, where possible, avoided 
mandating use of specific technologies or equipment, or prescribing the performance of  
 specific actions or procedures. The prescriptive standards are generally performance -
based efficiency metrics. However, the Energy Code includes both a prescriptive option, 
allowing builders to comply by using methods known to be efficient, and a performan ce 
option, allowing builders more freedom in their designs , provided the building achieves 
the same overall efficiency as an equivalent building using the prescriptive option.   
 
CONSIDERATION OF REASONABLE ALTERNATIVES, INCLUDING THOSE THAT 
WOULD LESSEN ANY ADVERSE IMPACT ON SMALL BUSINESS  
Since 1975, legislative enactments and state energy policies have directed the CEC to 
adopt cost -effective building standards to conserve energy and improve energy 
efficiency and thereby improve the state’s economy, energy security, and environment. 
The CE C has been presented with and has considered multiple alternatives to the 
proposed standards; however, at this time no reasonable alternatives to the proposed 
regulations have been proposed that would lessen any adverse impact on small 
businesses or that w ould be less burdensome and equally effective in achieving the 
purposes of the regulation in a manner that achieves the purposes of the statute being 
implemented.  
 
During the initial, informal stage of the rulemaking process, the CEC  conducted an 
extensive pre -rulemaking public process – including eleven (11) public workshops – 
where it considered many suggestions from numerous stakeholders about (1) 
alternatives that could improve the feasibility of the CEC’s  preliminary versions of the 
proposed regulations or could reduce their adverse impacts; (2) the technical and cost -
effectiveness analyses of those preliminary proposals; and (3) the language in those 
proposals. Based on the comments received and the aforementioned robust public 
process , the CEC developed and published preliminary rulemaking code language.  
  
FACTS, EVIDENCE, DOCUMENTS, TESTIMONY, OR OTHER EVIDENCE OF NO 
SIGNIFICANT ADVERSE IMPACT ON BUSINESS  
The CEC has made an initial determination that the proposed regulations are unlikely to 
have a statewide adverse economic impact directly affecting business, including the 
ability of California businesses to compete with businesses in other states. Despite  
minor competitive impacts to California businesses in the short term, the long -term 
benefits of the proposed regulations will not disadvantage California businesses from 
competing with businesses in other states.  
 
On the contrary, California's Energy Code is part of the California Building Standards 
Code and therefore impact  nearly all newly constructed buildings, as well as to specific 
additions and alterations to nearly all existing buildings. Therefore, the Energy Code 
may eventually impact all business in the state that own buildings. While there are initial 
up-front cost s imposed by the Energy Code, there are significantly more lifetime savings 
to residents and businesses across the state who will experience low er energy costs 
and lower overall costs of ownership.  
  
 There are long -term savings that typically more than compensate for initial upfront costs 
by a significantly positive ratio. Past changes to the Energy Code continue to generate 
benefits. More simply, the Energy Code helps create long -term economic growth and 
stability by increasing the disposable income of Californians and California businesses 
in the longer term. These long -term benefits far outweigh the initial upfront costs and, 
therefore, California businesses are not disadvantaged in competing with bu sinesses 
from other states by these regulations. Since the 1970s, California has maintained a 
deep history of progressive environmental and energy regulations that also save 
consumers money.  Additional facts, data, and evidence supporting this initial 
determination are included in the CEC’s Economic and Fiscal Analysis (STD. 399) and 
in the rulemaking docket . 
 
ASSESSMENT OF EFFECT OF REGULATIONS UPON JOBS AND BUSINESS 
EXPANSION, ELIMINATION OR CREATION  
The CEC has assessed whether and to what extent this proposal will affect the 
following:  
 
A. The creation or elimination of jobs within the State of California.  
The CEC has made the initial determination that the proposed regulations for the 2025 
Energy Code will result in an estimated 6,215 jobs created and 18 jobs eliminated. Jobs 
created and eliminated estimates were developed with support from Evergreen 
Economi cs using IMPLAN modeling software.  The IMPLAN model provides a relatively 
simple representation of the California economy’ however, it is important to understand 
that the IMPLAN model simplifies the extremely complex actions and interactions of 
individua l, businesses, and other organizations as they respond to changes in energy 
efficiency codes. The estimated jobs eliminated are the result of a proposed measure 
that will increase central water heating pipe efficiency requirements in newly 
constructed mult ifamily buildings, which will result in increased costs for builders. This 
measure results in incremental costs and thereby decreases discretionary income. 
Therefore, the CEC concludes that the proposal may result in both jobs created and 
eliminated in Cal ifornia.  
 
B. The creation of new businesses or the elimination of existing businesses 
within the State of California.  
 California's Energy Code is part of the California Building Standards Code and 
therefore impacts nearly all newly constructed buildings, as well as specific additions 
and alterations to existing buildings. As a result, the 2025 Energy Code is expected to 
eventually impact all businesses in the state that own buildings. While there are initial 
up-front costs imposed by the Energy Code, there are significantly more lifetime savings 
to residents and businesses across the state who will experience lower energy  costs 
and lower overall costs of ownership. The Energy Code helps create long -term 
economic growth and stability by increasing the disposable income of Californians and 
California businesses in the longer term making it possible that new businesses may be  
created to provide compliance services and to supply energy efficient products.  
 Therefore, the CEC concludes that the proposal may create some additional business 
and is unlikely to eliminate existing businesses within the state of California. Given the 
uncertainty, and the many unknown variables in making these projections, the CEC i s 
conservatively assuming there will be no additional businesses created.  
 
C. The expansion of businesses currently doing business within the State of 
California.  
California businesses producing energy efficient products and technology that meet or 
exceed the proposed Standards are likely to expand their sales of those products and 
technologies due to the implementation of these proposed Standards. Therefore, the 
CEC concludes that businesses currently doing business in California to provide 
energy -efficient products and services may be expanded.  
 
D. The benefits of the regulation to the health and welfare of California residents, 
worker safety, and the state’s environment .  
 Beyond the monetary benefits, the CEC estimates that the implementation of the 2025 
Energy Code updates will reduce anticipated increases in statewide annual electricity 
demand. This will, in turn, result in a net reduction in the emissions of greenhouse 
gases, nitrous oxide, sulfur oxides, carbon monoxide, and particulate matter attributable 
to electricity generation and on -site combustion. Improved air quality as a result of 
reduced emissions will result in health benefits to Californians and help mitiga te costs 
related to health and other issues associated with climate change. The reduction in 
statewide electricity demand will also marginally decrease water consumption in the 
electricity generation sector.  
 
The proposed regulations will not adversely affect the health and welfare of California 
residents, worker safety, or the state’s environment.  
 
ESTIMATED COST OF COMPLIANCE, ESTIMATED POTENTIAL BENEFITS, AND 
RELATED ASSUMPTIONS USED FOR BUILDING STANDARDS  
Due to the complexity of the analysis, refer to the Economic and Fiscal Impact 
Statement (STD. 399) for the estimated cost of compliance, estimated potential 
benefits, and related assumptions used for building standards found on the CEC 
website at: https://www.energy.ca.gov/programs -and-topics/programs/building -energy -
efficiency -standards/2025 -building -energy -efficiency . 
 
DUPLICATION OR CONFLICTS WITH FEDERAL REGULATIONS  
These proposed regulations do not duplicate or conflict with any federal regulations 
contained in the Code of Federal Regulations.  
 
FOR FURTHER INFORMATION  
Please direct general inquiries concerning aspects of the rulemaking process to:  
 
Corrine Fishman , MA 
Regulations Manager  Efficiency Division   
 corrine.fishman@energy.ca.gov   
 
Specific questions regarding the substantive and/or technical aspects of the proposed 
changes to the building standards should be addressed to:  
 
Payam Bozorgchami, PE  
Senior Civil Engineer  
Building Standards Branch  
payam.bozorgchami@energy.ca.gov  
  
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