Title 24 Unpacked
Engineer explains California’s latest energy code updates
The California Energy Commission’s recent update to the state’s energy code (Building Energy Efficiency Standards (Title 24, Part 6 and 11), known simply as Title 24) went into effect on January 1, 2023. We interviewed Ben Rosenzweig (PE, Vice President and General Manager at CoolSys Energy Design) to understand what these changes mean for new and existing construction.
This interview has been edited for length and clarity.
Can you give us an overview of Title 24?
Ben Rosenzweig: Title 24 is the Building Energy Efficiency Standards in California. It’s a statewide requirement that all the jurisdictions in California must adhere to, and every three years, that code is updated with different efficiency standards, building design and operation requirements. This year, on January 1, 2023, the 2022 Title 24 Building Efficiency Standards went into force. There are a lot of big, sweeping changes that will impact many different people in larger ways than in the past.
And specifically, who does this impact?
BR: The Title 24 changes this year will impact everyone involved in building design, construction operation and maintenance lifecycle. That starts with the developer and project management team that hires the architects and engineers to design the building, the contractors that are going to build it, and the equipment manufacturers that provide the equipment for the building. And ultimately, the owner and operator of the building and the tenants in the building.
Not only has the minimum efficiency requirements for certain pieces and components of equipment and building materials—like air conditioning units and glass for windows—changed, but this year, and for the first time, California does seem to be the tip of the spear for some of the larger changes coming to this country to deal with the global climate crisis and climate change. These include requirements for most new buildings under most occupancy classifications to have operational solar photovoltaic systems: solar panels on the roof to generate electricity and battery energy storage systems.
These are relatively new technologies to commercial and industrial buildings, although they’ve been around for quite some time. In the past, things like the solar photovoltaic requirement were things that needed to have provisions for future installation. For instance, the 2019 version of Title 24 required certain building types to be constructed so solar panels could be added in the future with minimal disruption to the building. Maybe that meant some conduits and piping from the electrical room to the roof and a roof that could withstand solar panels from a structural perspective. But now, contractors and building owners won’t get their certificates of occupancy to open their buildings without these systems installed and operational. They’ll be inspected as part of the final building inspection to open a building. So, these are new features—and they’re major features—but new features of building design and construction that everyone in the state who is building buildings, for the most part, will have to deal with.
Can you expand on solar photovoltaic systems?
BR: Developers, end users, retailers, and operators alike wonder how these changes will affect them. The new guidelines outline what percentage of your roof area needs to be covered in solar panels. It also outlines what size the batteries that store the energy need to be, which will dictate the size and footprint of the equipment.
You may look at your roof and have to lay things out differently than you would’ve prototypically in the past to make room for these solar panels. There are access requirements; people need to service them. So, many different things need to be considered as opposed to just running forward with your prototypical designs.
And it’s important to understand that if the drawings for your building or your major alteration project weren’t submitted to the authority having jurisdiction over your project before January 1, your building will likely be required to comply with these guidelines. For instance, if you designed a building with your architecture and engineering team and completed the design in December, but you’re waiting till this month to submit it, it will likely be subject to these new requirements.
What about battery energy storage systems?
BR: Battery energy storage systems are something homeowners have been putting in their primary residences for a while (think Tesla Power Wall). However, on a commercial scale, the battery energy storage systems will be installed coupled with the solar photovoltaic system to store electrical power for your building that can be used for things like minimizing the demand on the electrical grid during peak times.
All of this will help create a building that requires less energy from the grid and can generate, store and use more energy on its own. Power generated from solar panels has to be used instantaneously when it’s generated. The only way to store it is in batteries. That’s why this requirement is part of the new Title 24 requirements.
What do clients need to know about EV charging stations?
BR: EV charging stations are included in the new title 24 updates. However, they’re not listed in the same section as the other requirements—they’re part of CalGreen, another part of Title 24.
In the past, provisions for future EV stations and other requirements may have been included. Now, for most occupancies, you are required to have a certain percentage of the parking spaces in your parking lot to have operational electric vehicle chargers that meet all requirements.
Depending on the size and type of your building, you may need to have level two electric vehicle chargers, which require more power than a level one charger that someone might have in their home. That’s why your electrical engineer needs to understand these requirements before going into the basic design of your building so that none of these things come up as surprises later on.
What do people need to know about heat pumps?
BR: Electrification is now being implemented as a requirement for air conditioning and heating. Most buildings in most of the climate zones in California (as defined by the regulation) will be required to use heat pumps for air conditioning as opposed to more traditional rooftop units, package rooftop units or split systems that use electricity for cooling and natural gas for heating.
They’re trying to create an electrified building with lower emissions. You won’t be able to burn natural gas in a gas furnace of an air conditioning system. Instead, you’ll be required to use heat pumps, which are highly efficient and a 100% electric means of heating, cooling and ventilation.
What about equipment efficiency standard increases?
BR: Title 24 outlines the minimum efficiency standards for unitary and packaged pieces of equipment. This covers everything from the water heater in your back room or janitor’s closet to the air conditioning equipment and anything else that consumes electricity in the building that might have a nameplate on it and a listed efficiency from the manufacturer.
Engineers, designers and owners don’t really have a say in what the efficiency is of a piece of equipment (like your water heater). However, you will be required to specify, procure and install equipment that meets the new minimum efficiency requirements. Manufacturers are still working to ensure that all of the equipment in their lineup meet these requirements. It’s important that the engineer or architect that’s working on your project understands these requirements so that they can specify equipment that complies with the guidelines.
What are the biggest Title 24 concerns that your clients are expressing to you?
BR: One of the major concerns I’ve encountered with my clients and others in the industry is some of the surprises associated with these developments. For instance, let’s assume you are a retailer with developers building your building. As opposed to owning and operating your building, you end up as the tenant for a landlord. Your real estate group or representative likely negotiated the deal for that project long ago. And at that time, your financial analysis and the way you looked at that project did not include installing solar panels, battery energy storage or electric vehicle chargers.
We’re finding that many of our clients are having hard discussions with the landlord or developer for their projects about who will pay for changes. On one end, the developer may say that they agreed to provide a compliant building at the time they inked the deal. On the other end, the retailer or tenant might see it as an agreement to provide a compliant building, and now they’re ready to build the project, and these are the current requirements.
There’s definitely a discussion to be had about that. It’s important to work with partners, engineers, and architects that understand the efficient ways to meet these requirements to minimize the first cost. But it’s also important for the end-user to understand that many of these changes will lead to a more energy-efficient building. Ultimately, if you’re responsible for the energy bill and you’re going to own and operate that building for 10+ years, there will be a payback associated with the higher cost. So, hopefully, there’s a way to come up with a creative deal.
Another major concern they have is space. We work primarily with mixed-use and food retailers, and square footage is paramount in these buildings, especially on the sales floor. Many of these spaces do not have large back-of-house areas where additional equipment can be placed. Typically, the batteries associated with a battery energy storage system will either go outside the building or inside an electric room. They don’t normally go on the roof. So, you might have an issue if your prototypical layout or fixture plan doesn’t accommodate this equipment, which could require an electrical room 20-50% larger than you currently plan for. If you want to put it outside and the building wasn’t approved for that as new construction, you might need to go back to the city for site planning and other things to ensure it can get approved.
There are a lot of different nuances to this that will require a bit of a different process from the beginning of design to the completion of construction that people need to consider.
What happens if your clients aren’t in compliance?
BR: Because Title 24 is a code requirement in the entire state of California, it’s up to the local authorities to enforce these codes. The state also has an enforcement body, but the local jurisdiction is typically required to enforce these codes during plan review. When your architects and engineers submit their drawings, construction documents and specifications to the city as part of the permit application, the people reviewing those drawings are supposed to catch whether or not they’re compliant with the code.
Ultimately, it’s the registered design professionals’ responsibility to put forth a code-compliant design, so it does fall back on the architect and engineering team. For instance, if a plan reviewer misses a requirement, but later an inspector realizes in the field that it’s not there, the owner will still be liable for meeting that requirement. This could lead to changes to the project design late in the construction process, and everything costs more when you do it as part of a change order in construction as opposed to part of the initial design. Sometimes implementing some of the smaller new requirements doesn’t cost anything extra—it just has to be done right up front.
If a building is constructed without some of these requirements and the inspector notices, it’s going to need to be fixed. If they don’t notice and the building is constructed without conforming to the code, it may come up later. However, this is meant to be something that’s caught by the building officials during the planning and design phase so that it’s remedied before the building is opened.
If your building does not conform to any building or energy code requirement, inspectors have the right to fail your inspection and let you know you need to conform to those codes. It could delay the opening and completion of the construction of your building.
How can CoolSys Energy Design help clients with the new Title 24 rules?
BR: Coolness Energy Design prides itself on being at the cutting edge of technology, innovation, regulatory requirements, and other things of that nature. It’s really important for end users, developers and general contractors, to understand that you have to hire a competent architectural and engineering design team. Usually, it’s two different firms—like ours—that understand the code requirements in the location of your project so that it’s designed the right way the first time and efficiently. Some of these new requirements include very expensive, intricate equipment like solar panels and battery energy storage systems.
You want to make sure you have a competent engineer, especially an electrical engineer in this case, that knows how to integrate those types of systems in a code-compliant manner into the type of building you’re trying to build, operate, or open. CED is here to educate you on the code requirements and help you understand what you might need to change about your prototypical building designs to be compliant.
If you’re the type of building owner, retailer or end user that’s interested in going above and beyond what the code requires to provide the most cost-efficient building you can, we are here to help you build upon these minimum efficiency requirements to ensure that you have a building that’s going to cost you less to operate, making your business more profitable.
What’s your advice in navigating this for anyone planning new construction or remodels?
BR: My advice is not to look at these code requirements through a small lens, but to think big picture. The entire world is moving into a phase of decarbonization, reduced operational and embodied carbon building designs and construction. If governments have their say in the matter, regulatory pressures are going to eventually push people into building these types of buildings everywhere.
And if you want to be a good corporate and global citizen, you can build upon these minimum requirements with an engineering team like ours and come up with a sound, efficient building design that you can implement across your entire portfolio of buildings. You can get ahead of the curve from that regulatory pressure perspective and you won’t be surprised or have to worry about it.
I hear a lot of national clients I’ve worked with say they’re tired of chasing a moving target. This has come up a lot with refrigerant and emissions regulations and energy code requirements. If you’re working with a national engineering firm like ours that understands where the country is going, we can help you take these written code requirements and turn them into designed buildings that meet the aesthetic and operational requirements of your business in a way that will help you be a much more profitable company.
In your opinion, how will these new rules impact other states?
BR: The Title 24 Building Efficiency Standards are just limited to being enforced in California. There really isn’t a sweeping federal energy code in the United States. However, most states either comply with a direct or modified version of either the Ashrae 90.1 Energy Standard or the International Energy Conservation Code.
These get adopted every few years based on a code adoption cycle in every state, and then their jurisdictions have to comply as well. I fully expect all of these codes to be updated with very similar requirements and these things to be required across the country sooner rather than later. Therefore, I do think it’s well worth it for people to look at these projects they’re building in California, not as one off, but as opportunities to try different things and think about how that this type of project building or system can be integrated into an overall national portfolio.