APPROVAL OF AN ALTERNATIVE PROCEDURE FOR RELOCATABLE PUBLIC SCHOOL BUILDINGS IN THE 2025 ENERGY CODE

The California Energy Commission (CEC) adopts and regularly updates regulations for new construction, additions, and alterations to residential and nonresidential buildings, which are contained in California Code of Regulations, Parts 1 and 6 (the California Energy Code). These regulations go through an extensive public process and are adopted at a CEC business meeting before going into effect. Part 1 of the Energy Code includes administrative regulations for implementation. In certain circumstances, interested parties or the CEC may identify alternative procedures that meet the minimum requirements of the Energy Code, but that require additional regulatory action to ensure compliance and consistency with the Energy Code. In these situations, section 10-109(h) of the 2025 Energy Code states that “In addition to the procedures and protocols identified in Sections 10-109(c), 10-116 and the Reference Appendices, the Commission may authorize alternative procedures that demonstrate compliance with Part 6.” The 2025 Energy Code defines a relocatable public school building as “a relocatable building as defined by Title 24, Part 1, Section 4-314, which is subject to Title 24, Part 1, Chapter 4, Group 1”. On November 12, 2025, the Division of the State Architect (DSA) in accordance with California Education Code Sections 17310 and 81142 published Procedure PR 18-02 that introduced an alternative procedure for demonstrating compliance with the 2025 Energy Code for relocatable public school buildings. The approach allows relocatable public school building designs analyzed using the performance compliance approach to be evaluated for the four cardinal azimuths and introduced the climate zone group method as an acceptable alternate method of compliance. In keeping with the CEC mission to maintain accurate and technically feasible compliance procedures, CEC staff proposed an additional alternative procedure to the Nonresidential Appendix NA4 “Compliance Procedures for Relocatable Public School Buildings” specification of the 2025 Energy Code to align with the alternative compliance approach allowed by DSA, using representative climate zones to demonstrate compliance for specified climate zone groups, and rotating the relocatable public school building through the cardinal azimuths of 0, 90, 180, and 270 degrees to demonstrate compliance. On May 4, 2026, the CEC provided a copy of the proposed alternative procedure to interested parties, and accepted comments through June 11, 2026. No comments were received. CEC staff analyzed the proposed alternative procedure for demonstrating compliance and determined that it is technically feasible and effective at reducing the building energy budget to save at least as much energy as currently approved 2025 Energy Code compliance approaches. CEC staff and the Executive Director recommended the CEC approve the additional alternative procedure to the Nonresidential Appendix NA4 “Compliance Procedures for Relocatable Public School Buildings” specification of the 2025 Energy Code, consistent with Section 10-109(h). CEC staff and the Executive Director further recommended incorporating this alternative procedure in the California Building Energy Code Compliance software (CBECC), which is a CEC-approved software for demonstrating performance compliance with the nonresidential provisions of the 2025 Energy Code. The alternative procedure for relocatable public school buildings was approved at the CEC’s July 8, 2026 Business Meeting.