HomeMy WebLinkAbout2A Public CommentAnthony Mejia
From:
Sent:
To:
Subject:
Clarissa Smith <clarissasmith402@gmail.com>
Thursday, July 22, 2021 3:58 PM
City Clerk
Kings Garden
NOTICE: This message originated outside of The City of Palm Springs --DO NOT CLICK on links or open attachments unless you are
sure the content is safe.
I'm a community member writing in about Kings Garden. I have been made aware of a website that has allegations
against the company and its Ceo and I believe the community will be well served to hear from the company about
whether these allegations are true, especially prior to making access to a major expansion for the company. The website
is www.kingsgardenshareholders.com
Thank you
1
, l-z1.1/Z1Jz,I
ITEM No. QJq-Pub~·c
~
Anthony Mejia
From:
Sent:
To:
Cc:
Kathleen Weremiuk <kathy.weremiuk@icloud.com>
Tuesday, July 6, 2021 4:36 PM
Geoff Kors; Christy Holstege; Lisa Middleton; Dennis Woods; Grace Garner
Flinn Fagg; David Newell; Anthony Mejia; Justin Clifton
Subject: Fwd: Indoor Cannabis Farms
Attachments: 2022 Energy Code CEH provisions summary.pdf; 2022 Energy Code CEH provisions.pdf;
2022 Energy Code solar+ storage provisions summary.pdf; SECTION 140.10 -
PRESCRIPTIVE REQUIREMENTS FOR PHOTOVOLTAIC AND BATTERY STORAGE
SYSTEMS.pdf
NOTICE: This message originated outside of The City of Palm Springs --DO NOT CLICK on links or open attachments unless you are
sure the content is safe.
Anthony, please share this with the city council and city attorney regarding the Kings Garden project appeal.
Best, kathy Weremiuk
Chair of the Palm Springs Planning Commission
Sent from my iPhone
Begin forwarded message:
From: Kathleen Weremiuk <kathy.weremiuk@icloud.com>
Date: July 6, 2021 at 4:19:11 PM PDT
To: flinn.fagg@palmspringsca.gov
Subject: Fwd: Indoor Cannabis Farms
Please share this with the planning commission
Sent from my iPhone
Begin forwarded message:
From: Kathleen Weremiuk <kathy.weremiuk@icloud.com>
Date: July 6, 2021 at 4:18:08 PM PDT
To: Grace Garner <grace.garner@gmail.com>
Subject: Fwd: Indoor Cannabis Farms
Sent from my iPhone
Begin forwarded message:
From: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Date: July 6, 2021 at 3:31:56 PM PDT
To: kathy.weremiuk@icloud.com
Subject: FW: Indoor Cannabis Farms
1
7/22/202-1
ITEM NO. 211 'PufOI. If OJ#!hlKtf
Hi Kathy,
I'm forwarding FYI the email I just sent David Newell and Veronica
Goedhart, based on a clarification I received this morning from the
California Energy Commission on the 2022 California Energy Code
provisions applicable to indoor cannabis farms. Because the state
regulates their energy use, the City has a limited ability to do so
independently.
I will be attending the General Plan Update workshop next Tuesday
evening at the Convention Center and would be happy to chat with you
and David on this issue afterwards if you think that would be helpful.
Best,
David
David Freedman
Member, Palm Springs Sustainability Commission
Email. David.Freedman-ABM@palmsprinqsca.gov
Home: (760) 832 8268
Cell: (347) 634 2723
From: David Freedman
Sent: Tuesday, July 6, 2021 3:13 PM
To: Veronica Goedhart <Veronica.Goedhart@palmspringsca.gov>; David
Newell <David.Newell@palmspringsca.gov>
Cc: Patrick Tallarico <Patrick.Tallarico@palmspringsca.gov>; Tracy
Sheldon <Tracy.Sheldon@palmspringsca.gov>
Subject: FW: Indoor Cannabis Farms
Hi Veronica and David,
As Patrick is taking a well-deserved break this week, I am forwarding my
email exchange with the California Energy Commission (CEC) clarifying
provisions of the 2022 California Energy Code effective January 1, 2023,
applicable to building permits pulled after that date. This clarification
modifies what I had indicated to Patrick in my June 25 email to him, so I
wanted you to have the latest information right away.
The 2022 Code will have new requirements for controlled environment
horticulture (CEH) spaces, such as indoor cannabis grow facilities.
These include indoor lighting, greenhouse envelopes and
dehumidification. Reuse of dehumidification water will be a voluntary
measure and will not be required by the 2022 Code.
The CEC clarified that these CEH space requirements are separate and
distinct from the 2022 Code requirements for solar + battery storage
systems applicable to various commercial buildings, including
warehouses. The solar + storage requirements will apply to cannabis
warehouses if the warehouse constitutes at least 80 percent of the floor
area of the building .
Applying the 2022 Energy Code requirements to the cannabis facility
approved by the Planning Commission at its June 23 meeting and
2
assuming its building permits were pulled after January 1, 2023, when
the 2022 Code enters into effect, the indoor grow areas of the two new
87,120 square feet buildings will need to comply with the CEH
provisions. The new warehouse will NOT need to have solar + storage
because the PV system size of 3.277 kilowatts as per Table 140.10-A
(5,650 square feet x 0.58 watts per square foot of conditioned floor area)
is less than the minimum size of 4 kilowatts as per Exception 2 to
Section 140.10.
The net result is that the 2022 Energy Code will not require solar
systems for cannabis indoor grow facilities, although they will have to
follow the CEH rules. The solar and battery storage systems will only
apply to cannabis warehouses having at least 6,900 square feet of
conditioned floor area (4,000 I 0.58). Although City Council could impose
stricter rules than the 2022 Energy Code, that would require a cost-
effectiveness study and CEC prior approval. The easier approach for
Council would be to impose a requirement that the indoor grow facilities
are powered by carbon-free electricity from their selected electricity
provider. As that requirement does not affect the building energy use but
only its source, it would not require CEC approval.
I am attaching the relevant 2022 Energy Code draft texts and summaries
from a CEC workshop in late May. I've sent them before but wanted you
to have everything together.
Best,
David
David Freedman
Member, Palm Springs Sustainability Commission
Email. David.Freedman-ABM@palmsprinqsca.gov
Home: (760) 832 8268
Cell: (347) 634 2723
From: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>
Sent: Tuesday, July 6, 20211:15 PM
To: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Cc: Perez, Javier@Energy <Javier.Perez@energy.ca.gov>; Drozdowicz,
Danuta@Energy <danuta.drozdowicz@energy.ca.gov>; Patrick Tallarico
<Patrick.Tallarico@palmspringsca.gov>; Strait, Peter@Energy
<Peter.Strait@energy.ca.gov>; Tracy Sheldon
<Tracy.Sheldon@palmspringsca.gov>; Bozorgchami, Payam@Energy
<Payam.Bozorgchami@energy.ca.gov>
Subject: RE: Indoor Cannabis Farms
NOTICE: This message originated outside of The City of Palm Springs --DO NOT
CLICK on links or open attachments unless you are sure the content is safe.
Hi David,
3
The answer to your question has a little history behind. When we
started out with CEH measure, we did include the requirement to reuse
transpired water for irrigation. Through stakeholder process and
outreach, it was clear to the CASE team that this requirement is more
suited as a CalGreen measure than a mandatory measure in Part 6.
Since this will be the first time we regulate CEH spaces with cannabis
grows included, we want to be cautious of the stakeholders' concerns
and want to make sure that our regulations do not unexpectedly
discourage the cannabis community to enter the legal market.
Additionally, it is not uncommon for the CEC to add a measure in Part
11 to get the market ready then move such measure in a later code
cycle into Part 6.
Hope that answers your question!
Thao
From: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Sent: Tuesday, July 6, 202112:17 PM
To: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>
Cc: Perez, Javier@Energy <Javier.Perez@energy.ca.gov>; Drozdowicz,
Danuta@Energy <danuta.drozdowicz@energy.ca.gov>; Patrick Tallarico
<Patrick.Ta Ila rico@pa lmspringsca .gov>; Tracy Sheldon
<Tracy.Sheldon@palmspringsca.gov>
Subject: RE: Indoor Cannabis Farms
CAUTION: This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the
content is safe.
Hello Thao,
Many thanks for the clarification that a CEH space is subject to Section
120.6(h) and is separate from a warehouse subject to Section, 140.10.
I have another CEH question for you. In the CASE report accompanying
the draft CalGreen voluntary measures the CEC posted this past Friday,
the CASE team proposed a number of CEH standards. Most of them are
included in Section 120.6(h), but I did not see the requirement proposed
by the CASE team that dehumidification equipment shall have the
capability to reuse transpired water for irrigation.
Is there any reason why this provision was not included in Section
1206.6(h)? A cannabis industry sustainability report says that for indoor
growing operations, HVAC condensate and dehumidification water may
be suitable for recycling and reuse.
Best,
David
David Freedman
Member, Palm Springs Sustainability Commission
Email. David.Freedman-ABM@palmsprinqsca.gov
4
Home: (760) 832 8268
Cell: (347) 634 2723
From: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>
Sent: Tuesday, July 6, 202111:49 AM
To: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Cc: Perez, Javier@Energy <Javier.Perez@energy.ca.gov>; Drozdowicz,
Danuta@Energy <danuta.drozdowicz@energy.ca.gov>; Patrick Tallarico
<Patrick.Ta I la rico@pa lmspri ngsca .gov>; Tracy Sheldon
<Tracy.Sheldon@palmspringsca.gov>
Subject: RE: Indoor Cannabis Farms
NOTICE: This message originated outside of The City of Palm Springs --DO NOT
CLICK on links or open attachments unless you are sure the content is safe.
Good morning, David!
For a large cannabis warehouse, the solar and battery storage
requirements apply. In fact, they do not apply in general for any CEH
facilities. Under 2022 language, CEH spaces are now separated from
other warehouses and specified as processed spaces.
Best regards,
Thao
From: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Sent: Thursday, July 1, 2021 4:16 PM
To: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>
Cc: Perez, Javier@Energy <Javier.Perez@energy.ca.gov>; Drozdowicz,
Danuta@Energy <danuta.drozdowicz@energy.ca.gov>; Patrick Tallarico
<Patrick. Ta Ila rico@pa lmspri ngsca .gov>; Tracy Sheldon
<Tracy .Sheldon@palmspringsca.gov>
Subject: RE: Indoor Cannabis Farms
CAUTION: This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the
content is safe.
Hi Thao,
Many thanks for agreeing to speak at our Sustainable Cannabis Facility
Forum next month early September. I'm waiting to hear back from City
staff on their availability for a call in the next week or so.
My question on the CEH and solar + storage measures is specifically
linked to cannabis facilities, based on input from our Planning
Commission, which recently approved two very large indoor cannabis
grow facilities but had sustainability concerns. In the definition of indoor
growing in the 2022 Title 24 Part 1 45-day language, it states that
growing plants in a warehouse with or without skylights is an example of
indoor growing. I wasn't sure if in this case the CEH space provisions of
5
Section 120.6(h) and the solar+ storage rules applicable to warehouses
in Section 140.10 would both apply, assuming the building has a Skylight
Roof Ratio less than 50 percent..
Best,
David
David Freedman
Member, Palm Springs Sustainability Commission
Email. David.Freedman-ABM@palmsprinqsca.gov
Home: (760) 832 8268
Cell: (347) 634 2723
From: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>
Sent: Thursday, July 1, 20211:39 PM
To: David Freedman <David.Freedman-ABM@palmspringsca.gov>;
Drozdowicz, Danuta@Energy <danuta.drozdowicz@energy.ca.gov>
Cc: Perez, Javier@Energy <Javier.Perez@energy.ca.gov>; Patrick
Tallarico <Patrick.Tallarico@palmspringsca.gov>; Tracy Sheldon
<Tracy.Sheldon@palmspringsca.gov>
Subject: RE: Indoor Cannabis Farms
NOTICE: This message originated outside of The City of Palm Springs --DO NOT
CLICK on links or open attachments unless you are sure the content is safe.
Thank you Danuta for looping me in.
Hi David,
I am happy to speak at the Forum in regarding to the CEH measure.
Danny Tam is our subject matter expert on the solar+ storage
measures. If your questions regarding these two measures relate to
cannabis facilities, I can address them. Perhaps a call next week is good
to go over more details of the Forum and address any concerns you
might have. Please let me know if you would just rather email instead of
a meeting.
Best regards,
Thao
From: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Sent: Thursday, July 1, 20211:34 PM
To: Drozdowicz, Danuta@Energy <danuta.drozdowicz@energy.ca.gov>
Cc: Chau, Thao@Energy <Thao.Chau@energy.ca.gov>; Perez,
Javier@Energy <Javier.Perez@energy.ca.gov>; Patrick Tallarico
<Patrick.Tallarico@palmspringsca.gov>; Tracy Sheldon
<Tracy.Sheldon@palmspringsca.gov>
Subject: RE: Indoor Cannabis Farms
6
CAUTION: This email originated from outside of the organization. Do not click
links or open attachments unless you recognize the sender and know the
content is safe.
Hello Danuta,
Many thanks for your encouragement of the research I am doing with
Misti as well as Eric Engelman on a possible residential retrofit reach
code for Palm Springs, largely following the Chula Vista and Piedmont
models. I will be watching the LGSEC Webinar on the Chula Vista
EHESO that begins at 2.
Thank you as well to the introduction to Thao, as I was not aware the
CEC Building Standards Office has a point person on Energy Code
provisions for cannabis facilities
As I mentioned in the email I sent yesterday to Javier (who kindly spoke
at a 2019 Energy Code seminar the Palm Springs Office of Sustainability
co-sponsored in October 2019), the Office of Sustainability is planning a
virtual Sustainable Cannabis Facility Forum for mid-to late August or
early September. I have been following the CEC's 2022 Energy Code
proceedings closely and have suggested that someone from the CEC
could speak at the Forum to present the Code's new provisions on
controlled environment horticultural (CEH) spaces under Section
120.6(h), along the lines of the slides from the May 24 Lead
Commissioner Workshop.
The speaker could also address the solar + storage requirements for
warehouses under Code Section 140.10, if applicable. Warehouse is not
separately defined in Part 1 of the 2022 Code 45-day language, and it
wasn't clear from the text of Section 140.10 whether a warehouse that is
also a CEH space would need to comply with both Section 120.6(h) and
Section 140.10, or whether those provisions are mutually exclusive. If
Thao already has the answer to that question, it would be helpful to know
as we put together the topics to be covered in the Forum.
Best,
David
David Freedman
Member, Palm Springs Sustainability Commission
Email. David.Freedman-ABM@palmsprinqsca.gov
Home: (760) 832 8268
Cell: (347) 634 2723
From: Drozdowicz, Danuta@Energy
<danuta.drozdowicz@energy.ca.gov>
Sent: Thursday, July 1, 20211:12 PM
To: David Freedman <David.Freedman-ABM@palmspringsca.gov>
Cc: Chau, Thao@Energy <Thao.Chau@energy.ca .gov>; Perez,
Javier@Energy <Javier.Perez@energy.ca.gov>
Subject: Indoor Cannabis Farms
7
NOTICE: This message originated outside ofThe City of Palm Springs --DO NOT
CLICK on links or open attachments unless you are sure the content is safe.
Good Afternoon David,
Good to hear you on the Reach Code call this morning!
You mentioned that you've been in touch with Javier Perez regarding
cannabis farms in your jurisdiction.
I am writing to introduce you, if you have not met already, to Thao
Chau.
She is the CEC Building Standards Office point person on energy code
provisions for cannabis facilities, and a fantastic resource.
Also good to hear that you will be working with Misti evaluating
efficiency measures for retrofits.
I look forward to hearing more about that work as it progresses.
My best regards,
Danuta
Danuta Drozdowicz, LEED AP, WELL AP
Energy Specialist
Efficiency Division
California Energy Commission
1516 9th Street, MS 37
Sacramento, CA 95814
916.805.7436
8
Section: 120.&(h) -Mandatory Requirements for
Controlled Environment Horticulture (CEH)
Spaces
• Added new mandatory requirements for controlled environment horticulture
spaces including dehumidification, lighting, electrical power distribution systems,
and condition greenhouses.
• Section 120.6(h)1 Indoor Growing, Dehumidification
Stand-alone dehumidifiers
o Volumes s 8.0 cubic feet: min integrated energy factor of 1. 77 L/kWh
o Volumes> 8.0 cubic feet: min integrated energy factor of 2.41 L/kWh
o Integrated HVAC system with on-site heat recovery to fulfill ~ 75
percent of the annual energy for dehumidification reheat;
o Chilled water system with on-site heat recovery to fulfill~ 75 percent
of the annual energy for dehumidification reheat; or
o Solid or liquid desiccant dehumidification system for system designs s
50°F dewpoint.
Section: 120.&(h) -Mandatory Requirements for
Controlled Environment Horticulture (CEH)
Spaces
• Section 120.6(h)2 -Indoor Growing, Horticulture Lighting
• For newly constructed indoor facilities with 40 kW of horticultural
lighting:
o Luminaires with removable lamps: Photosynthetic Photon Efficacy
(PPE) > 1.9 µmol/J for the lamps
o Luminaires with non-removable lamps: Photosynthetic Photon
Efficacy (PPE) > 1.9 µmol/J for the luminaires
• Section 120.6(h)3 -Indoor Growing, Electrical Power Distribution
Systems
• Electrical power distributions shall be capable of monitoring usage from
a measurement device.
Section: 120.6 -Mandatory
Requirements for Covered Processes
• Section 120.6(h)4-Conditioned Greenhouse, Building Envelopes
• Greenhouses will have specific requirements for skylights and windows
applicable for their use instead of the current warehouse requirements.
• LI-factor of 0.7 or less is the new requirement.
• Section 120.6(h)6 -Greenhouse, Horticulture Lighting
For newly constructed greenhouses with 40 kW of horticultural lighting
• Luminaires with removable lamps: Photosynthetic Photon Efficacy
(PPE) > 1.7 µmol/J for the lamps
• Luminaires with non-removable lamps: Photosynthetic Photon Efficacy
(PPE) > 1.7 µmol/J for the luminaires
Page 198 2022 Building Energy Efficiency Standards
EXCEPTION to Section 120.6(f): Elevators located in healthcare facilities.
(g) Mandatory Requirements for Escalators and Moving Walkways
1. Escalators and moving walkways located in airports, hotels, and transportation function areas shall
automatically slow to the minimum permitted speed in accordance with ASME A17.1/CSA B44 when not
conveying passengers.
2. Escalators and Moving Walkways Acceptance. Before an occupancy permit is granted for escalators and
moving walkways subject to 120.G(g), the following equipment and systems shall be certified as meeting
the Acceptance Requirement for Code Compliance, as specified by the Reference Nonresidential Appendix
NA7. A Certificate of Acceptance shall be submitted to the enforcement agency that certifies that the
equipment and systems meet the acceptance requirements specified in NA7.15.
(h) Mandatory Requirements for Controlled Environment Horticulture (CEH) Spaces
1. Indoor Growing. Dehumidification. Dehumidification equipment shall be one of the following:
A. Stand-alone dehumidifiers that meet the following minimum integrated energy factors as measured
by the test conditions in Appendix Xl to Subpart B of 10 CFR Part 430:
i. Minimum integrated energy factor of 1.77 L/kWh for product case volumes of 8.0 cubic feet or
less:
ii. Minimum integrated energy factor of 2.41 L/kWh for product case volumes greater than 8.0 cubic
feet:
B. Integrated HVAC system with on-site heat recovery designed to fulfill at least 75 percent of the annual
energy for dehumidification reheat:
C. Chilled water system with on-site heat recovery designed to fulfill at least 75 percent of the annual
energy for dehumidification reheat: or
D. Solid or liquid desiccant dehumidification system for system designs that require dewpoint of S0°F or
less.
2. Indoor Growing. Horticultural Lighting. In a building with CEH spaces and with more than 40 kW of
aggregate horticultural lighting load. the electric lighting systems used for plant growth and plant
maintenance shall meet the all of the following requirements:
A. The horticultural lighting systems shall have a photosynthetic photon efficacy (PPE) rated in
accordance with ANSI/ASABE S640 for wavelengths from 400 to 700 nanometers and meet one of the
following requirements:
i. Integrated. non-serviceable luminaires shall have a rated PPE of at least 1.9 micromoles per joule:
or
ii. Luminaires with removable or serviceable lamps shall have lamps with a rated PPE of at least 1.9
micromoles per joule.
B. Time-switch lighting controls shall be installed and comply with Section 110.9(b)l. Section 130.4(a)4.
and applicable sections of NA7.6.2.
C. Multilevel lighting controls shall be installed and comply with Section 130.l(b).
3. Indoor Growing. Electrical Power Distribution Systems. Electrical power distribution system serving CEH
spaces shall be designed so that a measurement device is capable of monitoring the electrical energy
usage of aggregate horticultural lighting load.
4. Conditioned Greenhouses. Building Envelope. Conditioned greenhouses shall meet the following
requirements:
A. Opaque wall and opaque roof assembly shall meet the requirements of Section 120.7: and
B. Fenestration products used for greenhouse glazing shall have a U-factor of 0.7 or less.
SECTION 120.6 -MANDA TORY REQUIREMENTS FOR COVERED PROCESSES
2022 Building Energy Efficiency Standards Page 199
5. Conditioned Greenhouses. Space-Conditioning Systems. Space-conditioning systems used for plant
production shall comply with all applicable requirements.
6. Greenhouses. Horticultural Lighting. In a greenhouse with more than 40 kW of aggregate horticultural
lighting load. the electric lighting system used for plant growth and plant maintenance shall meet the
following requirements:
A. The horticultural lighting systems shall have a photosynthetic photon efficacy (PPE) rated in
accordance with ANSI/ASABE S640 for wavelengths from 400 to 700 nanometers and meet one of the
following requirements:
i. Integrated. non-serviceable luminaires shall have a rated PPE of at least 1.7 micromoles per joule:
or
ii. Luminaires with removable or serviceable lamps shall have lamps with a rated PPE of at least 1. 7
micromoles per joule.
B. Time-switch lighting controls shall be installed and comply with Section 110.9(b)l. Section 130.4(a)4.
applicable sections of Reference Nonresidential Appendix NA7.6.2.
C. Multilevel lighting controls shall be installed and comply with Section 130.l(b).
(i) Mandatory Requirements for Steam Traps. Steam traps in new industrial facilities and new steam traps added to
support new. non-replacement. process equipment in existing industrial facilities where the installed steam trap
operating pressure, which is the steam pressure entering the steam trap during normal design operating
conditions, is greater than 15 psig and the total combined connected boiler input rating is greater than 5 Million
Btu/hr, shall meet the following requirements:
1. Central Steam Trap Fault Detection and Diagnostics Monitoring. Steam trap systems shall be equipped with a
central steam trap monitoring system that:
A. Provides a status update of all steam trap fault detection sensors at no greater than 8 hour intervals.
B. Automatically display an alarm that identifies which steam trap has fault once the system has detected a
fault.
b Steam Trap Fault Detection. Steam traps shall be equipped with automatic fault detection sensors that shall
communicate their operational state to the central steam trap monitoring system as described in Section
120.6(i)l.
3. Steam Trap Strainer Installation. Steam traps shall either:
A. Be equipped with an integral strainer and blow-off valve: or
B. Be installed downstream with 3 feet of a strainer and blow-off valve.
4. Steam Trap System Acceptance. Before an occupancy permit is granted for steam trap systems subject to
Section 120.G{i). the equipment and systems shall be certified as meeting the Acceptance Requirement for
Code Compliance, as specified by the Reference Nonresidential Appendix NA7.19. A Certificate of Acceptance
shall be submitted to the enforcement agency that certifies that the equipment and systems meet the
acceptance requirements specified in NA7.19.
EXCEPTION 1 to Section 120.6(i}: Steam traps where steam is diverted to a steam system of lower pressure for use
when the steam trap fails open.
(j) Mandatory Requirements for Computer Rooms. Space conditioning systems serving a computer room shall meet
the following requirements:
1. Reheat. Each computer room zone shall have controls that prevent reheating. recooling and simultaneous
provisions of heating and cooling to the same zone, such as mixing or simultaneous supply of air that has been
previously mechanically heated and air that has been previously cooled. either by cooling equipment or by
economizer systems.
SECTION 120.6 -MANDA TORY REQUIREMENTS FOR COVERED PROCESSES
Prescriptive Require111ents for Photovoltaic
Syste111 and Battery Storage Systems
Presenter: Maziar Shirakh
DATE: May 24, 2021 Lead Commissioner Hearing for 45-Day Language
• Here Con,es the Sun: PV and Battery Storage
Requiren,ents -Current 2019 Standards
31
For the first time, 2019 Standards included prescriptive solar PV systems for lowrise
residential buildings:
• Sized to displace the annual kWhs of a mixed-fuel home, conforming with Net Energy
Metering (NEM) rules ~ 3 kW average size statewide for single family buildings
• Cost effective in all 16 climate zones, even if exports compensated at avoided cost; large
energy bill and CO2 emission savings
Battery storage was an option and could receive compliance credit if paired with a PV system
The 2022 Standards proposes to expand PVs paired with battery storage systems to
multifamily and selected nonresidential buildings
~ I'll Follow the Sun -New PV & Storage Requirements
~ for Multifamily and Nonresidential Buildings
Section 140.10 -Prescriptive Requirements for Photovoltaic and Battery Storage
Systems
New requirements for "lean and mean" solar & storage:
32
i. For high-rise residential four or more habitable stories
ii. Selected nonresidential buildings: Office, Retail, Grocery, School, Warehouse; minimal
requirements (similar to warehouse) for Auditorium, Convention Center, Hotel/Motel,
Library, Medical/Clinic, Restaurant, Theater
(i) New PV & Storage Requirements for Multifamily and
Nonresidential Buildings
"Lean and Mean" PV/Battery Storage Systems:
33
i. Limits hourly exports to 20°/o of PV generation without batteries, 10%
with batteries
ii.Cost effective in most buildings and climate zones even with exports
at avoided cost, likely NEM3 scenario
~ New PV & Storage Requirements for Multifamily and ~ Nonresidential Buildings
Exceptions for:
• Buildings with Solar Access Roof Areas (SARA) less than 3°/o of CFA
• PV sizes less than 4 kW
• Areas of state with high snow loads
• No PV in multi-tenant buildings without either a Virtual Net Metering (VNEM) or
community solar program
• No battery storage in small buildings and tenant lease spaces (<5,000 sf)
• No battery storage for very small system, less than 10 kWh
• No battery storage for offices, schools, and warehouses in climate zone 1
34
~ PV & Storage Requirements -Solar Access Roof Areas ~ (SARA)
Section 140.10(a)2 -SARA
The 2022 Standards introduces SARA concept to determine suitable areas available
for PV installation; SARA
1. Includes building's roof space and the area of all roof space on covered parking
areas, carports, and all other newly constructed structures capable of supporting
PVs
2. Does not include any area that has less than 70 percent annual solar
access. Obstructions that are external to the building casting shade, and
obstructions that are part of the building design and elevation features may
be considered for the annual solar access calculations.
35
(i) Photovoltaics & Storage for Multifamily and
Nonresidential Buildings
• Storage helps manage building electricity demand on the grid
o Provide for demand flexibility to avoid rooftop solar adding power to the grid
during periods of low net load (middle-of-the-day); lower electricity bills
o Contribute to large amount of additional rooftop solar needed to meet SB 100
o Increase the reliability of the grid during very high peak periods
• Reduce CO2 emissions from buildings
• Helps modern buildings be resilient to wildfires and PSPS events
36
Section: 150.1(c)14 -PRESCRIPTIVE
REQUIREMENTS FOR PHOTOVOLTAIC SYSTEMS
• Clarify PV systems are not required to be larger than what can be installed in the available
Solar Access Roof Area (SARA); clarifies what happens when SARA is greater than 80
square feet, but smaller than the area required for full NEM compliance.
• New Exception 2 for PVs systems that are less than 1.9 kWDC per building
• Removal of the following exceptions:
o Exception 2 ( CZlS)
o Exception 3 (2-story buildings)
o Exception 4 (3-story buildings)
37
~ Section: 150.1(c)14 -PRESCRIPTIVE REQUIREMENTS
~ FOR PHOTOVOLTAIC SYSTEMS -CONT.
• New Exception 3 for areas with high snow loads.
• Clarifies occupied roof areas -As specified by Title 24, Part 2, section
503.1.4, are not part of SARA
• Clarifies that for low slope roofs all obstructions external and internal to the
building, including building design features are not part of SARA
• Clarifies Exception 5 for self-shading for high-slope roofs approved by
planning departments prior to 1/1/2020
38
Less En,issions, Cleaner Air
2022 Standards reduce CO2e emissions by significant amounts:
Heatpump Baseline and PV /Battery Annual CO2e Emissions Equivalent Gas Cars
Savings mTons/yr Taken Off the Road
1st year 106,775 23,956
3rd year 318,892 71,546
30th year 2,649,252 594,384
Equivalent Gas Cars
Total 2022 Standards Annual CO2e Emissions Savings mTons/yr Taken Off the Road
1st year 632,873 141,991
l3rd year 1,993,930 447,356
l30th year 10,771,991 2,416,793 39
Page 314 2022 Building Energy Efficiency Standards
SECTION 140.10-PRESCRIPTIVE REQUIREMENTS FOR PHOTOVOLTAIC AND
BATTERY STORAGE SYSTEMS
(a) Photovoltaic Requirements. All newly constructed building types specified in Table 140.10-A, or mixed
occupancy buildings where one or more of these building types constitute at least 80 percent of the floor area
of the building. shall have a photovoltaic (PV) system meeting the minimum qualification requirements of
Reference Joint Appendix JA11. The PV size in kWdc shall be not less than the smaller of the PV system size
determined by Equation 140.10-A, or the total of all available Solar Access Roof Areas (SARA) multiplied by 14
W/ft2 •
1. SARA include the area of the building's roof space capable of structurally supporting a PV system, and the
area of all roof space on covered parking areas, carports, and all other newly constructed structures on the
site that are compatible with supporting a PV system per Title 24, Part 2, Section 1511.2.
2. SARA does NOT include:
A. Any area that has less than 70 percent annual solar access. Annual solar access is determined by
dividing the total annual solar insolation (accounting for shading obstructions) by the total annual
solar insolation if the same areas were unshaded by those obstructions. For all roofs, all obstructions
including those that are external to the building. and obstructions that are part of the building design
and elevation features may be considered for the annual solar access calculations.
B. Occupied roofs as specified by CBC Section 503.1.4.
C. Roof space that is otherwise not available due to compliance with other building code requirements if
confirmed by the Executive Director.
EQUATION 140.10-A PHOTOVOLTAIC DIRECT CURRENT SIZE
kWPVdc = (CFA X Al/1000
WHERE:
kWPvdc = Size of the PV system in kW
CFA = Conditioned floor area in square feet
A= PV capacity factor specified in Table 140.10-A for the building type
Where the building includes more than one of the space types listed in Table 140.10-A. the total PV system
capacity for the building shall be determined by applying Equation 140.10-A to each of the listed space types
and summing the capacities determined for each.
EXCEPTION 1 to Section 140.l0(a). No PV system is required where the total of all available SARA is less than
three percent of the conditioned floor area.
EXCEPTION 2 to Section 140.l0(a). No PV system is required where the required PV system size is less than 4
kWdc,
EXCEPTION 3 to Section 140.l0(a). No PV system is required if the SARA contains less than 80 contiguous
square feet.
SECTION 140.10-PRESCRIPTIVE REQUIREMENTS FOR PHOTOVOLTAIC AND BATTERY STORAGE SYSTEMS
2022 Building Energy Efficiency Standards Page 315
EXCEPTION 4 to Section 140.l0(a). Buildings with enforcement-authority-approved roof designs. where the
enforcement authority determines it is not possible for the PV system. including panels. modules. components.
supports. and attachments to the roof structure. to meet ASCE 7-16. Chapter 7. Snow Loads.
EXCEPTION 5 to Section 140.l0(a). Multi-tenant buildings in areas where a load serving entity does not
provide either a Virtual Net Metering (VNEM) or community solar program.
(b) Battery Storage System Requirements. All buildings that are required by Section 140.l0(a) to have a PV
system shall also have a battery storage system meeting the minimum qualification requirements of Reference
Joint Appendix JA12. The rated energy capacity and the rated power capacity shall be not less than the values
determined by Equation 140.10-B and Equation 140.10-C. Where the building includes more than one of the
space types listed in Table 140.10-B. the total battery system capacity for the building shall be determined by
applying Equations 140.10-B and 140.10-C to each of the listed space types and summing the capacities
determined for each space type and equation.
EXCEPTION 1 to Section 140.l0(b). No battery storage system is required if the installed PV system size is less
than 15 percent of the size determined by Equation 140.10-A.
EXCEPTION 2 to Section 140.l0(b). No battery storage system is required in buildings with battery storage
system requirements with less than 10 kWh rated capacity.
EXCEPTION 3 to Section 140.l0(b). For multi-tenant buildings. the energy capacity and power capacity of the
battery storage system shall be based on the tenant spaces with more than 5,000 square feet of conditioned
floor area. For single-tenant buildings with less than 5,000 square feet of conditioned floor area. no battery
storage system is required.
EXCEPTION 4 to Section 140.l0(b). In climate zone 1. no battery storage system is required for offices. schools.
and warehouses.
EQUATION 140.10-8 -BATTERY STORAGE RATED ENERGY CAPACITY
kWhbatt = kWPVdc X 8 / D0·5
WHERE:
kWhbatt = Rated Useable Energy Capacity of the battery storage system in kWh
kWevdc = PV system capacity required by section 140.l0(a) in kWdc
B = Battery energy capacity factor specified in Table 140.10-B for the building type
D= Rated single charge-discharge cycle AC to AC (round-trip) efficiency of the battery storage system
EQUATION 140.10-C -BATTERY STORAGE RATED POWER CAPACITY
kWbatt = kWPVdc X C
WHERE:
kWbatt = Power capacity of the battery storage system in kWdc
kWPvdc = PV system capacity required by section 140.l0(a) in kWdc
C = Battery power capacity factor specified in Table 140.10-B for the building type
SECTION 140.10-PRESCRIPTIVE REQUIREMENTS FOR PHOTOVOLTAIC AND BATTERY STORAGE SYSTEMS
Page 316 2022 Building Energy Efficiency Standards
Table 140 10-A -PV Caoacitv Factors
Factor A -Minimum PV Ca~aci~ (W lftz of
-conditioned floor area}
Climate Zone 1131 5116 2141 6-14 15
Groce!'.Y 2.62 2.91 3.53
Highrise Multifamil~ 1.82 2.21 2.77
Office, Financial Institutions, Unleased Tenant Sgace 2.59 3.13 3.80
Retail 2.62 2.91 3.53
School 1.27 1.63 2.46
Warehouse 0.39 0.44 0.58
Auditorium, Convention Center, Hotel[Motel 1 Libra!'.Y 1 Medical Office 0.39 0.44 0.58 Building[Clinic1 Restaurant, Theater
Table 140 10-B -Batterv Storaae Caoacitv Factors
Factor B -Ener~ Factor C -Power
-Callacitll Ca~aci~
Storage to PV Ratio WhlW WlW
Groce!'.Y 1.03 0.26
Highrise Multifamil~ 1.03 0.26
Office 1 Financial Institutions, Unleased Tenant Sgace 1.68 0.42
Retail 1.03 0.26
School 1.87 0.46
Warehouse 0.93 0.23
Auditorium 1 Convention Center, Hotel[Motel 1 Libra!'.Y, 0.93 0.23 Medical Office Building[Clinic1 Restaurant 1 Theater
NOTE•: Authority: Sections 25213, 25218, 25218.5, 25402 and 25402.1, Public Resources Code. Reference: Sections
25007, 25008, 25218.5, 25310, 25402, 25402.1, 25402.4, 25402.8, and 25943, Public Resources Code.:.
SECTION 140.10-PRESCRIPTIVE REQUIREMENTS FOR PHOTOVOLTAIC AND BATTERY STORAGE SYSTEMS