California’s Statewide Codes & Standards Enhancement (CASE) Team would like to highlight the definitions used for controlled environment horticulture (CEH) building type in Title 24, Part 6, in contrast to CalCannabis license type definitions. They are interested in feedback on any potential clarifications that would be helpful in the compliance manual.

Background
The California Energy Code (Title 24, Part 6) requirements for controlled environment horticulture (CEH) greenhouses and indoor growing spaces apply to all buildings spaces that “are dedicated to plant production by manipulating indoor environmental conditions, such as through electric lighting, mechanical heating, mechanical cooling, or dehumidification.” The Title 24, part 6 requirements apply to all types of crop grown in these spaces.

Title 24, part 6 defines a CEH indoor growing space as having a skylight area to roof area ratio less than 50%. A CEH greenhouse has a skylight area to roof area ratio of 50% or greater. Thus, the Title 24 definitions of greenhouse and indoor growing space are solely determined by the fraction of roof area that has glazing and is not affected by how much electric lighting is used in the space.

CalCannabis (operated by the Department of Cannabis Control) grants licenses for cannabis growing. Different types of licenses are based on factors such as lighting density and light deprivation. CalCannabis defines Indoor Cultivation as “Cultivation of cannabis within a permanent structure using artificial light exclusively, or within any type of structure using artificial light at a rate above 25 watts per square foot.” Therefore, a CalCannabis indoor cultivation license applies to indoor spaces with no skylights and any space, even greenhouses, with more than 25 Watts of electric lighting per square foot of growing area. A CalCannabis mixed-light cultivation license makes use of some amount of sunlight and must have no more than 25 Watts of electric lighting power installed per square foot of growing area. Thus, the CalCannabis definitions of “indoor growing” and “mixed-light” for licensure are not equivalent to the “indoor growing” and “conditioned greenhouse” definitions used for obtaining building permits under Title 24, Part 6.

How to respond:

If you have suggestions to help ensure building type definitions for CEH measures are clear and distinct from CalCAnnabis license type definitions, please respond to info@title24stakeholders.com by September 15, 2021.

Specific questions for feedback:

  1.   Do you find these clarifications helpful to distinguish different facility definitions from Title 24, Part 6 and CalCannabis?
  2.   Are there any changes to the compliance manual that you think would help clarify the new requirements?