Maintaining the Machine: What California’s Energy Code Cycles Teach Us About Progress
At A2 Efficiency, we take complexity as an invitation to dig deeper, simplify, and make sure everyone truly understands. California’s building energy code, as the subject of investigation, is always a topic of conversation. While there are always new pages to the story, even recent twists with Assembly Bill 130 pausing advancement on residential dwelling units for a code cycle, the process and complexities of keeping the process working are something we find helpful to address.
With the 2025 CalBEM Symposium coming up, we thought of posting some of our favorite past visual tools we built for ourselves and others back in 2023 to help have conversations on the process we are all a part of. We often reflect on these and ask, does this seem like what we are doing?
At the Symposium in 2023, we hosted a panel and discussion with the attendees on the potential bottlenecks and discussed some opportunities to improve the process. Major actors in this complex process include the CEC’s Building Standards Branch, third-party tool developers, CEC vendor teams, standards development staff (including CASE, Utilities, and others), and eventually, government officials, builders, contractors, and architects who use the resulting software for code change evaluation and compliance. Two years later we are finding these same tools helpful in thinking not just about advancing energy codes but also in how code is understood, enforced and achieved. Through the illuminating CEC staff report this fall on the Energy Code Compliance Gap Analysis there are a lot of great questions and gaps raised which perhaps warrant a future diagram! For now, we hope you enjoy these.
Maintaining & Advancing Multiple Energy Codes at Once
The California Energy Commission (CEC) updates the energy code requirements, Title 24 Part 6, every three years as part of the larger updates to the entire state building codes, the whole of Title 24. A process of activities over multiple years is shown below for the development of and adoption for Title 24 2025. The Energy Code Multi-Cycle Overlap diagram provides an overview of the energy code development process over multiple cycles. It illustrates the major activities that take place over time, highlighting the crucial fact that the CEC manages a continuous development cycle. This visualization is essential because it demonstrates the need for maintaining multiple energy codes simultaneously. For example, looking at the end of 2024 / start of 2025, concurrent activities include maintaining 2019 and 2022 versions of compliance software and support, while Title 24 2025 software is being developed, 2025 ACM documents written, new code trainings developed, and measures for consideration for 2028 are being evaluated.
While a lot goes into the process each cycle, three major swim lanes are shown on the diagram for the major groups helping advance the code:
The CEC energy code performance compliance software team must publish working software in time for the standard to be trained to users and utilized.
The CEC energy team needs to identify, propose and author code change measures and enhancements in line with state goals and feedback.
The California Investor Owned Utilities (IOUs) support code adoption by finding cost-effective strategies for efficiency improvements in the code which need to be publicly understood, evaluated and considered.
While the process is exciting, it tends to focus our attention on chasing the next level of efficiency the codes can achieve and any easy patches to problems. Yet it is important to remember that construction can be very slow and while new codes have been adopted there may still be projects moving through the process, not yet under construction, which adhere to older versions, 1, 2, or possibly more cycles before. While it is less common, there are still bugs found in those codes and the tools used which can require time, attention, and an update from time to time. Looking again just at the software swim lane shows those activities overlapping for the Title 24 2025 cycle:
This aspect is important to keep in mind when we consider the capacity of our friends at the CEC software team who are out there both maintaining, patching, and building all the time for 3 to 4 code cycles at once.
Development and Meaning of the Process Diagrams
After we developed the first workflow overview diagram we built a second process flow chart diagram specifically focused on the different facets of the code compliance and software development process.
The diagram focused just on the public development of the performance compliance software tools or tool now (CBEC). The Actors in the Software Enhancement Process flow chart focuses on depicting the specific steps and processes required to develop the compliance software and compliance software manuals for each code cycle. This flow diagram arranges activities in a semi-chronological order with key decisions and identifies the major actors (stakeholders) involved.
By mapping out the flow chart, the visual tool helps researchers and staff identify the dependencies between different steps and pinpoint where bottlenecks could occur along the way.
It was exciting to iterate this diagram with a panel of stakeholders involved at different points and hear how the process felt from their perspective and which aspects might be more ideal than history would indicate. Still, it serves a helpful depiction of the state of software development that occurs each code cycle.
The Imperative for Evolution
Through this work we concluded that there is no earlier date to start from in getting new code and compliance software developed and confirmed that satisfying the continuous need to maintain and advance compliance tools like CBEC often consumes available resources, which limits the ability and speed to include additional compliance options. Certainly, we would like to see more advancements or elements perfected yet we can appreciate the challenge that exists with just maintaining the machine. And while complexity builds over time it became clear that it is often a result of multiple things, all in their own way taking steps to advance the code for rational reasons. While we want improvements, it is hard to imagine what it might take to simplify without too much disruption. As California pauses to take stock of its energy code process, with AB 130 now in effect and with the calm after 2025 before 2028, the recent CEC Gap Analysis reminds us that the challenge is no longer just what the next standard will be—but how effectively the existing ones are realized. The diagrams we created to map the code’s moving parts now feel like a lens for seeing today’s compliance gaps: places where process, people, and performance drift apart. In revisiting these maps, we invite readers to reflect on the questions below—not only about how to advance the code, but how to make its intent truly achievable across every cycle.
1. Revisiting the Process
How does the complexity we mapped two years ago contribute to today’s compliance challenges—and where might those same maps help reveal solutions?
2. Defining and Measuring Compliance
What should “compliance” mean in California’s future—adhering to process, achieving modeled performance, or both?
Could new forms of data feedback or simulation help bridge the gap between “process-based” and “energy-based” compliance?
3. Designing for Capacity and Change
What would it take to support local jurisdictions and software teams who must maintain multiple code versions while still improving quality and usability?
How can collaboration among CEC staff, IOUs, RENs, and practitioners evolve to turn compliance insights into practical improvements?
If we treated the compliance gap as a design challenge rather than a policy failure, what new tools, maps, or partnerships might emerge?