Title 24 Covered Process Requirements

A covered process is equipment the Energy Code regulates in its own right rather than as part of the building — refrigeration, parking garage ventilation, process boilers, compressed air, elevators and escalators.

What makes something a covered process

Most of the Energy Code is about the building: its envelope, its lighting, the systems that keep people comfortable. A covered process is different. It is equipment that exists to do a job — freeze food, move people between floors, drive tools, raise steam — and whose energy use has nothing to do with occupant comfort.

Because that equipment is often the largest load in the building, the code regulates it separately under Section 120.6 rather than leaving it outside the scope. A refrigerated warehouse spends far more energy holding product cold than conditioning the few people working in it.

Seven subsections, seven different triggers

Section 120.6 runs from (a) to (g), and each part has its own threshold. That is the single most important thing to understand about it: there is no general covered-process requirement you either meet or do not. You work through the list and see which parts your equipment engages.

The thresholds are genuinely different in kind. A refrigerated warehouse is caught at 3,000 square feet of refrigerated space. A retail food store is caught at 8,000 square feet of conditioned area. A garage exhaust system is caught at 10,000 cfm of design exhaust. A process boiler is caught at an input capacity in millions of Btu per hour. Elevators are caught by existing at all.

Two forms, and a family of acceptance tests

Covered process compliance is documented on its own forms rather than folded into the mechanical or lighting sets: NRCC-PRC-E for the certificate of compliance and NRCI-PRC-E for the certificate of installation.

Behind those sits the largest acceptance test family in the code — more than twenty separate NRCA-PRC tests covering compressed air controls, garage ventilation, refrigerated warehouse evaporators and condensers, variable speed screw compressors, underslab heating, elevator lighting and ventilation, escalator speed control, laboratory exhaust, fume hoods and steam traps. You only run the ones your equipment triggers.

Who is allowed to run those tests

This is where covered process differs usefully from the rest of the code. Every acceptance test in the PRC family carries the -F suffix, which means a field technician may perform it. Lighting controls and mechanical acceptance tests require a technician certified through an approved provider; covered process tests do not.

That is a real scheduling and cost difference at the end of a job, and it is worth knowing before a contractor is told to find a certified technician who was never needed.

Why it gets missed

Covered process equipment is usually specified by a process engineer or an equipment supplier rather than by the design team producing the energy compliance documents. The refrigeration contractor selects the condensers; the energy consultant never sees the selection. Nothing surfaces until the forms are assembled and the equipment does not meet a requirement nobody applied to it.

Establishing early which subsections your project engages is the whole of the work here. The requirements themselves are specific and satisfiable — they are just easy to apply too late, when the equipment is already ordered.