Sustainability Plan Review

ENERGY EFFICIENCY REGULATIONS & PLAN REVIEW FOR SCHOOL CONSTRUCTION

All projects submitted to DSA for plan review, including relocatable modular buildings, must comply with the 2022 California Energy Code and the 2022 California Green Building Standards Code (CALGreen).

The effective date of the 2022 Building Energy Efficiency Standards of the California Energy Code is January 1, 2021. The DSA will be reviewing all applications for compliance to these standards. Applications for Pre-Checked designs for permanent or relocatable modular buildings submitted on or after January 1, 2021 need to meet the 2022 Energy Code. Refer to 2022 Building Energy Efficiency Standards and related notices and publications at 2022 Building Energy Efficiency Standards.

FOR DSA SUBMITTAL REQUIREMENTS

All site built projects are required to submit one or both of the following DSA forms:

• DSA 403-A: 2022 Energy Code - Certificates of Compliance Checklist (PDF) 
• DSA 403-B: 2022 Energy Code - Certificates of Compliance Checklist (PDF)

All Pre-Checked designs for permanent or relocatable modular buildings projects are required to submit the following DSA forms:

• DSA 403 PC-PER: Performance Method – 2022 CALGreen & Energy Code Compliance Checklist for Pre-Checked (PC) Building Designs (PDF)
• DSA 403 PC-PRE: Prescriptive Method – 2022 CALGreen & Energy Code Compliance Checklist for Pre-Checked (PC) Building Designs (PDF)

FOR PRE-CHECK SUBMITTALS

• PR 18-02: Pre-Check Permanent Modular or Relocatable Building Designs CALGreen/Energy Code Compliance Review (PDF)

For any questions regarding the California Energy Code, please call California Energy Commission’s (CEC) hotline at (916) 654-5106 or (800) 772-3300. You can also email CEC with your inquiry at title24@energy.ca.gov.

PROPOSITION 39 PROJECT REVIEW

Proposition 39 California Clean Energy Jobs Act K¬–12 Program awarded more than $1.7 billion over the five years it was in effect to local education agencies (LEAs) to improve the energy efficiency of the school buildings with equipment upgrades and clean energy generation measures.

The focus of the program was to improve the efficiency of buildings so that money is spent on education and creating jobs rather than spent on energy usage. The implementation of Proposition 39 was authorized and administered in accordance with Senate Bill 73 (SB73). DSA collaborated with the CEC, who was the lead in developing the guidelines for the overall program.

Funding for this program is no longer available and the program has ended. Projects that received funds are either closing construction or in the reporting phase. The deadline for all Proposition 39 projects to be completed was June 30, 2021, and annual reports were due no later than September 30, 2021. All final reports are due no later than September 30, 2022. Please review the CEC website for specific requirements and conditions of the program. 

PROJECTS REQUIRING DSA REVIEW

See DSA Interpretation of Regulations (IR) A-22: Construction Projects and Items Exempt from DSA Review for more information regarding solar photovoltaic installations on school campuses.

For information on accessibility requirements related to solar photovoltaic installations at school sites see IR 11B-9: Accessibility Requirements for Solar Photovoltaic Systems at School Site: 2013 CBC.

ELECTRIC VEHICLE CHARGING

Governor Gavin Newsom declared State of Emergency proclamations for the continued statewide drought in April and October of 2021. These proclamations extended those already declared by the previous governor in 2014. In support of the governor’s initiatives, DSA proposed regulations in the 2013 California Green Building Standards Code (CALGreen) to reduce outdoor water use for landscape irrigation by public schools and community colleges.

The DSA regulations were approved on an emergency basis by the Building Standards Commission on July 21, 2015 and are based upon the Model Water Efficient Landscape Ordinance (MWELO) regulations adopted by the Department of Water Resources. Since January 1, 2016, applications received by DSA are subject to the Outdoor Water Use regulation in CALGreen.

Refer to DSA Procedure (PR) 15-03: Compliance with CALGreen Code Outdoor Water Use Regulations for detailed information.

 1. When is the DSA 1-L: Title 24, Part 11 – Outdoor Water Use Self-Certification of Landscape Irrigation Design and Documentation form required?

All projects containing irrigated landscape improvements or modifications to existing landscape irrigation are required to comply with the Outdoor Water Use Regulations of Title 24, Part 11 (CALGreen), which are based on the mandatory MWELO in Chapter 2.7, Division 2, Title 23, California Code of Regulations.
Projects are required to be submitted to DSA if the project cost is over the threshold that requires project submission to DSA. Refer to IR A-22 for information on these project cost thresholds.

2. Do I need to submit a DSA 1-L if the project’s scope of landscape work does not include the installation or modification of an irrigation system?

Yes. If the project’s scope of landscape work does not include the installation or modification of an irrigation system, check the appropriate box on the DSA 1-L and provide the signed form at project submittal.

3. Do I need to submit a DSA 1-L if the landscape work is under the area thresholds defined in the CALGreen Outdoor Water Use Regulations?

Yes. If the landscape work is under the area thresholds defined in the CALGreen Outdoor Water Use Regulations, check the appropriate box on the DSA 1-L and provide the signed form at project submittal.

4. Do landscape-only projects need to be submitted to DSA?

Landscape-only projects are not required to be submitted to DSA; however, compliance to the CALGreen Outdoor Water Use Regulations is required.

5. For incremental projects with increment specific irrigated landscape in the scope of work, will each increment be required to submit form DSA 1-L?

No. There is only one DSA application number for incremental projects; therefore, there is only one form DSA 1-L required for the project. The initial submittal will require a Site Landscape Area Location Plan which shows all the irrigation landscape scope for all the increments. If there is a change of scope after the initial submittal, a revised form DSA 1-L will need to be submitted.

6. If an area of rehabilitated landscape is over 1,200 square feet (sq. ft.) but is a Special Landscape Area (SLA), does the Outdoor Water Use Regulations of CALGreen apply?

Yes. The Outdoor Water Use Regulations of CALGreen apply to the SLA. While SLA have an increased water allowance, they must be designed and installed with an evapotranspiration adjustment factor equal to or less than 1.00.

7. If a school district utilizes reclaimed water at the site, is a form DSA 1-L required?

Yes. Modifications to the existing irrigation systems are required to be submitted to DSA, even if a site is in full compliance with  MWELO.

8. Do the CALGreen Outdoor Water Use Regulations apply to landscape projects on property owned by the school district or community college but leased to a charter school?

Yes. Landscape projects on property owned by the school district or community college but leased to a charter school must comply with the CALGreen Outdoor Water Use Regulations.

9. Do I need to file a DSA form L-1 if the scope of work includes reconfiguration of ballfields on an existing irrigated sports area?

Landscape projects where the scope of work includes rehabilitated irrigation systems are required to meet the CALGreen Outdoor Water Use Regulations. Form DSA 1-L is required for projects at existing schools rehabilitating irrigation systems.

10. Are landscape maintenance projects such as reseeding/resodding of athletic fields and replacement of dead plants required to be submitted to DSA?

“Maintenance” work does not require submission to DSA provided the existing irrigation system is not being modified.

11. Does “rehabilitated landscape area” mean that the existing landscape area is irrigated? Are there any situations where the existing landscape is not irrigated, but can be considered rehabilitated?

No. Replacing a current inefficient irrigation system with a more efficient irrigation system is critical to the definition of “rehabilitated.” An existing landscape area must have an inefficient irrigation system to be considered a landscape area that can be “rehabilitated.”

12. Can both new and rehabilitated landscape areas occur on an existing site?

Yes. “New landscape” is an area that never has had landscape irrigation installed, whereas “rehabilitated landscape” is an area that previously had landscape irrigation installed.

13. Is a campus exempt from the Minimum Rehabilitated Landscape Area (MRLA) requirement of the CALGreen Outdoor Water Use Regulations if there are no irrigated landscape areas on the entire campus, or all the existing landscape areas are compliant with MWELO?

Yes. Projects on a campus that have no irrigated landscape areas or are fully compliant with either the 2009 or 2015 MWELO would not be subject to the MRLA requirement. Check the appropriate box on the DSA 1-L and provide the signed form at project submittal.

14. Is a shade structure exempt from the MRLA requirement?

Yes. Shade structures are exempt from the MRLA requirement.

15. Can the MRLA requirement be satisfied by using a combination of rehabilitated landscape areas and removal of existing irrigated landscape areas from service?

Yes. Show the location and the square footages on the Site Landscape Area Location Plan with a description of the type of rehabilitation or removal and show the entire area of the previously irrigated landscaped area.

16. Can I apply the MRLA to an existing landscape area that is taken out of service by new paving, hardscape or a building? =

The MRLA may be applied to the existing landscape area being removed if it has an irrigation system. Any portions of the remaining existing landscape irrigation system that are modified must comply with the CALGreen Outdoor Water Use Regulations.

17. If the district wants to replace natural turf which has an existing irrigation system with synthetic turf which will only require water for cooling/cleaning, will the existing area be considered “out-of-service?”

While the 2015 MWELO does not specifically address synthetic (artificial) turf, the Department of Water Resources (DWR) considers it a nonliving area similar to a hardscape. Since artificial turf needs to be cooled and washed, the water utilized by a permanent watering system or hose bibs needs to be included in the district’s water budget. The area is not necessarily “out-of-service;” however, the area would be considered “rehabilitated” since it is more water efficient.

18. What is the district required to do for a site that has less landscape area needing rehabilitation than required by the MRLA?

If the existing irrigated landscape area needing rehabilitation is less that the MRLA required area, show on the Site Landscape Area Location Plan the areas to be rehabilitated and note in Part 3 of the DSA 1-L that there are no additional irrigated landscape areas on the existing site needing rehabilitation.

19. Is the MRLA required for buildings that are being replaced due to fire, water, or other related damage?

If the building has approximately the same square footage as the original building (measured at the footprint), then it would be a considered a “replacement-in-kind;” therefore, compliance with the MRLA requirement is not required. Form DSA 1-L will be required to be submitted if the project includes irrigated landscape work that exceeds the area thresholds of the CALGreen Outdoor Water Use Regulations.

20. Does the MRLA apply to projects involving placement of relocatable buildings?

Yes. For projects involving placement of a relocatable building with a total area of 1,600 sq. ft. or greater, the MRLA applies.

21. When is the application of the MRLA required for relocatable buildings installed on a new or existing site?

The following table lists the various options and whether the MRLA is required:

22. We are working with a school district that is planning to replace an existing 1,920 sq. ft. modular building with a new 2,800 sq. ft. modular building. Since we are only adding 880 sq. ft. of building area, and therefore below the 1,600 sq. ft. threshold, are we exempt from the MRLA requirement?

No. The 2,800 sq. ft. modular building is considered a “new building” and therefore the project is not exempt from the MRLA requirement.

23. What would trigger a DSA MWELO audit?

The CALGreen Outdoor Water Use Regulations require compliance with the provisions of MWELO. While DSA is relying on a trust-based self-certification of compliance by licensed design professionals, it also has a responsibility for accountability to the DWR that the regulations are being followed.

DSA audits of landscape irrigation projects will be based on several criteria:

• Randomly selected from projects with significant landscape irrigation work.
• Observations of DSA inspectors and field engineers.
• Citizen or district complaints of noncompliance.
• Pattern or practice of systematic noncompliance on previous audits.