01Key facts / TL;DR
Yes, many permitted commercial/TI alterations need applicable Part 6 compliance documentation.
It depends which lighting, mechanical, envelope and other regulated systems are actually changed.
No, a lighting-only TI is not automatically the same documentation scope as a full-building project.
It depends what a change of occupancy triggers; confirm the specific work and requirements with the AHJ.
02“Tenant improvement” describes a project, not a complete energy scope
A TI can range from finish work to major changes in lighting, controls, HVAC, envelope and use. The energy question needs the actual affected systems. A lease area, construction budget or the words “office remodel” do not tell a preparer which certificates and calculations apply.
For many permitted nonresidential alterations, NRCC design-compliance documents form part of the submission. A focused lighting scope can differ substantially from mechanical changes or a complete building design. Do not order a generic all-systems package without identifying what is retained, altered and newly installed.
Some limited finish-only work may not create a new Part 6 documentation task, but this guide grants no permit exemption. Change of occupancy or conditioning can also affect the analysis. Ask the AHJ which requirements and evidence apply to the specific work, rather than treating a small tenant area as a blanket waiver.
03A commercial/TI decision checklist for architects and applicants
Describe the work at system level and keep responsibility boundaries visible.
- +Use and scope: identify existing/proposed occupancy, tenant boundaries, conditioned areas, shared/common spaces and whether shell work or a separate permit already governs part of the project.
- +Lighting: mark affected fixtures, controls and space uses. Provide schedules/layouts and supported design information; do not infer compliance merely because luminaires are LED.
- +Mechanical: identify changed equipment, controls, ventilation and served areas, with retained versus new systems. Tenant walls alone do not establish HVAC boundaries.
- +Envelope and other systems: mark glazing, assemblies, hot water and other affected regulated work. Identify interactions with the landlord’s or shell designer’s scope.
- +Application and evidence: provide the AHJ-recorded date, actual plan revision, accepted prior reports and complete comments. Ask about unresolved occupancy/scope questions before final preparation.
04Lighting-only, full TI and shell coordination
For a lighting-only alteration, start with the affected lighting and controls and the applicable method. The current CEC catalog includes NRCC-LTI indoor-lighting documentation. Area categories, space use and retained/altered scope need to reflect the design; a generic office label may hide different actual spaces.
A broader TI may also change HVAC, ventilation, envelope or other systems. The correct package should address each applicable system without claiming unrelated existing work was redesigned. Show who owns shell/base-building documentation and which assumptions the tenant’s work changes. A previously accepted shell report does not automatically cover a different tenant layout or system alteration.
Do not assume the only choices are “no report” and a whole-building performance model. Applicable prescriptive or performance approaches and system-specific documents can differ. The preparer needs enough information to identify supported deliverables, not a request to manufacture a passing result around incomplete plans.
Detailed tenant-improvement guideCommercial documentation service
05Form families and the people responsible
NRCC records design compliance for the applicable nonresidential scope. NRCI addresses installation, NRCV applicable verification, and NRCA acceptance testing. Not every project needs every record. The current catalog and selected measures determine the actual documents and instructions.
The architect and system designers define the proposed work; the energy preparer supports the agreed compliance documentation. Installing contractors and applicable qualified verification/acceptance participants address their respective stages. A prepared NRCC does not certify that equipment was installed or that controls passed acceptance testing.
ECC is current residential field-verification terminology, with HERS relevant to legacy/older-cycle residential records. Do not describe commercial acceptance testing as simply renamed HERS or assume all NRCA records are ECC certificates. Match the terminology and family to the actual building and measure.
Current CEC nonresidential formsCEC Energy Code Support Center
06Worked decision: LED replacements versus a coordinated TI
ILLUSTRATIVE ONLY: a proposed office TI replaces lighting and changes room layouts while retaining some fixtures. The applicant initially submits only a fixture cut sheet. The team requests the affected-area plan, space uses, fixture/control schedules and retained-versus-altered scope before selecting applicable indoor-lighting documentation.
The mechanical designer then identifies a changed served-area layout. The energy task is reviewed to determine the additional applicable mechanical documentation, rather than assuming a lighting certificate covers the whole TI. No invented wattage limit, fixture-count exemption or acceptance-test result is supplied.
The final design package identifies applicable construction-stage installation/acceptance responsibilities. Those later tasks are not described as included report preparation. The lesson is to define changed systems early, then keep drawings, NRCC and construction records consistent instead of collecting unrelated blank forms.
07Application date and occupancy changes need explicit confirmation
The 2025 California Energy Code applies to building-permit applications on or after January 1, 2026. Confirm the AHJ-recorded date and its treatment of amendments, phased shell/TI submissions or refiling. A lease signing, landlord approval or earlier conceptual drawing does not automatically establish the tenant permit’s code edition.
A change of occupancy is a reason to review the actual use, conditioning and affected systems—not to assert that every case needs one identical full-building energy package. Provide both existing and proposed use and ask the agency which requirements apply. This educational guide does not determine occupancy classification, grant an exemption or provide legal advice.
08What to request after the need decision
Send plans and schedules with a written system scope, application record, accepted shell/previous reports and responsible designer contacts through the private intake process. Include the complete correction list for resubmittals and clearly mark changes. Describe unknowns so scope can be agreed before final documentation.
The published commercial square-footage tiers describe the report-pricing menu, not an assurance that every permit needs the same work. Field/acceptance testing, registry fees, CALGreen and AHJ permit fees are separate. Preparation does not design the systems, perform the tests or control permit-review timing. Use the detailed service and form guides for the next stage.
Nonresidential forms and responsibility guidePlan-check correction supportModeling option studies
09Six commercial/TI decisions
Does every TI require a whole-building performance model?
No universal model is assigned here. Identify the actual changed systems and applicable documentation/method. A lighting-only alteration can differ from a full TI or new building.
Are LED luminaires enough to show lighting compliance?
No. Applicable controls, space uses, altered/retained scope and documentation still need review. A product cut sheet alone does not establish the completed design’s compliance.
Can a shell energy report automatically cover the tenant layout?
Do not assume so. Provide the accepted shell package and actual tenant changes. The design/documentation team must identify which assumptions and systems remain valid or need updating.
Does a change of occupancy always need identical NRCC pages?
No. Identify existing/proposed use, conditioning and systems, then confirm applicable requirements with the AHJ. This guide does not grant an occupancy or documentation exemption.
Does NRCC preparation include NRCA acceptance testing?
No. Design documentation and applicable installation/verification/acceptance responsibilities are separate. Qualified participants complete required testing; its cost and field work are excluded from report preparation.
Is commercial acceptance testing now called ECC?
Do not conflate the programs. ECC is current residential field-verification terminology; nonresidential acceptance records retain their applicable family and instructions. Use the CEC catalog for the actual building/system.
10Choose the next documentation step
Use the published residential/commercial square-footage menu to understand report pricing, then send a scoped request rather than assuming a full model is necessary. Field testing, acceptance testing, registry fees, CALGreen and AHJ permit fees are separate. Intake is not payment, production acceptance or permit approval. This is educational information, not legal advice; confirm the applicable requirements and documentation with the authority having jurisdiction (AHJ).
Start with the Title 24 decision hubDo I need Title 24 for multifamily?Do I need Title 24 for remodel?Do I need Title 24 for windows?Confirm the application’s code editionWhat to send for an energy reviewNonresidential form responsibilitiesSee published PricingGet a Quote / upload plans