The MVPE committee of the State Building Code Council on Feb. 17 approved written opinions clarifying when refrigerated walk‑in coolers and freezers are considered refrigerated warehouses subject to the commercial energy‑code provisions and voted to table a related question for further refinement.

Committee members said the threshold in the current code that separates a walk‑in cooler or freezer from a refrigerated warehouse is square footage‑based and that the distinction, not the presence of refrigeration equipment alone, drives which sections of the energy code apply.

"In looking at the code there, I think there's a differentiation between refrigerated warehouses and warehouses that have refrigeration units within them," committee member Kjell said during the discussion. "Adding coolers or or freezers to a warehouse doesn't make it a refrigerated warehouse. But if you're building a new warehouse and it is in the entire thing or a large portion of it is cool, then it is a new refrigerated warehouse and requires compliance with the relevant sections of code."

Why it matters

The committee's clarification matters for grocery stores, distribution centers and food‑processing facilities that may add cooled areas inside larger non‑refrigerated buildings. Different energy‑code sections (notably C406 and related commercial energy provisions) apply to whole refrigerated warehouse buildings and can require additional efficiency credits and renewable generation or other measures. Developers, designers and local code officials told the committee the difference can have substantial cost and design implications.

What the committee approved and why it was tabled

Members unanimously approved the committee's draft answers for Question 1 and Question 3 that address when refrigerated spaces trigger the commercial code. The committee amended language to emphasize the square‑footage split and existing code definitions. The committee then voted to table Question 2—an item that committee members said folded multiple scenarios into one unclear question—so staff and members can rewrite it as at least two distinct questions (for a new refrigerated building vs. a refrigerated space added inside an existing building).

"I hate to do this, but I don't know that I'm I'm gonna agree with Larry on this one and suggest that we need to split this into a couple questions and come up with thoughtful questions and thoughtful answers," Kjell said before making the motion to table. The motion was seconded and passed.

Key points from discussion

- Square‑footage threshold: Several members referred to a 3,000‑square‑foot metric in the current definitions. "My question is is where did you come up with the 3,000 square feet?" asked Larry Andrews (Andrews Mechanical Incorporated), who noted many grocery and distribution coolers can be large and heavily insulated.

- Source of the definition: Lisa Rosner (Evergreen Technology Consulting) said the 3,000‑square‑foot threshold comes from the ICC/IECC definitions (ICC 2021 referenced) but agreed the line can be confusing in some retrofit and mixed‑occupancy scenarios.

- Alterations vs. new construction: Committee members discussed that Chapter 5 (alterations) generally does not trigger the same C406 requirements that apply to new buildings and additions, but that a change in space conditioning (see C505.2/C505.3) may require bringing an altered space up to code.

- Practitioner view: Brett, an architect who works on refrigerated projects, described two distinct real‑world types: fully refrigerated buildings (where the enclosure itself is climate‑controlled) and discrete refrigerated boxes inside larger buildings. He said the latter are commonly treated as process equipment and may not automatically trigger the refrigerated‑warehouse provisions.

What the opinions say (summary)

- Walk‑in coolers and freezers wholly enclosed within another occupancy typically remain governed by the host occupancy's requirements; they do not automatically convert the entire building to refrigerated‑warehouse status simply by the presence of refrigeration equipment.

- A new building that is primarily a refrigerated, climate‑controlled warehouse (or where a large portion of the building is refrigerated) is treated as a refrigerated warehouse and is subject to the relevant commercial energy‑code sections.

- Whether a retrofit or alteration triggers the refrigerated‑warehouse requirements depends on whether the work constitutes a change in space conditioning or occupancy that is within the scope of Chapter 5 (not all alterations trigger C406).

Meeting action

- The committee approved the draft opinions for Question 1 and Question 3 as presented (motion by Kjell; seconded; passed by voice vote).

- The committee voted to table Question 2 to the next committee meeting to allow staff and the proponent to reframe it as two distinct questions (motion to table by Kjell; seconded by Ben; passed by voice vote).

What members asked staff to do next

Committee members instructed staff to: (1) confirm the cross‑reference to the ICC/IECC 2021 definition for the 3,000‑square‑foot threshold in the published opinion; (2) add clearer language distinguishing a refrigerated "space within a space" from a fully refrigerated building; and (3) solicit a rewritten Question 2 from the proponent that separates new refrigerated buildings from refrigerated spaces added inside existing buildings.

Ending

Chair Jay Arnold thanked members and moved the committee to its next agenda items after the vote to table.