The HVAC system a cannabis cultivator installs today could still be running a decade from now. The facility being designed today may go through multiple expansions, renovations, and equipment upgrades over its lifetime. The codes governing those facilities will not stand still.
That’s the question DRM CEO Nic Bucholz is urging operators to ask before making any major facility investment in 2026: will this facility still make sense under the next generation of codes?
California Is a Preview of What’s Coming
California’s 2025 Energy Code took effect January 1, 2026, and already sets specific requirements for controlled environment horticulture, covering dehumidification equipment, horticultural lighting, and electrical power distribution. Those rules do not just apply to new builds. Newly installed HVAC or dehumidification systems in existing indoor grow facilities have to comply too, and certain lighting alterations can trigger the same requirements.
More is already on the calendar. California’s 2025 Intervening Code Adoption Cycle produces supplements effective July 1, 2027, and the state is already developing its next major Energy Code for 2029. For large, high intensity indoor cultivation facilities, a proposal under discussion would tie HVAC and dehumidification together as one coordinated system rather than two separate equipment purchases, requiring load calculations across every stage of the grow cycle, lights on and lights off.
“You can’t look at HVAC and dehumidification as two unrelated equipment purchases,” Nic said. “They are managing the same environment and interacting constantly.”
Not Just a California Problem
Massachusetts passed legislation in 2026 requiring its Cannabis Control Commission to review cannabis regulations on workplace safety, including air quality, by July 1, 2027. Meanwhile, the International Code Council is developing its 2027 generation of model codes, the same codes that states and local jurisdictions build their own standards on top of.
“There isn’t one national cannabis building code that suddenly changes on January 1,” Nic said. “What we’re seeing is an evolving network of building, mechanical, electrical, fire, energy and cannabis-specific requirements.”
Six Things to Review Before a Major Investment
DRM recommends operators planning construction, expansion, or significant equipment purchases review:
- HVAC and dehumidification strategy. Calculate real sensible and latent loads across the full grow cycle instead of relying on rules of thumb.
- Electrical capacity. Confirm the facility can support current and future equipment without a costly infrastructure redesign later.
- Equipment selection. Evaluate equipment on how it performs as part of the whole system, not just purchase price.
- Fire and life safety. Understand how occupancy classifications, egress, and hazardous materials rules apply as facilities change.
- Permitting and code cycles. Know which code edition will actually govern your project timeline.
- Expansion flexibility. Build today’s infrastructure so tomorrow’s expansion is a plan, not a redesign.
The Cheapest Equipment Can Become the Most Expensive Decision
An undersized HVAC system often leads to bolted-on dehumidification, which adds heat, which adds cooling load, which can trigger an electrical upgrade. What started as one equipment decision becomes a full facility redesign.
“The least expensive place to solve these problems is on paper,” Nic said. “Once equipment has been ordered, walls have been built and permits have been submitted, your options get more expensive very quickly.”
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For more details on planning cannabis cultivation facilities around evolving codes and long-term infrastructure needs, read the full press release here:
Know What’s Coming Next in Codes While Still Planning
Plan Now, Don’t Panic
None of this means operators should freeze investment until every future code is finalized. It means the opposite: use this window to make better informed decisions on projects that will stay in service long after today’s requirements change.
“Don’t wait until a code change forces you to rethink the facility,” Nic said. “If you’re buying a major piece of equipment, expanding canopy, renovating rooms or designing a new facility, that’s the time to have the conversation. We can look at what you need today, what the codes require and where the requirements are heading before you spend the
