BLUF: ASHRAE 90.1-2022 Addendum G — the Load Management section — turned grid-interactive operation from a voluntary efficiency story into a code-anchored procurement question. Seven G-modules (G01 through G07) now name the operator actions that count. The DOE Grid-Interactive Efficient Buildings (GEB) program and the GEB Decarbonization Resource Guide give the engineering blueprint underneath. This page is the operator translation: what each G-module asks, which jurisdictions are wiring it into state energy code, and a 12-question Readiness Diagnostic that maps a portfolio to compliance posture today.
What changed: the load-management vocabulary moved into base code
Until 2022, “grid-interactive” was a research framing — valuable but optional. ASHRAE 90.1-2022 Addendum G changed that by naming load management as a measurable building attribute. Seven discrete modules (G01-G07) define what an operator must be able to do, monitor, or report. As state code adoption cycles fold 90.1-2022 into mandatory minimums (a 7-15 month rolling window per state cert), the modules become procurement language — a chiller plant, a controls retrofit, or a tenant fit-out either supports the module or it does not.
The DOE’s Grid-Interactive Efficient Buildings Initiative runs the engineering layer underneath: VOLTTRON as the open-source orchestration platform, the GEB Reference Architecture as the system blueprint, and the GEB Decarbonization Resource Guide as the operator playbook. The CRE-side translation has been missing — operators have the modules in their code, the engineering in DOE’s tech library, and no published bridge between the two.
The seven G-modules, in operator language
| Module | What the code asks | Operator translation | Failure mode the agent flags |
|---|---|---|---|
| G01 — Demand response readiness | The building can receive and respond to grid signals (auto-DR or manual within stated window) | BMS subscribes to a DR signal stream; setpoint overrides documented; minimum response time logged | No DR-signal endpoint configured; setpoint overrides not auditable |
| G02 — Load-shifting capacity | Ability to shift loads (HVAC, thermal storage, EV, lighting) by N hours without thermal-comfort breach | Pre-cool/pre-heat sequence, ice/chilled-water storage charge schedule, EV-load shed protocol | Sequence not validated under summer/winter design days; comfort exceedance unrecorded |
| G03 — Load-shedding capacity | Ability to drop discretionary load by X% within Y minutes of a DR call | Plug-load circuits, redundant lighting circuits, ventilation reduction zones documented | Shed protocol exists on paper but no measured baseline; no recovery sequence |
| G04 — On-site generation coordination | PV, fuel cells, generators, batteries are coordinated with the load (not free-running) | Energy management system orchestrates dispatch; export limits respected; transitions logged | PV inverter and BMS do not share telemetry; battery dispatch decisions are vendor-side, not operator-side |
| G05 — Metering granularity | Interval data (typically 15-minute or finer) by end-use category, retained for the IPMVP baseline period | Whole-building, HVAC, lighting, plug-load sub-meters with timestamped retention; data quality monitored | Sub-meter coverage <60% of regulated end-uses; gaps unreported |
| G06 — Communication and protocol openness | Control points exposed via open protocol (BACnet/IP, OPC-UA, or similar) for grid services participation | BACnet point list published; OT-IT boundary documented; cybersecurity boundary mapped | Proprietary BMS protocol cannot expose points without vendor middleware |
| G07 — Reporting and verification | Annual report covering DR events, load shifted, load shed, on-site generation, M&V protocol | IPMVP Option C whole-facility baseline; G-module event log with utility cross-check | Annual report assembled by hand each year; no audit-grade trail |
Jurisdictional adoption: which states reference 90.1-2022 today
State-cert posture for 90.1-2022 (the substrate Addendum G amends) is moving in three speeds:
- Lead states. California (Title 24 cross-references), Washington (state energy code), New York (Stretch Code adoption), Massachusetts (Specialized Stretch Code), Colorado, Oregon — either already reference 90.1-2022 or its functional equivalent in adopted code as of Q2 2026.
- Mid-cycle states. Texas, Illinois, Pennsylvania, Florida, Virginia, North Carolina — in active rule-making or code-cycle review windows where the load-management vocabulary is on the table for the next code update.
- Trailing states. Several southeastern and plains states remain on 90.1-2016/2019 substrate; municipal-level stretch codes (Atlanta, Austin, Denver, Boulder, NYC LL97) are the operator-relevant trigger here.
Two parallel layers compound: federal grants (Inflation Reduction Act § 50121 energy efficiency revolving loan fund, § 50131 building energy code adoption grants) reward states that adopt zero-energy-ready and grid-interactive-ready code; utility tariffs (capacity tags, time-of-use bands, real-time pricing pilots in PJM/CAISO/ERCOT/NYISO) reward buildings that operate as G-module compliant whether or not state code requires it yet.
What this means for procurement this quarter
If a portfolio is renewing a BMS, a controls contract, an energy services agreement, or a tenant fit-out package between now and Q4 2026, the G-modules belong on the RFP. Three questions a buyer should be able to ask without rewriting the spec:
- Which G-modules does this scope support — out of the box vs. with optional add-ons? A vendor who cannot answer at the G01-G07 level is selling a 90.1-2016 product against a 90.1-2022 floor.
- Show me the M&V protocol for G07. If the answer is “we report annually,” ask whether the report is IPMVP-grade. If the answer is “the BMS dashboard,” the G07 reporting pillar is not present.
- Show me the BACnet/IP point list for G06. If the vendor cannot expose the controls layer over open protocol, the G06 pillar is structurally absent — not a roadmap gap.
The 12-question GEB Readiness Diagnostic
A self-scored diagnostic that maps a portfolio to G01-G07 posture in ~30 minutes. Each Yes is 1 point; each No is 0; partial-coverage is 0.5. Score 0-6 = pilot-only readiness, 7-9 = procurement-ready for new contracts, 10-12 = portfolio-grade G-module compliant.
- Does at least one building in the portfolio currently receive an automated DR signal (OpenADR 2.0b or equivalent)?
- Are setpoint overrides logged with timestamp, originating user/system, and revert state?
- Is there a documented pre-cool / pre-heat sequence validated under summer and winter design days?
- Has the load-shed protocol been measured under a real or simulated DR call within the last 12 months?
- Are on-site PV, batteries, and generators visible to the BMS (or vice versa) with shared telemetry?
- Do sub-meters cover ≥60% of regulated end-uses with 15-minute or finer interval data?
- Is the BMS point list available over BACnet/IP (or OPC-UA) without vendor middleware?
- Is the OT-IT boundary documented and reviewed annually by the security team?
- Is an IPMVP Option C baseline established for at least one building in the portfolio?
- Is the annual G-module event log assembled from BMS data programmatically (not manually)?
- Has the M&V protocol been cross-checked against the utility’s 15-minute interval data in the last 6 months?
- Is the operator’s grid-interactive posture summarized in a procurement-ready document the buyer’s legal team can review (rather than a vendor brochure)?
Operators who score below 7 should treat the GEB readiness gap as a code-survivability question, not a sustainability story. The 90.1-2022 floor is rising under your portfolio whether or not your asset team has been told.
Agent Door: ask before you sign
A working CRE-TS technical-services agent can be asked — with no NDA, no demo schedule — “Show me which sections of ASHRAE 90.1-2022 my chiller plant would fail today,” or “Walk me through G05 metering granularity for an office portfolio in a state on 90.1-2016 substrate.” The agent returns the section reference, the operator translation, and the procurement-language version. Try it: /ask/.
Companion reading. IPMVP verification framework (Option C baseline anchors G07 reporting) · MCP-native CRE platform surface (CRE-TS BMS/IoT squad outputs) · EU AI Act readiness procurement document (parallel compliance posture surface) · The 7 CRE squads
Sources. ASHRAE 90.1-2022 Addendum G (Load Management) · DOE Grid-Interactive Efficient Buildings (GEB) Initiative · GEB Decarbonization Resource Guide · DOE VOLTTRON open-source platform · ASHRAE GEB Resource Guide · OpenADR 2.0b specification · IPMVP 2022 Option C protocol · Inflation Reduction Act §§ 50121, 50131 (energy code adoption incentives).