Title 24
Managing Updated Title 24 Regulations:  Commercial and Industrial Lighting

By Focus Earth Green Media


Title 24 is one of the most comprehensive energy savings initiatives undertaken by the State of California.  Many have viewed these regulations as a burden, but the lighting requirements of the new CA energy code stand to benefit owners and tenants in measurable ways.

Property owners, architects and contractors face new challenges with the California Energy Commissioner’s 2013 Building Energy Efficiency Standards (Title 24 or “The Code”).  This article examines the lighting and controls portion of Title 24, specifically as they pertain to nonresidential properties.


New lighting and control technologies represent one of the most extreme deviations in energy consumption from their predecessors.  LED lighting and controls systems are often 50-90% more efficient than the standard fluorescent or high intensity discharge (HID) on/off installations.

Contractors, owners, developers and designers unfamiliar with new lighting and control technologies could find some of the latest changes burdensome.  However, innovation is keeping up with the regulations, and a surge of competition has kept service and materials costs manageable.

All commercial and industrial buildings larger than 100 square feet are now required to have either Multi-Level Controls or Continuous Dimming.  These facilities must also meet a set of uniformity requirements for each luminaire type by being connected to at least one of five types of controls.

Typically, these five controls include:


1. Lumen maintenance
2. Tuning maximum light levels below full power
3. Manual continuous dimming with on/off switching
4. Automatic daylight controls
5. Demand response controls


New uniformity measures are good news for employees, as consistent lighting can positively influence work efficacy through reduced eyestrain and fatigue (Lighting Productivity).


Day Lighting Zones will be required in an additional 25% of overall space for all new buildings above 5,000 sq. ft.  The 2008 code mandated that buildings over 8,000 sq. ft. incorporate 50% of the light plan into day lighting zones.  Updated requirements now encompass all buildings over 5,000 sq. ft., and require day lighting in 75% of the ceiling plan.


Occupancy Sensors must be included in all new indoor parking areas, secondary spaces and offices above 250 sq. ft.  When the facility is unoccupied, sensors must be available to cut power by 50 percent.  Requiring occupancy sensors is not good news for fluorescent or HID installations, as both technologies have a “warm-up time” that delays their ability to reach maximum brightness instantly.


Demand-Response Capability requirements have been expanded as well.  While the 2008 code included only retail buildings with sales floor areas greater than 50,000 sq. ft., the new requirements call for nonresidential buildings greater than 10,000 square feet be able to respond to a signal to cut lighting power at least 15 percent below the maximum.  (Studies have shown that the human eye typically does not perceive any change in lights that are dimmed as much as 15%.)


Part 6 also eliminates the Light Waste (a.k.a. “light pollution”) allowance that was traditionally permissible for intermittently used structures such as offices, stairwells, and parking garages.


Retrofit projects will have to incorporate the newest generation of lighting technologies as well.


System alterations allow for the existing lighting system to be modified.  If less than 10% of the luminaires in an enclosed space are affected, there is no requirement.  If more than 10% are involved in a retrofit, area controls, shut-off controls, multi-level controls and daylight controls must be considered.  Lighting providers must focus on the Lighting Power Density (LPD) of the retrofit area, in order to determine the best control system for the application.  Demand response controls only come into play if the facility is over 10,000 sq. ft.


Luminaire modifications-in-place include modifying the internals of the luminaire, changing the optical system, or replacing lamps and ballasts in the fixtures.  These modifications are only required if less than 10% of the luminaries are in an enclosed space, and more than 40 luminaires are modified-in-place.


Lighting wiring alterations now encompass modifying or relocating existing luminaire wiring, adding circuit feeding luminaries, replacing board wiring or installing a new panel board feeding the building’s lighting systems.


The State of California has developed a training test called California Advanced Lighting Controls Training Program (CALCTP), which obligates technicians to recertify each time the codes change.  Certified Lighting Controls Acceptance Test Technicians (CLCATT), dubbed “cool cats”, are becoming an integral aspect of all lighting retrofits and new construction.


CLCATTs verify the following information about a project:


1. Equipment meets the Certificate of Compliance
2. Installation includes mandatory lighting controls
3. Acceptance & Installation forms are completed


Hiring a CLCATT costs about the same as hiring a qualified contractor or electrician, and is necessary to ensure your property is up to code after the installation of a new system.  The State of California Energy Commission offers training and online help to assist buildings owners and planners meet the mandatory requirements.


Commissioning and acceptance testing compels owners to view lighting as a long-term investment.  Fortunately, the burden of adoption has been eased by the influx of new lighting manufacturers.


Hundreds of lighting and control providers have entered the global market, and the cost to upgrade has reduced considerably.  Lighting system consultants, like CA-based Focus Earth, have also emerged to help commercial and industrial building professionals navigate the myriad of new systems available.

We always welcome reader feedback!  If you feel something should be included in this article to help future readers understand Title 24 better, don’t hesitate to contact us.  Thanks!

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