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Key changes in the 2016 update of California’s Title 24 energy standard include new performance parameters related to lighting quality, a color rendering index (CRI) of 90 or better, and correlated color temperature of 4,000K or lower.

California Code: The impact of Title 24

May 16, 2017
California’s Title 24 building energy code is changing the game in lighting and controls in the Golden State and beyond.

Electrical distributors and manufacturers’ reps all across the land should be keeping an eye on California’s building energy code. Distributors and reps in California are naturally well aware of them, because they spend their days dealing with the code’s many requirements for new construction and major renovations. But the state’s Title 24 Building Energy Efficiency Standards, generally known as Title 24, are moving the needle on product development and sales of lighting and controls for commercial and residential construction nationwide.

Title 24 is generally considered the most progressive and aggressive of the prominent building energy codes in the U.S. market. All have the common aim of slashing building energy consumption to a minimum. Many, including Title 24, have the aim of eventually combining efficiency with localized generation to make buildings that consume less energy than they produce (zero net energy buildings) a new normal for construction in general.

Most states in the U.S. use the International Code Council’s International Energy Conservation Code (IECC), while 18 states opt for the ANSI/ASHRAE/IES 90.1 standard. Both are heavily influenced by Title 24. Given the way the Golden State tends to influence trends in the other 49 states the lessons learned in California bear watching no matter where you live.

“Title 24 is sort of the gold standard in energy codes and they have the most stringent requirements that usually start in Title 24 Part 6, the energy code, and make their way into ASHRAE 90.1 or IECC,” says Michael Jouaneh, manager of sustainability and energy standards for Lutron Electronics, Coopersburg, PA.

In fact you’re probably seeing this code’s impact in your market without realizing it. Many of the most recent developments in lighting control systems are being driven by the need to meet the requirements of Title 24 in a way that makes compliance easier for installers and end users. As a result of these efforts the capabilities and ease of use in lighting controls are getting better.

Michael Lunn, senior product manager, Eaton Lighting Solutions, Peachtree City, GA, began his career with the company in field service, where he traveled to California to work with contractors on commissioning controls for factory startups, before moving into sales and then product management where he works on designing and commercializing the systems that must comply with Title 24.

“The changes to Title 24 are really affecting the contractor and the specifier more than they affect me,” he says. “Because we have access to the standards before they take effect, we’re able to see what’s coming and hopefully plan products accordingly, whether that’s new products or new features for existing products. When the rule comes down, installers and specifiers don’t understand, and that gives us an opportunity to make it easy for them by developing the products to basically just meet Title 24. It’s, ‘If you just install this, we’ve done all the back-work to make it compliant for you.’ They don’t have to worry about, ‘Do I have the right pieces and components and programming?’”

This led to new products such as a wireless lighting control system introduced last month that commissions the system to Title 24 standards by drag-and-drop functions on a smartphone app.

Lunn sees ease of Title 24 compliance as the new competitive battleground for lighting controls. “The race is on to see who can create the best widget that is Title 24 compliant and so easy to install that no contractor would think twice about it,” he says.

California’s electrical contractors have been thinking a lot about Title 24, especially over the past three years. Title 24’s history goes back to 1977 when it was created by a legislative mandate to reduce the state’s energy consumption. The standards have since been updated on roughly a three-year cycle to apply new techniques and technologies. The 2005 edition was the first to mandate that lighting in homes be high efficacy or be controlled either by an occupancy sensor or dimmer.

The 2013 edition of Title 24, which took effect in July 2014, modified or introduced a large number of requirements that targeted building lighting and controls. Among the areas most affected were new requirements that controls be capable of handling demand response signals from the utility. It also required daylighting controls that dim lights when sufficient daylight was coming through windows and skylights.

Compared to the 2013 edition, the 2016 version of Title 24 contained mostly incremental changes to fine-tune the existing code on the commercial buildings side but with a few significant changes, especially pertaining to high efficacy lighting and residential buildings. It required that all indoor and outdoor lighting for new homes be listed as high efficacy and set out the performance parameters for being considered high-efficacy in Joint Appendix 8, or JA8. Under JA8, the state now maintains a database of lighting products that meet its standards for efficacy. To sell lighting for new construction and major renovations in California now the products must be listed in the database and, as of Jan. 1, 2017, must carry a mark identifying them as JA8 compliant.

The 2016 version of Title 24 also simplifies lighting control requirements for indoor spaces. Control requirements are now based, in nearly all cases, on the type of lamp or luminaire installed. Any JA8-compliant lamp or luminaire must be controlled by a vacancy sensor or dimmer. The only space-specific regulations regard lighting in a bathroom, garage, laundry room or utility room, where at least one luminaire must be controlled by a vacancy sensor or dimmer.

Title 24 2016 introduced for the first time performance parameters related to lighting quality in its requirements under JA8, including luminous efficacy of 45 lumens/watt or higher, a color rendering index (CRI) of 90 or better, correlated color temperature of 4,000K or lower and minimum standards for startup time, dimming, flicker and noise.

There were changes on the electrical distribution system side in the 2016 code as well, with requirements about circuit design to allow for better measurement and analysis of different kinds of loads in the building.

Title 24 is now an essential part of California’s Zero Net Energy Action Plan, which calls for all new California homes to be zero net energy (ZNE) by 2020 and all commercial buildings by 2030. The ZNE goal puts the standard’s energy efficiency requirements in a different light, says Ted Konnerth of Egret Consulting, Mundelein, IL,whose background includes decades in executive roles with lighting manufacturers.

“It’s kind of like Title 24 is getting to a point of diminishing returns on investment,” Konnerth says. “A replacement for an LED downlight that took it from 100W down to 10W or possibly 5W, and then adding controls onto that to try to save 5W, it’s getting to a point where —controls are not necessarily cheap — does it make financial justification?

“But then again, I didn’t realize California Building Commission’s stated objective is Zero Net Energy in residential by 2020 and commercial by 2030. From that perspective, every handful of watts you pick up reduces the load draw on solar panels, the predominant source they’re driving. The long-term benefit for everybody is a good thing.”

The perception that Title 24 requirements cost more than the savings to be gained has been a frequent concern among customers, says Steve Espinosa, president of The Lighting Co., Irvine, Calif. He has seen an increase in renovations being curtailed, rethought or abandoned to avoid pulling permits that would require compliance with Title 24.

“Especially for the commercial warehouse, if you have a 100,000-sq-ft warehouse and you’re just going to put pallets of material in there, does it make sense for that warehouse to double the installed cost of their lighting just to eke out another 10% savings?

“Do those guys really want to dim the lighting in their facility? Probably not. They don’t mind motion sensors, if someone’s in the area lights are on, if nobody’s in the area lights are off. That technology has been widely used in warehouses for years. But do they want to tie their lighting system into skylights if all of a sudden a cloud goes by, lights go on, then the cloud passes, lights go off. What I think will happen is somebody will override it, they’ll cut the eyeball out and disable it. All the fixtures now all have dimmable capability and it’s not used and they don’t want it anyway.”

Even with such questions rising up around Title 24, electrical distributors have seen opportunity in developing technical capabilities around lighting controls, says Charles Knuffke of Wattstopper/Legrand, whose title is “Systems V.P. & Evangelist.” He has been working in California lighting controls his whole career. “Previously, there were just a few distributors who wanted to know all the nuts and bolts of the lighting control system. All of a sudden you start moving to a systems mentality. Smart distributors, and there are quite a few of them, realized fairly quickly once they started understanding what this change was going to be in 2013, that you can’t just do a little lighting controls.  Just like industrial controls, you’re either in that business or you’re not. That same mentality hit for both lighting and controls. You always had people who were really good at lighting. But now they couldn’t just be good at lighting because it was so intertwined with controls. In California we’ve got distributors that, before, never would have thought about stocking our system products.”

In a broader sense, Title 24 and the other building energy codes have boosted awareness of lighting controls’ ability to improve efficiency. But energy efficiency doesn’t have much of a future if the result is inferior lighting, says Eric Lind, sales V.P. of strategic commercial accounts for Lutron. “We don’t want to lose sight of the fact that buildings are built for a purpose, and usually that’s with people in mind, so what I like about California Title 24 is that they’re really paying attention to that lighting-experience piece.”

Lind also said the California Title 24 standards place the right emphasis on making the requirements cost effective. “I think they have done very good job balancing requirements and solutions that are cost effective so they aren’t hindering adoption.”