The mega-changes to the 2013 edition of California’s Title 24 Building Energy Standards Part 6 took many lighting professionals by surprise and disrupted entire sectors, particularly lighting controls and retrofitters. The changes to the 2016 iteration of the Title 24 commercial lighting standards are far less impactful: somewhat tighter and hopefully a bit more commonsensical in places. For residential spaces, a single dictate for 100% high-efficacy lighting will bring the code that much closer to net zero… without delay.
My conversation with independent consultant Gary Flamm outlined the major lighting changes to Title 24 2016. For 15 years, Flamm served as the lighting lead for Title 24 at the California Energy Commission. He lectures widely on Title 24 and encourages lighting professionals to stake a claim on the code development process.
LIH: What are the goals for the 2016 version of Title 24 Part 6?
G. Flamm: The California Energy Commission [CEC] continues to update Title 24 on a 3 year cycle. For the 2016 code they focused on moving toward the net zero energy goals for the state. All new residential buildings in California must be zero net energy by 2020, and all new commercial buildings must follow suit by 2030. There’s only one more update to the code before 2020, so that gives a sense of urgency.
All Title 24 revisions are intended to align with the ASHRAE/IES 90.1 model code: this year it’s ASHRAE 90.1 2013. Title 24 is equivalent to or more stringent than the model code. The CEC staff analyzes 90.1 requirements to determine if they’re cost effective, technically feasible and energy efficient. In many ways Title 24 is more stringent than 90.1 but still determined by staff to be cost effective, technically feasible and energy efficient. The two codes are getting closer and closer every cycle.
Each revision also cleans up language and mistakes that creep in. Sometimes the language is really unclear or the thresholds are not always consistent. Each version of the code basically gets crash tested by people working with it out in the field, so it’s an ongoing effort to clean up and make adjustments.
LIH: What are the major changes to the commercial lighting code for 2016?
G. Flamm: Well I would always use the term nonresidential because the Energy Commission uses that term. Lots of people say commercial, though.
The big changes to Title 24 2016 focus primarily on residential lighting. It’s dedicated to bringing residential to net zero energy. The nonresidential changes mostly keep up with 90.1 2013.
First, a number of LPDs for different kinds of nonresidential buildings, like restaurants, schools, libraries, etc. were lowered. (There’s a long list.) Because these LPDs were already low, small decreases make a big impact in the challenges of meeting the code.
LIH: Do improvements in LED lighting technology and pricing help?
G. Flamm: Yes, definitely.
The 2016 code revises the timeout for occupancy sensors. For years and years, occupancy sensors were required to turn off lights with 30 minutes. The 2016 code requires a 20 minute timeout.
Also, the energy advocates in 2008 had pushed the limitations to indoor security and egress lighting way down, but there was a lot of resistance. In 2013 they added an auto shutoff provision, but gave egress lighting in office buildings an exception. For 2013 that exception is extended to all buildings and the allowed LPD is raised to 0.1 W/sqft. There were issues with 2013 going too far, so they loosened that up for 2016.
Another thing that changed was an indoor controls issue. Title 24 2013 basically says all interior lights need to be turned off with a time timeclock or occupancy sensor. (The egress lighting in offices is the exception.) In 2016 that can either be a partial-on occupancy sensor or a vacancy sensor in classrooms, conference rooms, small offices and large multipurpose rooms. Occupants in those spaces will need to turn the lights on, or up, and a significant number of people won’t bother. It should save a lot of energy.
The 2016 code tweaks one of the bigger changes in the 2013 code regarding renovations. And restates the question: When does routine maintenance turn into a retrofit?
For many years if you changed out 50 percent of the luminaires in the room, you had to meet the code. For 2013, Title 24 determined that once you change 10 percent of the luminaires, it is now deemed cost effective for you to bring the project up to code. (In fact, 90.1 was the first to propose the 10 percent threshold.)
Also, in 2013, for the first time changing out lamps and ballasts became an alteration that was regulated. Starting in 2013 if you replace lamps and ballasts in less than 40 luminaires, even if you hit 10 percent of the luminaires on that floor, you would not trigger compliance with the code. More than 40 luminaires makes the project a retrofit, and all the LPDs and controls requirements come into force.
Title 24 2016 will keep the 10 percent trigger on luminaire changeouts, but that threshold definition of 40 luminaires will become 70. You’re a retrofitter at 70 lamp-ballast retrofits on one floor in a year. Something else that helps is the lighting control requirements are not as stringent.
LIH: What are the major residential lighting changes for Title 24 2016?
G. Flamm: This is where the Energy Commission put most of its effort because of the pending net zero energy goals. The difference between residential and nonresidential is that lighting power is not regulated according to watts per square foot. Because residential lighting uses layered lighting, it’s not a uniform lighting system, typically. Therefore, lighting power densities are difficult to calculate. Plus in some rooms you only have a switched receptacle.
In residential you classify luminaires as “high efficacy” or “low efficacy.” And in previous codes, a lot of effort went into defining, What is a high-efficacy luminaire?
The designer is required to consider the amount of high-efficacy wattage and the amount of low-efficacy wattage, only in kitchens. Half the lighting wattage in a kitchen must be from high-efficacy sources. The result is that, typically, for every incandescent luminaire you’re installing six compact fluorescent or LED luminaires.
For the rest of the house, the type of luminaire determined what type of controls you had to install. And screwbase sockets were considered incandescent regardless of what kind of lamp you put in them.
So here’s what’s changed in 2016: you no longer have to do any math in the kitchen. Every luminaire in the house must be high-efficacy. But…many luminaires can now use a screwbase LED lamp to classify as a high-efficacy luminaires. The CEC giveth, and they taketh away.
The big restraint is on recessed downlights. Recessed downlights cannot be screwbased.
The JA-8 appendix to Title 24 [note that JA stands for Joint Appendix] currently defines the source efficacy and color and flicker etc. for LED lamps, dedicated LED luminaires and LED retrofit kits. Now the term LED has been purged from the title to make it technology neutral. But the only screwbased light bulbs currently on the market that meet JA-8 appear to be LED.
Most pinbased luminaires do not have to meet JA-8 unless they’re lamped LED. Pinbased fluorescent, compact fluorescent and HID luminaires don’t have to meet JA-8 to be considered high-efficacy.
So, say, if you have a sconce in your new home, you can have a pinbased fluorescent, a hardwired LED luminaire that meets JA-8, or you’re going to have to have a medium-base socket with a JA-8 lamp.
Everything has to be high-efficacy, but in most cases (not downlights) you can use an LED lamp. There is an expectation that consumers are going to love the LED lamps and will insist on them.
LIH: How final is the new code? What is the implementation date?
G. Flamm: It has been officially adopted by the California Energy Commission. It is final. The next step is simply an administrative step, where it will be approved by the California Building Standards Commission, and Part 6 will be published with all of the other subsections of the 2016 Title 24 updates.
It will go into effect for projects where building permits are filed on or after January 1, 2017.
LIH: The 2013 code went into effect 6 months late. Will there be an extension?
G. Flamm: The reason they got an extension for 2013 was the software was not ready for the building industry with sufficient lead time. That is not expected to be a problem this time. It’s January 1, 2017.
LIH: Title 24 is subject to public review and comment. What are some reasons lighting professionals should get involved in the code development process?
G. Flamm: What I see happening is there’s more and more professional industry, paid consultants, now dominating the rulemaking. So the average person does not get their issues heard. Because it is so time-intensive to participate in a rulemaking proceeding, many lighting professionals who could get involved, don’t.
There’s an assumption that it’s a foregone conclusion, and what an individual says doesn’t matter. But that’s not true.
The California Energy Commission has limited resources and limited expertise. You may have a critical piece information or experience from the field. CEC invites all comers. The Administrative Procedure Act requires that the Energy Commission respond to every comment, regardless of the source. If you submit comments during that formal rulemaking phase, those comments become part of the public record and the CEC must respond to your concerns in writing and on the record.
What are useful comments? “I don’t like it” is not helpful or actionable. Your best comment is to question whether the proposed code will always and in every scenario be cost effective, technically feasible and energy efficient? Start with, Does the product exist that can meet code in every application?
Tertiary codes and standards have significant impact. These are cited within codes and used in rulemaking across the world. For instance, getting involved at IES [Illuminating Engineering Society] could change the recommended practice, which greatly influences the Energy Commission. A lot of times, if you are involved with these tertiary standards, you are influencing the code process.
LIH: But why is this important?
G. Flamm: Truth is, if you’re a lighting professional, can you afford not to get involved?
The lighting community has the goal, and the obligation, to protect the “visual experience,” and to keep the energy efficiency advocates from compromising our visual experience. I believe that there needs to be a stakeholder advocacy group for quality lighting, because the other stakeholders have different interests. All of the interests are legitimate, but the process is deficient without a quality lighting stakeholder.
This piece was inspired by Gary Flamm’s seminar at LightShow West 2015:
2016 Lighting Changes to Title 24 Building Energy Efficiency Standards
Though this article is presented as a conversation, it is a product of outlining, telephone conversations and much back-and-forth technical clarification. Thanks to Mr. Flamm for his generous commitment of time and expertise.
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