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Beginning July 2014, California’s Title 24 2013 building energy code requires formal testing of lighting controls in nonresidential spaces. To date, more than 1000 technicians have been certified. And while the certification process is regulated, the experience and facility of acceptance testers varies widely. Despite the delays in implementation, change comes slowly and contractors and owners have been caught unawares by city inspectors. A project lacking a Certificate of Acceptance cannot be issued a Certificate of Occupancy.

Certified Lighting Controls Acceptance Testing Technicians (aka CLCATTs, or cool cats – yes, really) must be employed by a Certified Lighting Controls Acceptance Test Employer; both certified by a Lighting Controls Acceptance Test Technician Certification Provider. There are two accredited certification bodies: the California Advanced Lighting Controls Training Program (CALCTP, or sometimes shortened to cal-sep) and the National Lighting Contractors Association of America (NLCAA). Both organizations maintain lists of certified employers and technicians.

“CALCTP represents the lighting industry in California, and it is a completely nonprofit and volunteer organization. Classes are free at the utilities’ training centers, and they’re taught at community colleges at the regular community college unit cost,” according to Bernie Kotlier, executive director, Energy Solutions for the California Labor Management Cooperation Committee, a joint effort of the National Electrical Contractors Association and the International Brotherhood of Electrical Workers in California. He is also cofounder and cochair of CALCTP. As expected, many of the acceptance testing technicians (ATTs) certified so far are licensed electricians employed by electrical contractors. “But you don’t have to be an electrician. We’re training electricians, commissioning agents, engineers, lighting designers and lighting company representatives. It’s very much mixed.”

Jack Yapp, senior vice president at NLCAA, describes the curriculum as a mixture of online, in-class and hands-on instruction that is effective in covering the tremendously complex lighting and testing requirements of the code. “The ATT not only has to understand the standards but also needs to be familiar with wide variety of systems and technologies, which reduces the number of people qualified. You have to have 3 years of professional experience and experience with lighting controls and electrical systems.”

Lighting controls testing vs commissioning

CALCTP_acceptance_testing3The services provided by an ATT can cross over into lighting controls commissioning, and the owner or contractor hiring an ATT needs to be clear on scope. Commissioning verifies that individual components of a lighting control system are working together and that their setpoints – footcandles, voltages, timeouts, schedules, etc. – are adjusted according to the owner’s intent. “These actions, adjusting these set points, are done by factory-authorized technicians, someone who is very knowledgeable about specific equipment. That’s the traditional definition. A new definition is a third party, usually, who conducts and writes up the tests to verify that the systems performs according to the owner’s intent,” ATT Rick Miller, president of RNM Engineering, clarified. “The acceptance testing technician, on the other hand, verifies that the lighting controls comply with Title 24, according to tests and setpoints defined in the appendices.”

For instance, an ATT will test to see if occupancy sensors will turn off lights within 30 min of vacancy, according to code. Whereas a commissioning agent will test to see if lights go off as specified by the owner or design team: perhaps 20 min in a fluorescent installation or 10 min for LED. “The commissioning agent is obliged to make sure that the owner gets maximum value from his investment. That’s beyond Title 24,” Miller explained.

If the owner’s intentions for the lighting control systems are documented in advance of construction, then electricians, factory technicians, commissioning agents and ATTs are able to properly install, program, and test the equipment. Detailed design documents are vital in all phases.

“The testing technicians in the field are discovering that projects do not have this documentation. They are discovering that lighting zones are not indicated on the plans. Sometimes the plans do not show occupancy sensors or photosensors, even though the plans have already gone through plan check,” Miller said. “One of the first items on the forms is to verify that the plan complies, with all of the equipment and zoning clearly indicated…. It’s smart for the contractor to engage the test technician at the beginning of the project.”

Start the process with design review

All of the sources interviewed for this article recommended bringing an experienced ATT on board for design review, prior to pulling a permit. When a $500 investment could save $5000 or more in change orders and project delays. “You can at least pick up 60% of issues just in simple plan review,” according to ATT Michael Scalzo, senior project manager at AAA Companies.

“My clients are contractors, general and electrical; architects and sometimes business owners. Most of the time it’s last minute, and they’re asking me to perform acceptance testing or order to obtain their certificate of occupancy,” Scalzo said. “And there’s generally problems with the design and/or the installation and/or the commissioning.”

Lack of information and inexperience are at the root of the problem: “Either the design team or the installer contractor is not properly prepared for the new Title 24 requirements: not understanding the code; how the lighting control systems are supposed to be installed correctly and programmed correctly.”

Instead of just failing the project, Scalzo provides solutions. “Generally, on the next project I will be brought in on the design phase. My business is going heavy into engineer and design consulting, which is the way this whole program was set up.”

According to ATT Lyn Gomes, for projects larger than 10,000 sq ft, or any LEED or CALGreen project, Title 24 requires commissioning, along with documentation, testing and training.

For projects larger than 10,000 sq ft, or any LEED or CALGreen project, Title 24 requires commissioning, along with documentation, testing and training, according to ATT Lyn Gomes, senior commissioning agent at kW Engineering. “The new NRCC [Nonresidential Certificate of Compliance] forms are pretty extensive, and the ones for design review are new,” she said. “Especially for CALGreen, we have been called in to provide emergency documents for a building permit: a commissioning plan and specifications.”

In addition, all nonresidential buildings larger than 10,000 sq ft must be “capable” of automatically responding to a demand response signal from the power company, dropping overall lighting power 15%. Even though the owner is not required to sign up for a demand response program. “Because I have to test this, the contractor has to put in some programming…. But the contractor often doesn’t know that they need to program for demand response and implement control strategies.”

These demand response specifications are also required for design review, when applying for a permit. Gomes reports that the 2016 version of Title 24 will require that acceptance testing be conducted by a third party.

Lois I. Hutchinson

About Lois I. Hutchinson

Lois I. Hutchinson is a freelance writer specializing in lighting and energy issues. She is also the content marketing mastermind behind Inverse Square LLC, a Los Angeles–based consultancy. Contact her via with your comments and any article ideas that concern the lighting community here in the Southwest.

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