California’s mandatory Title 24 standards include tough energy efficiency requirements for commercial lighting retrofits. In this blog, our Don Barnetson will explain how plug-and-play LED lightbulbs make meeting retrofit requirements simple.
Title 24 defines a broad set of building performance metrics that apply to buildings under construction or renovation in California. Of specific interest to lighting is the mandatory lighting control and dimming requirements that the latest version of Title 24 imposes.
In the case of new construction, Title 24 requires occupancy sensing, daylight harvesting and the capability for automated demand response (ADP) that forces a building-level lighting control system at a typically installed cost of $2 – $6 per sq. ft.
For an existing building, where only an energy retrofit is desired, these requirements would generally make that retrofit non-economical, thus it is critical to understand under what conditions lighting retrofits can trigger Title 24 mandates.
Table 1. What you can Change
See attachment:
Enlarged version of Table 1 for detail
Retrofit Option 1: Upgrade with Ballast Driven LED Lamps
Ballast driven LED lamp upgrades do not require a building permit or skilled labor to implement; thus they do not trigger any Title 24 action for an existing building.
Retrofit Option 2: Upgrade with Ballast Bypass Fixture Upgrades
Ballast bypass LED lamp upgrades, where the ballast is removed and the line voltage is brought directly to the lamp sockets, are considered Luminaire Modifications-In-Place by Title 24, 2013.
Table 2. Depending on how many fixtures you modify in a calendar year – you can trigger a variety of different requirements:
Situation | Result |
If less than 40 fixtures per building space (whole building, floor of building or a suite on a floor) | No impact provided if power is equal or less |
If more than 40 fixtures are modified with the resulting power less than 85% of allotted power under prescriptive lighting measure (0.75 W/ft. for open office) |
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If more than 40 fixtures are modified with the resulting power more than 85% of allotted power under prescriptive lighting measure (0.75 W/ft. for open office) |
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See attachments:
Table 141.0-E Requirements for Luminaire Alterations
Table 141.0-F Requirements for Luminaire Modifications-in-Place
Retrofit Option 3: Luminaire Alterations
If you move, replace or remove luminaires; you trigger an enhanced level of scrutiny called Luminaire Alterations. This essentially brings the full force of Title 24, 2013 to bear on your building space. With existing controls technology this is likely to make your retrofit project non-economic.
- Luminaire Alteration at <85% of power density triggers: Area controls (light switch), 4 step or linear dimming, automatic shutoff (occ. sensor or time clock) and demand response
- If you go above 85% of power density then you can add in daylight harvesting
See attachment:
Lighting Retrofits: Luminaire Alterations vs. Luminaire Modifications in Place
Final Thoughts
- If you use ballast driven LED lamps, you do not trigger Title 24, as you are not pulling a building permit or making modifications to your building. You are simply replacing a lightbulb.
- If you choose ballast bypass lamps, you are limited to retrofitting up to 40 fixtures per building space per calendar year, so long as the retrofitted fixture draws less power than what you are replacing.
If you retrofit more than 40 fixtures per building space per calendar year, you will be mandated to add a substantial control system, which will tend to make the LED retrofit non-economic with current controls technology.
- If you move, remove, or replace fixtures, you trigger the full Title 24, 2013 code to bear, likely making your retrofit non-economical.
Therefore the simplest, most economical way to retrofit to LED lamps, with the accompanying energy and maintenance savings, longer life and improved quality of light LEDs deliver, is to use plug-and-play ballast-driven LED lamps.
Please refer to the attached Title 24 section .pdfs for more information:
- Lighting Retrofits: Luminaire Alterations vs. Luminaire Modifications in Place
- Table 141.0-E Requirements for Luminaire Alterations
- Table 141.0-F Requirements for Luminaire Modifications-in-Place
- Enlarged version of Table 1 for detail
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