California’s 2019 Title 24 mandated updates go into effect January 1, 2020.

What’s new in non-residential regulations?

(1) More stringent controls on existing building lighting alterations

(2) Consolidation of demand response controls and demand management requirements into a single new section 

(3) Requirement that all restrooms install occupancy sensor controls

(4) LPD requirements are now based on LED lighting

 For a breakdown of terminology, here’s the full 2020 California Title 24 Non-Residential Lighting Key Changes guide.

“Lighting is one of the biggest changes with non-residential standards,” notes Brian Selby of Sacramento-based Selby Energy. “Rules are more stringent.” Selby detailed updates in commercial lighting regulations, including new lighting power allowances.

“Allowed watts per square footage is lower now,” Selby explained. “The lighting power density (LPD) requirements are now based [entirely] on LED, not fluorescent, lighting.”

What’s coming in 2020 includes the addition of Group 1 medical facilities to T24 requirements (only Group 1-2) and a new code section grouping all demand responsive controls and demand management requirements. Section 130.1(a) now mandates that a manual area control must be in the same enclosed area unless an exception applies.

Restrooms must have occupancy sensors, classroom minimum control steps are relocated to a different code table and the Energy Commission added a minimum control step regardless of luminaire type for library stack aisles, aisle ways and open areas in warehouses, parking garages, parking areas, loading and unloading areas, stairwells and corridors.

Look for new exceptions for daylit zones, which the code defines as “areas under skylights that existing adjacent structures or natural objects block direct sunlight…[and] [a]reas adjacent to vertical glazing below an overhang that covers the entire width of the vertical glazing.” 

Retail merchandise sales and wholesale showroom areas now have an exception for Sidelit zones. There’s also a new code section called Controls Interactions, which regulates how controls interact with each other. Under section 130.2, the motion sensor requirement exception changes to 40 watts for all luminaires. Motion sensor reduction changes to 50-90 percent and must now be separately capable of turning a luminaire off.

The new energy controls stipulate that: “Automatic scheduling controls (time clock) shall allow scheduling of a minimum of two nighttime periods with Independent lighting levels.”

Additionally, code section 130.4 says that health care facilities must comply with OSHPD. As Selby noted, LPDs are drastically reduced by 40 percent. Three new Lighting Power Adjustments include Clearstory, Horizontal Slats, Light Shelves (No AT). Section 141 designates three new methods for determining alteration requirements.

California’s Title 24 code is effective on January 1, 2020. Read the complete code here.

When asked about how today’s builders, designers and planners may overcome code-related obstacles, Selby said that the biggest challenge is for smaller projects that don’t necessarily have a designated lighting contractor. 

“Sometimes, they get to the end of the job and the building inspector asks for a certificate — and no one knows who’s responsible,” he observes.

The head of one of the agencies that certifies acceptance test technicians, Michael Scalzo, who runs the National Lighting Contractors Association of America (NLCAA), said that interpretation and education are the main challenges with Title 24. 

“There’s a lack of education from the end user to the acceptance tester,” Scalzo noted, “and there’s misunderstanding. People interpret codes to their advantage. For example, under daylighting controls, there’s an exception that states that if you get below a LPD, you don’t need controls—but some interpret that as not needing any control. Then, when the acceptance tester comes out, they run into this problem.”

Scalzo observes that end users generally don’t understand government lighting controls. 

“People want to disconnect [dimming] lighting near a window because they think it’s malfunctioning. Also, people don’t understand the control that automatically shuts off lights. In office areas, lobbies, conference rooms, kitchen areas in office spaces and copy rooms, you have to have a controlled outlet within six feet of an uncontrolled outlet, so they’ll have a duplex receptacle that’s activated by a time clock or occupancy sensor. Sensors are allowed to go for 20 minutes. The intent is to save energy. So the computer will stay on but the lights turn off.”

Scalzo sees understanding work habits as pivotal. “You walk into your office like you’ve always done and lights don’t automatically come on—you walk out and lights shut off. You might think the device is broken but this is caused by regulation. So, you might have it replaced. Or you think the device is broken when you walk into your office and lights come on at 50 percent capacity.”

The Energy Commission’s founding goal, Scalzo and Selby point out, is to reduce energy. Conservation is the premise of California’s lighting controls. 

“The [government’s energy] code states what amount of energy is allowable,” Scalzo said. “It’s all about controlling energy based on wattage per square footage.”

Key 2019 Energy Code Changes

100.00 The addition of Group 1, medical facilities to the T24 requirements (only Group 1-2)

110.9 Code section name change, covers devices and systems in lieu of Title 20. Added devices.

110.12 New code section: these changes consolidate all demand responsive controls and demand management requirements throughout Part 6 into a single new section. 

130.1(a) The Manual area control must be in the same enclosed area unless an exception applies.

130.1(b) Restrooms and health care are excluded from multilevel lighting requirements.

Classroom minimum control steps are relocated to Table 130.1(a)

Added minimum control step regardless of luminaire type for library stack aisles, aisle ways and open areas in warehouses, parking garages, parking areas, loading and unloading areas, stairwells and corridors found in 130.1(a) Table.

130.1(c) Restrooms shall have occupancy sensors.

130.1(d) New exceptions for daylit zones; areas under skylights that existing adjacent structures or natural objects block direct sunlight. Areas adjacent to vertical glazing below an overhang that covers the entire width of the vertical glazing.

Retail merchandise sales and wholesale showroom areas now have an exception for Sidelit zones.

130.1(e) Relocated to 110.12

130.1(f) New code section: Controls Interactions. Details how controls interact with each other.

130.2 24’ motion sensor requirement exception change to 40 watts for all luminaires. Motion sensor reduction change to 50-90 percent and separately capable of turning luminaire off.

Automatic scheduling controls (time clock) shall allow scheduling of a minimum of two nighttime periods with Independent lighting levels.

130.4 No Acceptance Testing. Health care facilities must comply with OSHPD.

140.6 2019 LPDs drastically reduced by 40 percent.

Three new Lighting Power Adjustments; Clearstory, Horizontal Slats, Light Shelves (No AT).

141.0 Three new simplified methods for determining Alternation requirements

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