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Nonresidential Lighting

Codes and Standards Enhancement (CASE) Report

The Statewide CASE Team is requesting feedback on the 2019 Title 24, Part 6 Draft CASE Reports. The CASE Report presents pertinent information that supports the code change proposal. Please email feedback to You may also submit written comments to the Energy Commission. See the agenda for Energy Commission pre-rulemaking workshop (available here) for instructions on how to submit comments to the Energy Commission’s docket.

Draft CASE Report: Nonresidential Lighting Alterations

Measure Description

The Statewide CASE Team developed a spreadsheet-based model to provide a tool for the Energy Commission to perform a transparent analysis of the energy impacts from potential changes to the nonresidential lighting alteration requirements. This tool can be used to evaluate changes that may be proposed by various stakeholders throughout the 2019 Standards rulemaking. In this report, the model or tool is referred to as the alteration analysis or the alteration model. The spreadsheet is expected to be available to any stakeholder upon request. This report provides technical documentation for the alteration model (version v1.0b).

The alteration model assesses the relative energy savings resulting from each of the three prescriptive options to comply with Title 24, Part 6 nonresidential lighting alteration requirements. Specifically, the alteration model quantifies the effect of lower 2019 lighting power density (LPD) levels on energy savings from nonresidential lighting alterations for the entire luminaire and component modification retrofit types. The effects of the measures proposed in 2019 CASE Report on Indoor Lighting Controls (i.e., full OFF occupancy controls in restrooms and dimming to OFF for automatic daylighting controls) are also included in the alteration model.

In addition to developing the alteration model, the Statewide CASE Team is proposing several specific code change measures that will affect one of the options to comply with the current nonresidential lighting alteration requirements (i.e., Option 3). The developed alteration model was used to calculate the expected per-unit and statewide energy savings resulting from one of these proposed measures (Measure G that would require a reduction of existing lighting wattage by 50 percent of the rated wattage under Option 3 for all building types).

Lastly, this CASE Report includes several proposed code cleanup measures that are intended to clarify the nonresidential lighting alteration requirements.

Request for Feedback

The Statewide Utility Team encourages participation in the CASE Report development process through the submission of data—both primary sources and references to existing data. We are requesting data on areas such as energy savings, costs, market impacts, industry practices, barriers to code compliance, etc. from stakeholders. The data will inform the energy savings estimates, cost-effectiveness analysis, compliance and enforcement, and market impacts that will be presented in CASE Reports. Do you have feedback or data to share? Send us an email at

California Statewide Utility Codes and Standards Program

This program is funded by California utility customers and administered by Pacific Gas and Electric Company, Southern California Edison, San Diego Gas and Electric Company, Southern California Gas Company, Sacramento Municipal District, and Los Angeles Department of Water and Power in preparation for the California Energy Commission’s Codes and Standards Buildings Advocacy.