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Nonresidential Lighting Clarification and Controls

Measure Description

This CASE report provides the rationale for the adoption of the following changes to the California Energy Code which simplifies, clarifies and provides compliance credit for inexpensive and effective control strategies.

  • Section 100.1 A definition of “initial design illuminance” is added to support the required activities to qualify for a Power Adjustment Factor for “High End Trim Tuning of Dimmable Lighting in Section 140.6(a)2H (see below).
  • 9(b)3. This would add clarifying language to the lighting controls requirement that the flicker requirement applies to entire dimming system (control, lamps and ballasts or drivers) and not just the controls. It also references a flicker test method in reference Joint Appendix JA10. The details of this test method and rationale were also contained in the Residential Lighting CASE report. It is repeated here for completeness.
  • Section 130.1(b)3. This proposed change would replace a hard to enforce, confusing portion of the multi-level lighting controls requirements with a simpler requirement which is easier to enforce. The confusing portion has a requirement to pick one out of five requirements for each enclosed area in addition to all other requirements. However two of the requirements (manual dimming control and demand response) are already required in many situations. The proposal would require clarify the requirement that most commonly applies (manual dimming controls for dimmable luminaires). This will simplify and render this section more enforceable.
  • Section 130.1(d)2D. More clearly state the requirements for the accessibility of calibration adjustment control for photocontrol (daylighting control) systems. The primary purpose of this requirement is to prevent tampering with the photosensor and to have the calibration controls readily accessible so that adjustments to daylighting controls can be easily performed by authorized personnel in response to changes in geometry or reflectance of the interior, changes in occupancy or tasks and in response to requests for more or less light from occupants.
  • Section 140.6(a)2H. Remove the PAF for Partial-ON Dimming Controls (now a mandatory requirement) and replace with a description of the requirements of the Daylight Dimming Plus OFF controls. It should be noted that ASHRAE 90.1-2013 contains a mandatory requirement for daylighting controls that turn lights all the way OFF when the space is fully daylit. This proposal is a halfway step towards having daylighting control requirements as stringent as found in ASHRAE 90.1. Ideally this PAF prepares the market for this control strategy being the default or mandatorily required in the 2019 Title 24 standards.
  • Section 140.6(a)2J. Replace the description of Manual Dimming or Multiscene Programmable Dimming System controls that qualify for a PAF with the description of Manual Dimming Controls with High end Trim Tuning controls that qualify for a PAF. This section also notes that the initial design illuminance must be on the construction documents and that high end trim must be tuned so that it is within 10% of the initial design illuminance as verified by the acceptance tests as contained in nonresidential appendix NA7.6.4.
  • Table 140.6-A Remove two Power Adjustment Factors in Table 140.6-A for Partial-On controls and dimming system controls. The rationale for removing these PAFs is contained in the Nonresidential Lighting Controls Partial-ON Occupancy Sensors CASE report. These changes are included in the proposed changed code in this report for ease of understanding how the proposed changes from both CASE reports would impact this table and this section
  • Table 140.6-A Add two Power Adjustment Factors in Table 140.6-A for daylight dimming plus OFF control and tuning of dimming systems.
  • 7.6.2 “Acceptance Tests for High End Trim Tuning of Dimmable Lighting.” This new acceptance test is added to verify that lighting systems claiming the High End Trim Tuning Power Adjustment factor have tuned the lighting system appropriately.
  • JA10 Test Method for Measuring Flicker of Lighting Systems and Reporting Requirements. This test method quantifies the long standing requirement of “low flicker operation for dimming systems. See also the clarification of dimming requirement in Section110.9(b)3.

This proposal interacts with and builds upon the Residential Lighting and the Nonresidential Lighting Controls Partial-ON Occupancy Sensors CASE reports. The full citations for the Residential Lighting and the Nonresidential Lighting Controls Partial-ON Occupancy Sensors CASE reports can be found in the References Section of this report.

The following documents will be modified by the proposed change:

  • Main text of Title 24, part 6
  • Nonresidential Standards Appendix NA7 (acceptance tests)
  • Nonresidential Alternative Compliance Method (NACM) Manual.

Stakeholder Meeting

Several stakeholder meetings and CEC staff workshops were held regarding the Lighting Clarification and Controls building energy efficiency topic. The list of past meetings and hearings can be found here.



  1. Final CASE Report

Give Us Your Feedback

The Statewide CASE Team values input from all stakeholders engaged in the Title 24, Part 6 code change process. We encourage the open exchange of code change comments and concerns.

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