In this episode, host Aaron Woloszyn IllumeTALKs to Diane Weber about Title 24 and how it has impacted lighting retrofit work in the state of California in recent years.
Bonus: If you can count how many times Aaron and Diane say "Title 24", there's a prize in it for you! Listen to the very end for details, then be sure to submit your guesses to email@example.com.
Get the scoop on Title 24 in Episode 3 of IllumeTALK:
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IllumeTALK, Episode 3: How Title 24 has changed lighting retrofit requirements in California
Aaron Woloszyn (AW): The first iteration of California’s Energy Code Title 24 was released in 1978. However, up until the last decade it never interfered with lighting retrofit work. In last five years that all changed.
Title 24 may sound like the most boring podcast topic on the planet, but to Facility Managers, Directors of Energy, Procurement Specialists and anyone else with a footprint California, Title 24 can play a major role in your organization's lighting and energy initiatives.
Good morning everyone, and welcome back to IllumeTALK. I'm excited to get this episode started because it's going to be a little different than the first two.
Today's topic was actually influenced by a question we received from a listener. They wanted some information on what they referred to as “the headache that is Title 24”. So, today we're going to be talking about California Energy Code, Title 24.
I'd like to first introduce my resident Title 24 expert, Diane Weber. Good morning Diane!
Diane Weber (DW): Hi, Aaron. How are you?
AW: I'm good how are you doing.
DW: Very good.
AW: Diane has been in the lighting industry for the better part of two decades now.
DW: Oh my gosh!
AW: Yes – long time.
DW: Thanks. Thanks for that, Aaron.
AW: You’re welcome.
DW: I was 12 when I started. Just to set the record straight.
AW: OK. We'll go – we'll go with 12. So, when I first brought this up with you… you were pretty excited about talking about Title 24. I'm not sure many would be, but you were very excited. Why was that?
DW: It's been a little bit of a passion for mine for the better part of two years. There is more and more information available today than there was when I first started learning about it. It's growing in importance and I wish I had something a little bit easier to digest, and hopefully fun, to listen to as I'm cruising down the highway that I could use to help me understand.
AW: OK. So with that being said, what are you hoping listeners take away from today's episode?
DW: Really just some basic information for those that maybe have heard of Title 24, but don't have a lot of the details. I'd like to be able to provide some quick points of reference and a little bit of the history of it – and just make sure that they understand that it's not a massive headache, not anything that you need to be terribly scared of.
AW: So, energy code, as you know, can be complicated. Let's do our best to keep this as simple as possible.
DW: I'm on with you.
AW: All right. OK. So let's start with the basic definition. How would you define Title 24?
DW: Title 24 is the building standards code in the state of California.
DW: It's part of the California Code of Regulations which is a government document that has 28 Titles, or headings, to it. Title 24 is the 24th of that, and it's put out by the California Code of Regulations, also known as CCR.
DW: Not to be confused with another CCR, which is a band from California that I'm sure you're familiar with.
AW: You know I'm not though. We always – we always talk about this. I'm not good with music.
DW: Alright. After the podcast wraps well we'll do a listening session on some CCR. Get you educated.
AW: Are you going to tell me who it is, or are you going to make me wait?
DW: We'll wait.
AW: Alright, so just to reiterate – Title 24 is merely the 24th heading of all the 28 titles in the California Code of Regulations.
AW: OK. So when someone in our industry is referring to Title 24 What are they referring to?
DW: So in our industry people who speak about Title 24 aren’t speaking about the whole California building code. They're actually speaking particularly about one part which is Title 24, Part 6 – which is energy code that is put out by the California Energy Commission. And for you and I, and our business, we're more concerned with the non-residential sections of Title 24, Part 6.
Music Transition to Segment 2
Title 24 Lighting Retrofit Requirements of California
AW: So, before we get into the positives that this energy code brings, why do most view Title 24 as a headache?
DW: Well, it is government bureaucracy at work and there's a lot of people who are averse to that right off the rip. And California does have a lot of bureaucracy – we hear a lot about what happens in California and it gets kind of conflated with what the truth is. But, when we talk about Title 24 and we want to understand what is required, it does add more time and more money to execute a Lighting Retrofit project in California when you're following Title 24. And the reason for that is that what you and I rely on when we do lighting quotes is basically lighting audit data. We go out and we do a survey; a lot of times we're working retail spaces so we'll go out and survey a group of stores and that gives us our baseline. And we come back with some LED upgrade options for the customer; and that's what we use in order to justify and provide an ROI for our program.
AW: So how is it different with Title 24?
DW: With Title 24 you actually have to work from building plans, and our customers don't always have building plans. You've probably talked to customers…
AW: Mmhmm, that that's true.
DW: (thought continued) … that have no idea where their plans are, or they're horribly outdated. So we actually have to have some sort of a reflected ceiling plan, some sort of a lighting plan, to use in order to demonstrate compliance with Title 24 to local permit office. So we not only need those lighting plans we now need a permit application. We're also going to need compliance documents for Title 24; and then on the back end of a project, we're also going to need to have a compliance acceptance tester go out and make sure that we did all the things that we said that we were going to do in order to be compliant with Title 24 so that does take time and that does take money. And whenever you talk to customers about money that does impact our ROI
AW: That does seem like a lot of added work for the retrofit business – especially when you consider how relatively simple retrofitting has been for the last 30 plus years.
DW: Yeah, I mean we've seen just the straight lamp and ballast retrofits from 2013 on – that code language was now impacting that business. The business of retrofitting was now a trigger for Title 24. So what is basically almost like a maintenance up keep – you'd change out the lamp, you change out the ballast, maybe you put in a new retrofit kit, hopefully you're going LED at this point – but those things are now considered “luminaire modifications in place” and that does trigger Title 24, and the compliance that comes with it.
So typical controls that people were seeing with retrofit projects over the last 20 plus years, like occupancy sensors, EMS is very popular right now – Energy Management Systems are in the majority of commercial spaces that we generally occupy. Those things are pretty basic.
DW: But Title 24 brought in more advanced controls, like multilevel controls, with LED that requires dimming systems. That's something that is not always a consideration for people doing lighting retrofit work. You also have daylighting that's going to be impacted when you bring in retrofit work under Title 24, So now you've got a retrofit of fixture but you're going to have some impact on that fixture if it's near a window or a skylight. Also, you have a requirement for demand response for spaces that are over 10,000 square feet. So you've got to find a way to load shed 15 percent of the energy from that lighting system through a demand response signal that's going to be sent out by the utility.
So these are things that, they do add complexity to the scope of work, and it is possible that people are going to be quickly overwhelmed because they've never really had to do this.
It was something for new construction but not something for the retrofit work itself. So, on both sides of the equation you'd have code officials and you have people on our side that are wondering how this impacts it.
AW: So, it affected both sides really
DW: It did. Yeah. You had a lot of outreach that the California Energy Commission did prior to Title 24 coming online. You and I heard about it before it happened, and people were trying to get as educated as they possibly could.
AW: I can see why. I mean there's a lot to consider.
DW: We actually had a story that – I don't know if it's true or not – but I heard a story…
AW: Oh boy here we go.
DW: …that there was a contractor that went with a compliant packet for Title 24, went up to Modesto to file it and he was never seen or heard from again.
AW: The missing contractor!
DW: That's right.
AW: So, coming to Netflix this fall – Title 24 paperwork and the missing contractor.
DW: It could happen!
Music Transition to Segment 3
The History of Title 24 Lighting in California
AW: I know some changes were brought about 2016 to help alleviate these pain points. Let's quickly touch on those. Can you explain what took place?
DW: Yeah, so after 2013 the California Energy Commission fielded over 300 public comments – specifically about the things that got written into the 2013 code and the ways that it impacted the retrofit market in California.
A lot of people in the lighting industry were hoping for a removal or a redefinition of “modification in place” so that it wouldn't impact lighting retrofits as severely as it did in 2013.
AW: But the language wasn't removed, was it?
DW: No it was not removed. They kept that in place. But what the California Energy Commission did do is offer an alternative compliance path to alleviate some of the control burden.
AW: So these compliance paths were created to help retrofit fitters meet the newer code without having to go with a full blown compliance package.
DW: Exactly. So what the CEC was able to determine after 2013’s public outcry and some further evaluation of the code, is that they actually were able to get greater energy savings by mandating certain thresholds for reduction in energy instead of doing the additional controls that they were required.
In other words, if you're able to demonstrate through Title 24 that you're reducing by at least 50 percent the energy in a hotel, office or a retail space, and at least 35 percent reduction in energy and all other occupancies, you can actually avoid having to do the multilevel control, the daylighting and the demand response.
AW: What kind of impact did this have?
DW: We actually saw it work very successfully for our customer about two years ago that did not want to implement any additional controls, because they wanted to keep as streamlined a solution throughout their stores in California and outside of California. So, instead of doing those additional controls we were able to tweak a little bit of their lighting package so that they were able to save at least 50 percent; and they only had some minimal occupancy sensors and some minor adjustments to their energy management system in order to comply.
AW: So the 50 percent path was basically perfect for them?
DW: It was. It was it worked well.
AW: There seem to be a lot of success stories and positive outcomes with Title 24. Title 24 obviously wasn't created to be a burden – the idea here has always been energy efficiency
DW: Yes, and in fact, we can have some level of confidence that what's written into Title 24 is there because it is economically feasible to save energy using the methods that they've described, and have mandated in that code. It offers essentially a way to implement best practices for energy savings, and gives customers the peace of mind in knowing that they are doing everything possible to be as energy efficient as they can be.
AW: One of the reasons, and please correct me if I'm wrong, that we look to California's energy initiatives is because what happens in California doesn't always stay there, does it?
DW: That's right. So, California has done a great job of demonstrating to the rest of the country what's possible and they've done that through a lot of outreach, education and enforcement. One of the things that we watch closely is the ways in which ASHRAE ninety point one which is put out by the American Society of Heating Refrigeration and Air Conditioning engineers.
AW: Good job.
DW: Thank you. How ASHRAE 90.1 as a standard closely aligns with Title 24 part 6 and the rest of the country's energy codes are following that ASHRAE standard as they write and update their own energy codes. So, it's a matter of seeing what California has done, seeing the goals that they've set – and those goals that they've achieved – and other states looking to achieve similar goals.
AW: Do you know of any other goals offhand?
DW: One of the big ones for California is their goal of zero net energy by 2030. That's for all new buildings, but they also want to achieve zero net energy in 50 percent of their existing buildings by 2030. So, that's a pretty high benchmark for them to meet, but they're going to be able to meet that through initiatives like implementing Title 24 for retrofit and remodel projects.
AW: So with everything we've just spoken about – especially the compliance paths which make it easier to stay within energy code – does Title 24 honestly have to be that scary?
DW: It doesn't. When you think about code and what it's morphed into over the last few years you do see that yes it is written, and a lot of the language is geared towards new construction, but at the permit office two thirds of the applications are actually filed for remodels and retrofits.
AW: Two thirds?
DW: Yeah. So if you're actually doing a retrofit and doing all of the requirements for Title 24 you're in the majority of the rest of the people that are down there filing for permits as well.
AW: So, what happens next? I know the 2019 code was adopted, but those changes won't take effect until 2020. What changed with 2019?
DW: So we don't see the major changes like we did in 2013 with the modification in place language, or 2016 with the alternate compliance path. But Title 24 part 6 for 2020 does incorporate some of the things that ASHRAE is doing as well with the lighting power densities. They're now treating LED as more of a baseline and that drives overall energy efficiencies to lower watts per square foot thresholds than they previously were seeing. And for new construction projects that don't take the 50 or 35 percent reduction path, those lighting power densities are going to come into play for compliance.
AW: I think we've covered quite a bit. So why don't you give me a final thought on Title 24, and his overall goal of energy efficiency?
DW: So California sets the stage for the rest of the country. What they've been able to do through enforcement, education and outreach is showing other states what they can do with their codes, and what comes next with ASHRAE 90.1. And what we need to continue to keep in mind is that as energy code advances, there's going to be more and more training available to the code officials and to the people who are designing lighting systems and control systems in order to help them along in this process.
So being as open to the change that will come through advances in energy code will breed the type of optimism that we want in our industry and in the world.
AW: So finally, are you going to tell me who CCR is?
DW: So, yeah – aside from the California Code of Regulations…
AW: Of course.
DW: CCR is band from late 60s / early 70s – Creedence Clearwater Revival.
AW: Ohhh I've heard of them.
DW: You have, yeah. So you know like “Looking Out My Backdoor” and “Proud Mary”…
AW: I know the first one. I'm not sure about Proud Mary, or who she might be…
DW: Seriously? Oh my gosh. All right.
AW: Unless you want to sing it for me.
DW: We'll go to iTunes right now and play it.
AW: OK. Diane thanks for joining me.
DW: Thanks for having me!
AW: I honestly didn't think we could make Title 24 interesting but I think we may have done it.
DW: That's great to hear.
AW: That concludes our IllumeTALK for today. Thank you all for listening in.
If anybody has any questions, please feel free to reach out to me or any one of my colleagues on LinkedIn. As you can see, Diane is a true lighting and energy nerd – she loves talking about this stuff so don't hesitate to reach out to her directly.
You can also contact us though our website – illumetek.com. That's I-L-L-U-M-E-T-E-K, And for additional podcasts news and updates, be sure to follow a illumeTALK on Instagram. That’s I-L-L-U-M-E-T-A-L-K
DW: And we'll also share some great resources some links to some sites in California that you can visit to learn more about Title 24.
California Energy Commission -
2016 Energy Standards: https://www.energy.ca.gov/title24/2016standards/index.html
Staff Report on alternative compliance for 2016: https://efiling.energy.ca.gov/GetDocument.aspx?tn=210938
Energy Standards Hotline: 800-772-3300
Education & Outreach -
Energy Code Ace: https://energycodeace.com/
SDG&E Energy Innovation Center courses: https://www.sdge.com/energy-innovation-center/education-training
UC Davis California Lighting Technology Center: https://cltc.ucdavis.edu/
AW: IllumeTALK is a production of Front Porch Media. A special thank you to our producer Brigid Coyne, our audio engineers Eric Koltnow and Dave Douglas. To learn more about this and other podcasts, please visit the thefrontporchpeople.com.
For those of you listening, the first person to send me an e-mail or a message on LinkedIn or contact me in any way with the correct number of times that Diane and I said “Title 24” in this podcast will get a special prize from me!
Thank you for listening.