From Guest Blogger Dr. Bulb: California’s Title 24 – Is It Actually Conserving Energy?

A public school district in California had no choice but to cancel a necessary lighting upgrade due to strict energy codes. Because of this, the local schools will be stuck with the same inefficient and ineffective lighting that was installed decades ago. This decision will affect many, but most importantly, it will affect the students.

State energy codes are meant to encourage and enforce property managers to choose the most energy-efficient options available in a time when environmental conservation and the consumption of resources is becoming a global concern. Unfortunately, some of the new regulations can become so cumbersome and expensive that it prevents buildings from making necessary updates. This is the problem in California with Title 24. While the original regulations encouraged energy conservation, the new regulations may be preventing it.

The California public school district in question initially approved a lighting retrofit that was accepted under the original Title 24 regulations. However, additional requirements in the updated Title 24 regulations made the retrofit much more expensive and, without significant energy savings, forced the school district to cancel the upgrade. Sadly, this is also the case for many other properties in the state.

Prior to the latest update, Title 24 had separate requirements for retrofits and new construction. This was logical simply because new construction projects would already require brand new lighting and control products, whereas retrofits have existing lighting and controls that can easily be updated to become more energy-efficient. The recent update, however, treats retrofits and new construction nearly the same, which has led to lighting retrofits that cost 20%-30% more.

For example, the latest Title 24 regulates T8 LED tube lights (TLEDs). These lights are meant to be energy-efficient alternatives to fluorescent lamps. Retrofitting existing fixtures with reduced wattage fluorescent T8 lamps or TLEDs, while keeping the existing ballast, does not trigger Title 24. Retrofitting with TLEDs that do not require a T8 ballast is more reliable, yet this triggers the new Title 24 regulations and associated expense. Property managers may be forced to choose inferior solutions that are cheaper in the short term because they cannot handle the additional financial burden.

With Title 24, dimming and controls are often required, even if they’re not cost effective for the building. Imagine an office building where employees habitually turn off the lights immediately when leaving the room, like many tend to do. Occupancy sensors allow a 10-15 minute delay before the lights turn off. In this case, occupancy sensors would actually waste energy, due to the fact the lights are on for longer than they need to be. Furthermore, current LED and high performance fluorescent fixtures require so little energy that occupancy sensors could have a 15-year payback.

Even rebates that typically serve as incentives aren’t as attractive under Title 24. Customized rebates based on kWh saved do not provide the same savings since existing wattage is not considered to be what it actually is on the property. Instead, Title 24 sets a maximum allowable amount. The higher cost discourages property managers from implementing updates to make their buildings more energy-efficient.

Consequently, energy-saving projects are being shelved, which ultimately leads to a significant reduction in business for electrical contractors and suppliers in California. Energy codes as strict as Title 24 negatively impact businesses and schools. It can be argued that more energy would be saved without Title 24, because many of the specific regulations potentially waste more energy than they actually save, while a number of property owners simply cannot afford the extra expenses for Title 24 compliant projects. These property owners have no choice but to use outdated energy-hogging lighting systems in their buildings.

Energy codes are necessary in today’s world, but it is critical that they are carefully planned and within reason. Energy codes that make it impossible to update to energy-efficient lighting are only contributing to the problem.