A reminder that Title 24 Title 20 in California – which impacts all lighting manufacturers doing business in the Golden State – takes effect starting January 1, 2017.

When lighting industry members talk about legislative changes, the phrase, “As California goes, so goes the country” is often intoned. Indeed, for the past 10 years California’s regulations have significantly impacted (some say inconvenienced) lighting manufacturers as well as retailers — not to mention consumers. From the mass conversion to CFLs in kitchens, bathrooms, and ceiling fans to the upcoming state-wide regulation concerning “high-efficacy” bulbs in all lighting fixtures and portable lamps, California has served as a major proponent of change in the industry.

The Pros

Here’s how it began: The Codes and Standards Enhancement (CASE) initiative presented recommendations to support California Energy Commission’s (CEC) efforts to update the state’s Building Energy Efficiency Standards (Title 24) to include new requirements or upgrade existing requirements for various technologies.

Who thought this was such a great idea? The four California Investor Owned Utilities (IOUs) –
Pacific Gas & Electric Co., San Diego Gas & Electric, Southern California Edison, and Southern California Gas Co. – plus the Los Angeles Department of Water and Power (LADWP). The program’s goal of implementing cost-effective changes to make buildings more energy-efficient is certainly understandable. After all, this was a state that instituted “rolling brown outs” (i.e. preplanned and controlled blackouts) in the peak of summer not that long ago as an emergency measure.

The Residential Lighting proposal updates Section 150.0(k) to require the use of high-efficacy lighting in all residential new construction applications — including single family residences and low-rise multi-family residential buildings, as well as units within high-rise multi-family buildings. It also eliminates the exception that allowed low-efficacy lighting in combination with controls.

What constitutes a “high-efficacy” luminaire for residential application? The official definition is: “any fixture installed with high quality, high efficacy lamps, regardless of base type (including screw-base lamps) as long as they comply with quality and high-efficacy requirements in the revised Reference Joint Appendix 8 (JA8). Or, as American Lighting Association’s (ALA) Director of Engineering & Technology Terry McGowan puts it, “Basically, it’s all LED — even CFL doesn’t meet the requirement.”

The Cons

Unlike the original Title 24 regulations that required lighting in the kitchen and bathroom to be high-efficacy and allowed low-efficacy elsewhere if controlled by dimmers/vacancy sensors, the new revision that takes effect starting in January applies to all of the lighting in the home — even portables.

Having every luminaire and portable being lamped with LED certainly puts the onus on manufacturers to make these changes if they want to continue selling their products in California. The authors of the revision do not see this change to be a great hardship for manufacturers, as the report states: “Revised JA8 requirements may also increase the product testing and labeling burden on manufacturers, but manufacturers are already routinely testing their products to meet various standards, and the proposed measures primarily reference existing testing protocols. Most of the testing requirements match those in the ENERGY STAR Product Specification for Lamps (Version 1.0) that took effect September 2014.”

On the other hand, McGowan points out that ENERGY STAR is a voluntary program – manufacturers are not lawfully obligated to be ENERGY STAR-qualified and not every manufacturer has chosen to go that route. He also notes that these new luminaires and portables must be clearly labeled with California markings to show that they meet the new requirement and must be easily seen by the building or home inspector.

The new regulation also states that recessed lighting fixtures – primarily the low-efficacy type –
would not be allowed to contain screw-based lamps, and would be required to contain a JA8 compliant source.

In the 2016 CASE (Codes And Standards Enhancement) Initiative report, it is noted that the majority of lighting wattage in homes is low efficacy and that this proposal would change that entirely. In the past, homeowners, designers, and specifiers got around the original regulation calling for high-efficacy fixtures by simply replacing the screw-in bulbs once the home/building inspection was completed.  Granted, this was at a time (2004) when CFL was the only alternative and consumers and designers alike balked at the light quality early CFLs provided and couldn’t wait to go back to their beloved incandescents. This new stipulation was created to eliminate that loophole.

The Discussion

Title 24 Title 20 goes into effect January 1, 2017 and the proposal does meet its goal of “allowing for greater flexibility and choice for consumers while delivering substantial energy savings,” but the added expense shouldered by manufacturers to produce these fixtures and lamps, create the necessary labels, and submit to new testing standards just to be able to sell in one state – albeit an important one from a business standpoint – has had lighting industry members grumbling.

Most importantly, in order to comply with the new regulation, the fixtures and portable lamps must be equipped with light sources that have the following characteristics:

Color temperature and color rendering
index similar to incandescent

Dimmable and low flicker similar to incandescent

Start time similar to incandescent

Life of at least 15,000 operating hours

The CASE report noted that “for light sources placed in enclosed or recessed luminaires, long lamp life at high temperatures has historically been a problem for CFLs and recently LEDs.” It is believed that this new criteria will eliminate that difficulty.

As a result, as of 2017, Californian consumers who are buying or renovating homes (i.e. any project where a permit is required) will – as stated in the CASE report – “receive a high-quality light source that does not need new lamps for time periods in excess of 10 years [which] is extremely cost-effective.” Furthermore, the report adds, “this approach increases the market demand for approximately 3 million additional high-efficacy, high-quality lamps per year. This will likely increase economies of scale and downward price pressure on these light sources.”

Lighting manufacturers who have to make the financial investment in order to comply with these new regulations just to be able to sell to California are understandably not too joyful about these changes. Despite the financial pinch, McGowan concedes that the new regulations will push the industry forward. Retailers in all other parts of North America are wise to be aware of what is happening with California’s lighting regulation, because as the saying goes…. 