State energy codes were meant to help save energy and encourage property managers to choose the most energy-efficient options available, but what happens when the codes become so cumbersome and expensive that it inhibits properties from getting the necessary updates that they need? This is what seems to be happening in California. The original Title 24 regulation set standard and encouraged energy conservation, but the new Title 24 regulations may have gone to far, and may even be written to promote special interests.
For example, a public school district in California approved a new lighting retrofit that was accepted under the original Title 24. With the new update that took effect in July 2014, the school district had no choice but to cancel the upgrade. The requirements made the retrofit much more expensive and without significant energy savings. The same story is being told for many other buildings in the state.
Before the latest update, Title 24 had different requirements for retrofits than it had for new construction. This made sense because new construction requires new lighting and control products anyway, while retrofits already have existing lighting and controls that can be easily updated to become more energy efficient. The recent update treats retrofits and new construction relatively the same, which has led to lighting retrofits costing 20%-30% more under the update.
For example, the previous Title 24 allowed checker-boarding the lights on different switches if the existing fixtures had inboard/outboard lighting. The update requires bi-level lighting in almost every fixture, unless the lighting power density (LPD) is less than 0.5 watts per square foot (WSF). The cost of retrofitting for this in existing buildings is prohibitive and in most instances does not add much as far as energy savings.
Another example is how the new Title 24 regulates T8 LED tube lights. 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 not backwards retrofittable and is more reliable, yet this triggers the new Title 24 regulations and all of the associated expense. Consequently, contractors have to go with these inferior solutions, even though there are more efficient and cost-effective options available. Also, it is causing energy saving projects to be shelved.
Dimming and controls are often required under Title 24, even if they’re not cost-effective. Imagine a school building where faculty and staff are used to turning off the lights when they leave the room, like most people do. Occupancy sensors typically allow a 10-15 minute delay before the lights turn off. This actually wastes energy, since the lights are on for additional minutes when they do not need to be. Moreover, with current LED and high performance fluorescent performance, wattage is so low that occupancy sensors often have a 15-year payback.
To reduce the costs of an expensive retrofit, contractors typically turn to rebates. Customized rebates, based on kWh saved, do not provide the same savings under Title 24 because existing wattage is not considered to be what it actually is on the property. Now, it is the maximum allowed by Title 24.
Title 24 has resulted in significantly less business for lighting retrofit contractors and suppliers in California. Many are thinking of working under the Title 24 radar, only doing small projects that do not trigger Title 24, focusing on sales outside of California, moving out of California, or closing up shop completely. Energy codes as strict as Title 24 may save energy, but they also negatively impact businesses, and even schools. It can even be argued that more energy would be saved without Title 24, for the reason that many of the codes actually waste energy instead of save. And if a public school cannot update its lighting, then it has no choice but to use its outdated energy-hogging system, which definitely does not save energy.
Energy codes are a great idea, and maybe even necessary—but only if it’s within reason. Unfortunately, other energy codes and states may soon follow suit.