The changes to the requirements for lighting alterations proposed for the 2016 Standards establish a parallel compliance path specifying a percent reduction in existing lighting power instead of a Lighting Power Allowance. This path includes a requested relaxation of a bi‐level lighting requirement that would otherwise apply to projects at 85 percent or less of their Lighting Power Allowance. In addition, the numeric threshold for triggering requirements in a luminaire modification project was raised from 40 luminaires to 70 luminaires, and a numeric threshold of five (5) luminaires was added to the requirements for outdoor lighting projects. Lastly, an exception to acceptance testing requirements was added for projects that add controls for 20 luminaires or fewer.
Overview
Existing regulations in Title 24, Part 6, Section 141.0(b)2 set requirements for alterations to existing lighting in nonresidential buildings. These requirements establish a limit on the total lighting power that may be installed in a given space, and specify updates to the lighting controls that must be performed as a part of such alterations. Other sections of the Regulations further specify that newly installed lighting controls are subject to acceptance testing.
The existing regulations allow for a tradeoff between the complexity of the controls and the efficiency of the installed lighting. If the total lighting power is at least 15 percent below the limit for that space, then the updates to the controls are not required to include daylighting and may include bi‐level controls in place of more extensive multi‐level controls that would otherwise be required.
The proposed regulations restructure the requirements of this Section primarily to enhance its clarity and consistency. As the rulemaking process is an open, public process that solicits public participation, the proposed regulations were also responsive to concerns regarding the existing regulations that were brought to the Energy Commission. For the regulations applicable to indoor lighting, the following concerns were addressed:
1. Members of the public had voiced concerns that calculation of Lighting Power Allowances for existing buildings can be complex and prone to uncertainty, particularly in buildings with complex (i.e., non‐rectangular) spaces. To address this concern, the proposed regulations include a parallel compliance path based on achieving a 35 percent reduction in the amount of installed lighting power in the space: staff analysis had shown that for the majority of existing buildings this percentage would result in greater savings than being 15 percent below the Lighting Power Allowance.
2. Members of the public had voiced concerns that installing bi‐level or multi‐level lighting often requires extensive rewiring, if the existing lighting is not already bi‐level or multilevel, raising questions of cost and cost effectiveness relative to the anticipated savings from having multiple lighting levels. To address this concern, the bi‐level control requirement (that would otherwise apply to a project 15 percent below its Lighting Power Allowance) was relaxed for projects using the percent reduction compliance path, based on the additional savings estimated to be achieved by that path.
3. Members of the public had voiced concerns that acceptance testing was inappropriate for small projects that include installation of small numbers of off‐the‐shelf, non‐networked controls. To address this concern, an exception to the acceptance testing requirement was added for projects where new controls were installed for no more than 20 luminaires.
4. Members of the public had voiced concerns that the threshold of 40 luminaires for requiring updated controls, as it applies to projects that modify existing luminaires, was overly restrictive and not indicative of a typical small project (given that the intent of the threshold was to exclude small projects from the associated requirements). To address this concern, the threshold was raised to 70 luminaires.
For outdoor lighting, the following concerns were addressed:
1. Members of the public had voiced concerns similar to those for indoor lighting that calculation of Lighting Power Allowances for existing outdoor lighting can be complex and prone to uncertainty, particularly in areas with complex geometry. To address this concern, the proposed regulations include an exception to determining Lighting Power Allowances based on achieving a percent reduction in the amount of installed lighting power in the space that would achieve an equivalent savings.
2. Members of the public were concerned that, without a numeric threshold, the 10 percent and 50 percent thresholds could be crossed by altering a single luminaire, which was not the intent of the regulations given that it defeats the purpose of having a threshold. To address this concern, the proposed regulations include a numeric threshold of five (5) luminaires and specify that the greater of five luminaires or the specified percentage would trigger the need to meet associated requirements.
3. Members of the public had voiced concerns similar to those for indoor lighting that acceptance testing was inappropriate for small projects that include installation of small numbers of off‐the‐shelf, non‐networked controls. To address this concern, an exception to the acceptance testing requirement was added for projects where new controls were installed for no more than 20 luminaires.
After publishing 15‐Day Language that included these proposed revisions, the Energy Commission received public comments expressing concern that the changes to the regulations for indoor lighting alterations would result in an overall loss of energy efficiency and increase in energy use, and therefore a significant adverse environmental impact. In response to these comments, the Energy Commission made minor changes to the proposed language.
To address this comment and ensure that the regulations were equivalent to the current regulations, staff re‐evaluated the proposed regulatory language and prepared this Initial Study to examine the impacts of these revisions and determine whether the proposed changes to these Sections are likely to result in an adverse impact on the environment.