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Do Energy Codes Really Save Energy?

By Stan Walerczyk, HCLP, CLEP

Let’s focus on the current California Title 24 because: it’s the one I know best, California is the largest state in population, and other energy codes, such as ASHREA and IBC, along with other states, may copy California.

At least for lighting retrofits, I would bet my house that more energy would be saved without this Title 24, which took effect on July 1, 2014, than with it.

There are numerous reasons for that statement. 

Several lighting retrofit contactors and suppliers have told me that their business is way down. Some are thinking of working under the Title 24 radar, only doing small projects that do not trigger Title 24, focusing on sales outside California, moving out of California or closing up shop. For example, one public school district approved a lighting retrofit with the previous Title 24, but canned it with the new one because it became much more expensive without significant extra savings.

Although previous Title 24s were much easier on retrofits than new construction, this version treats them the same. What may be okay for new construction, since new lighting and control products have to be purchased anyway, is not often cost effective for retrofits, when there are already lighting and controls products. Previous Title 24s allowed checker-boarding the lights on different switches if the existing fixtures had inboard/outboard lighting. But the new one requires bi-level lighting in most every fixture, unless the lighting powder density (LPD) less than 0.5 watts per square foot (WSF).

Typically lighting retrofits cost 20 – 30% more with this Title 24, with the new and detailed permit process, having to measure each room, the certified lighting controls acceptance test technician (CLCATT), etc., Plus, customized rebates, based on KWH saved, are usually less because existing wattage is not considered to be what is actually in the building, but the maximum allowed by this Title 24.

Dimming and controls are often required, even if not cost-effective. With current LED and high performance fluorescent, wattage can be so low that even basic grade wall mounted occupancy sensors often have a 15-year payback. Since the code often requires them, there are no rebates for them. Plus, controls can often increase energy use. There are many private offices, elementary school classrooms and other rooms where people do a very good job manually turning off the lights when they leave. But after occupancy sensors are installed, those people typically allow for the occupancy sensors’ 10 – 15 minute delay to turn the lights off, so annual hours of operation actually increase. 

There are room types that may even have existing occupancy sensors, but they will need to be replaced with new partial-on or partial-off occupancy sensors, which will add parts and labor costs but will probably not save significant energy.

Yes, demand response (DR) is very important, and this Title 24 requires DR for lighting. But addressable electric car charging stations and HVAC units are much more cost effective for DR than current LED and high performance incumbent lighting technologies

Title 24 is pushing people in the wrong direction. Retrofitting existing fixtures with reduced wattage fluorescent T8 lamps or LED T8s, while keeping the existing ballasts, does not trigger Title 24. So, even though there are better retrofit options, many people have or will go with these inferior solutions.

The main message that I keep hearing during my Title 24 lighting seminars from end-customers, retrofitters and others who really understand lighting retrofits, is that energy savings do not have to be mandated. If they are cost effective, they will be installed.

On the other hand, some ‘ivory tower experts’ who probably have never sold lighting retrofit projects say that, although it may take some time and education, everybody will get used to this new Title 24 and it will business as usual. But how can that be when projects cost 20 – 30% more without any (or significantly more) energy savings and customized rebates are less? If there were more low-hanging fruit of T12s and magnetic ballasts, this new Title 24 would not be such a burden. But existing are mainly first- or second-generation T8s and electronic ballasts.

Title 24 was approved, even if the number and size of retrofits drastically shrink.

There are rumors of an upcoming ‘permit police’, where end-customers would be fined for projects without Title 24, and some of that money would go to the bounty hunters, and contractors could lose their licenses.

As previously stated, this new Title 24 may be okay for new construction. But let’s look at an example. A national restaurant or store chain wants to build a new facility in California or Nevada with proposed sales estimated to be about the same in both states. For Nevada, this company can use its existing comprehensive building plans which it uses across the country. But for California, this company will have to pay for new building plans. Where do you think this company will build their new facility? I would bet Nevada. So California would not get the construction or other jobs and taxes. The only positive is that California will keep down energy consumption.   

While this current Title 24 was being developed, I put in considerable time and effort trying to make it well-balanced. I even got some lighting retrofit contractors to provide input to the California Energy Commission. But after realizing that those, and other peoples’, efforts were being wasted and I had to make a living, I stopped. It is my understanding that most of the people who could afford attending the long and numerous meetings worked for dimming and control manufacturers. The rest of the people, including builders, building owners, facility managers, lighting retrofit contractors, ESCOs, distributors, lighting consultants, architects, etc. had to do their regular jobs.

Politics, like in most issues, can get involved. Certain politicians and people working for public agencies may want the bragging rights of the strictest energy codes with the lowest LPDs and the most controls, even if those codes are not practical.

If anybody from the California Energy Commission or anybody else thinks that I am inaccurate in any way about this Title 24, let’s have a debate.

One very significant matter with existing and upcoming energy codes is: if there is enough wattage for sufficient light for the non-visual or biologic part of the visual system, which is for circadian rhythms, alertness, etc., what is the sense of saving every KWH if worker productivity and student learning and test scores suffer?

Hopefully the process and results will be improved for the upcoming Title 24, and other energy codes’ processes and results will be good. You may be able to help.

The bottom line may be that if energy codes are impractical, people may do nothing or try to do stuff under the radar. Carrot is often better than stick.

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