How To Deal With California Title 20 and 24 Difficulties

Dealing With California Title 20 and 24 Difficulties: Code-Compliant Lighting and Permitting

Over the past two years, California electrical contractors have had to deal with sweeping changes.

Title 20 and Title 24 are the driving force behind these changes, affecting lighting and appliance codes, as well as labeling for a variety of lighting products.

The first changes took place in 2018, when Tier 1 of the Title 20 kicked in. Tier 2 went into effect on July 1, 2019. And, this past Jan. 1, Title 24 launched.

The First Hurdle: Finding Compliant Lighting

Title 20 changes brought the first set of difficulties for contractors. David Walter, a master electrician at Alcoa and founder of Electrician Mentor, said the main issue with Title 20 was finding compliant products.

“Originally, we did have sourcing issues and finding the right supplier for complaint equipment, but that has been sorted out, and is now one of the easier processes,” Walter told us.

EnergyAvenue has played a role in California electricians getting what they need. Our site carries a variety of Title 20-compliant lighting options.

This is important, as there are a ton of rules for lighting. Here’s an example of some of the requirements for general lighting, per Title 20:

  • Retailers can’t sell lights that generate less than 45 lumens per watt
  • Has to be rated for at least 10,000 hours of use
  • Dimmable lamps have to be dimmable to 10%
  • CRI has to higher than 80

According to Title 20, “general service lamp” means:

  • ANSI base
  • Operates at 12V, 24V, 100-130V, 220-240V or 277 volts for integrated lamps
  • Initial lumen output equal to or greater than 310 lumens and less than 3,300 lumens
  • Not a light fixture
  • Not an LED downlight retrofit kit
  • Used in general lighting applications

Now, even though these requirements seem complicated, we’ve made sure we stock our warehouses with lighting that will help meet code requirements. Our lighting concierge team will walk you through what you need.

But lighting isn’t the main issue that contractors are facing, Walter said. His company is facing difficulties with the permit requirements included in Title 24.

The Second Hurdle: Title 24 Permitting

Title 24 is focused on building efficiency standards, of which lighting is a part. To ensure that new construction and retrofits are in line with the state’s goal for energy efficiency, you have to go through a specific permit application and approval process.

“These insanely strict regulations have made it a difficult road for my business to navigate, particularly when it comes to commissioning. there are a lot more checkpoints and regulations to go over,“ Walter said. “My guys have to be upskilled and a lot were trained a while ago, so keeping on top of these new regs, even though they have been in place a little while has been tough going.”

The toll the permitting process has taken on his business isn’t just about a bigger learning curve; it’s about money and lost time, Walter said.

“The additional documentation involved before carrying out work and the subsequent review and inspection has added an extra 20% to our admin and workload,” Walter said. “Some projects are being delayed and some have been delayed indefinitely.”

Even though the new regulations have cost him time and money, Walter said the upside is that his team is more aware of decisions that could trip them up and delay a project.

“The training we’ve had to do helps to limit mistakes and limit questions that may pop up during installation,” he said. “Plus, our insurance cover and client confidence has increased.”

So, even if you’re feeling frustrated and overwhelmed by Title 20 and Title 24, there is hope.

A Success Story: Covering Your Title 24 Bases

One of the ways you can ensure you run into as few problems as possible is to train your team well and even designate a Title 24 expert, as nailing the permit process is the hardest part of the new regulations.

Cale Garamendi, a commercial project developer at Santa Cruz-based Sandbar Solar & Electric, said they’ve implemented this tip to perfection.

If anything, the new regulations made the company add extra layers of expertise to ensure they’re code-compliant every step of the way.

“Title 24 compliance is a standard and accepted part of doing business for Sandbar,“ Garamendi said. “Our in-house electrical engineer collaborates closely with Title 24 experts at our primary electrical supply house to ensure that we are specifying the correct equipment applied in the correct manner in our construction plan sets.”

Once a project’s plans are developed, Garamendi brings in a Title 24 certified compliance officer to review the plans “and complete the necessary forms for submittal to the state,” he said.

Even though Garamendi and his colleagues see positives coming out of Title 24, there is no denying that the regulations have required more time and, as a result, more money spent on training.

Training and permitting issues aside, one of the things you can use to your advantage is the California Energy Commission’s code database.

The database has a search tool you can use to verify the lighting elements you want to use in your next project are Title 20 and/or Title 24 compliant. The tool allows you to do a search by model number, brand, company and more.

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