Lighting Controls and Title 24 Part 6 Compliance

Lighting is one of the first systems a California building department reviews for energy compliance, and controls are where many submittals stumble. A fixture schedule can be perfect while the control narrative is vague, the daylight zones are missing or the acceptance forms were never planned. Our electrical engineering services and architectural lighting design services teams coordinate these items so that the design, the drawings and the field work agree.

This guide walks through what Title 24 Part 6 asks of lighting controls, how to design for it, what the acceptance process involves and where projects go wrong. Budlong has served California owners and architects since 1958, and the lessons below come from the plan review and field verification stages that decide whether a project receives final approval.

Also Read: Title 24 Compliance Checklist for New Construction

1. What Lighting Controls Compliance Covers

Title 24 Part 6 is the California Energy Code. For lighting, it combines three ideas. Lighting power must stay within an allowance. Controls must reduce or shut off that power when it is not needed. Installed controls must be verified to work. Compliance is documented through forms, drawings and test records, not just a stamp on a sheet.

Mandatory versus performance requirements

Some requirements are mandatory and apply regardless of the compliance path. Lighting control functions, device certification and acceptance tests fall in this group. Other items, such as the allowed lighting power density, depend on whether the project uses the prescriptive path or a performance approach. A design team that confuses the two may meet the power limit and still fail on controls.

Where the requirements sit

Nonresidential lighting provisions are organized in the Part 6 sections numbered in the 130s and 140s, with device certification in the 110s and alteration rules in the 141 series. Section numbers can shift between editions, so confirm them against the adopted document at the start of design. Our Title 24 compliance guide explains how the whole code is organized.

2. How Controls Save Energy and Meet the Code

Lighting uses energy only while it is on and at the power level it is set to. Controls attack both variables. Occupancy and schedule controls remove hours of operation. Daylight controls trim output when windows or skylights supply light. Multilevel and dimming controls let occupants and automation match power to the task. Demand response controls give the utility a way to trim load during peak events.

The signal path

Every control strategy has the same basic path: an input such as a sensor, switch, schedule or signal, a logic element that decides, and an output such as a relay or dimming driver. Code compliance asks whether that path exists, whether it is configured correctly and whether it behaves properly in failure. Our overview of low voltage design best practices covers the wiring and device standards behind these paths.

Why certification matters

Part 6 expects control devices to be certified to the California Energy Commission, so a sensor or time switch without certification cannot be used for compliance credit even if it works well. Submittals should list model numbers that can be traced to the certified product listings.

3. Control Types and Strategies

The code language is functional, so a single product can satisfy several requirements when it is configured correctly.

Standalone, zone and networked systems

Standalone devices are simple and low in cost for small rooms. Zone controllers combine several functions for open offices and corridors. Networked systems, whether wired or wireless, centralize schedules, reporting and reconfiguration. The protocols involved include 0-10 volt dimming, described in the American National Standards Institute catalog as ANSI C137.1, addressable DALI-2, and building automation links such as BACnet, which is maintained through ASHRAE.

Power over Ethernet lighting

Some projects power luminaires and sensors from structured cabling under standards published through IEEE. This simplifies zoning changes, but it moves lighting reliability onto the network, so it belongs in the technology design. See our technology services for coordination support.

4. Title 24 Part 6 Requirements in Detail

The 2025 standards, published by the California Energy Commission, took effect on 1 January 2026. Permit applications submitted on or after that date use them, and local departments can confirm the date used for older submittals. The points below summarize the intent. Always read the adopted text for exact thresholds.

Indoor controls

• Area controls: manual control within each enclosed area, usable by occupants.
• Multilevel controls: at least one intermediate level between a low and a high fraction of full power, commonly cited as between 30 and 70 percent.
• Shut-off controls: automatic off by occupant sensing or a time schedule, with a short delay after vacancy and defined exceptions.
• Daylight controls: automatic response in sidelit and skylit areas that exceed size and power thresholds.
• Demand responsive controls: a defined reduction capability in buildings above a size threshold.

Outdoor and sign lighting

Outdoor lighting must shut off when daylight is available through a photocontrol or astronomical time switch, and many luminaires need motion-based dimming or reduction. Outdoor lighting zones, from the darkest to the most urban, set the allowable power. Sign lighting has its own control and efficiency provisions.

Acceptance and certification

Installed controls must pass acceptance tests, and the project record must include certificates from the designer, installer and acceptance tester. The standards include test procedures in a nonresidential appendix, and the forms belong to the NRCC-LTI, NRCI-LTI and NRCA-LTI families. Related energy code context is in our comparison of ASHRAE 90.1 and Title 24, and the green building side appears in the CALGreen MEP guide.

Also Read: ASHRAE 90.1 vs Title 24

5. Applications by Building Type

Each building type leans on a different mix of control strategies.

Offices and commercial interiors

Commercial buildings and tenant spaces, such as the Riot Games office building, often use networked zoning to reconfigure rooms without rewiring. Sensor layouts need to follow furniture plans.

Education and health facilities

Educational buildings, including the Los Angeles City College work, must satisfy Part 6 and the plan review path described in our DSA process guide. In health facilities the state review path, explained in the HCAI guide, adds its own requirements. The Department of General Services and HCAI publish current procedures.

Hospitality

In hospitality, guestroom controls differ from public area controls, and back of house spaces follow standard shut-off rules. Scene control for lobbies and ballrooms is designed together with architectural intent.

Need Lighting Controls That Pass Plan Check?

Our engineers prepare control narratives, zoning drawings and compliance documentation so reviewers and inspectors can approve the work without repeated resubmittals.

Talk to a Budlong Electrical Engineer

6. Design Process, Forms and Deliverables

A repeatable process keeps documents consistent.

1. Confirm the adopted edition and the compliance path.
2. Classify each space and assign its shut-off and multilevel strategy.
3. Identify daylit areas and draw their control zones.
4. Select certified devices and note default and failure states.
5. Write the sequence of operations, including demand response.
6. Coordinate emergency lighting and bypass devices.
7. Complete the certificate of compliance and list acceptance tests.
8. Prepare the installation certificate and test plan for the field.

Deliverables on the drawings

The drawing set should show control zones, device locations, circuiting, the legend that links symbols to device models and a control matrix. The matrix lists each space, its function, the assigned control strategy and the acceptance test that applies. Our guide to the electrical construction document package describes how these sheets fit with panel schedules and details.

Energy modeling and power allowances

Where lighting power is traded against other systems, results from energy modeling inform the compliance forms. Make sure the modeled controls match the installed ones, or the compliance report will not reflect the building.

7. Special Cases: Egress, Alterations and Outdoor Lighting

Emergency and egress lighting

Egress illumination is a life safety requirement, covered by the adopted building code from ICC and by NFPA documents such as NFPA 70 and NFPA 101. Controls must not allow designated emergency luminaires to go dark when normal power fails. Listed emergency relays, often evaluated to UL 924 through UL Solutions, force these fixtures on. Coordination with fire and life safety design prevents conflicts, and our article on code-compliant fire safety engineering in California explains how these systems relate.

Alterations and tenant improvements

When a defined portion of luminaires is replaced, or a space is rebuilt, the altered lighting generally must meet current power and control rules. Retrofit scopes therefore need an early look at the alteration provisions, since swapping fixtures for LED can pull wiring, sensors and acceptance tests into the job.

Multi-family and mixed occupancy

Part 6 applies to many nonresidential portions of multi-family buildings, such as corridors, lobbies and amenity rooms, while dwelling units follow other parts of the code. Be clear about which provisions govern each area.

8. How to Choose a Controls Approach and Cost Drivers

The right approach depends on size, tenant churn, reporting needs and the owner’s operating staff.

Cost drivers

Cost follows the number of zones, the sensor count, driver type, network infrastructure, programming and acceptance testing. Reduced wiring in networked systems can offset device cost, while low-bid substitutions of uncertified devices often create expensive rework. Utility incentive programs may help, so check current offers. For fee planning see how to estimate MEP engineering costs.

Integration with building systems

Many owners want lighting data in their building platform. Our article on implementing smart building technologies discusses how to scope that integration. The U.S. Department of Energy and the Lawrence Berkeley National Laboratory publish research on advanced lighting controls and their savings.

9. Best Practices, Mistakes and Acceptance Testing

Best practices

Write the control matrix early, assign every space a strategy and review it with the architect. Choose a control platform the owner’s staff can support. Name devices consistently, label zones on the drawings and require manufacturers to supply startup reports.

Common mistakes

• Missing or outdated compliance forms at permit submittal.
• Daylight sensors aimed at windows or placed under shading devices.
• Occupant sensors that do not cover the furniture layout.
• Uncertified devices substituted during procurement.
• Emergency fixtures that go dark when controls turn lighting off.
• No plan for who will run the acceptance tests and when.

Acceptance tests

Schedule testing before the final inspection, and give the tester access to ceilings and panels. Failed tests should be corrected and retested, with results recorded. Our commissioning services and building commissioning process show how independent verification can run alongside the code-required acceptance work.

Also Read: Integrating Smart Building Technology with Modern MEP Systems

10. Where Budlong Delivers This

Budlong prepares electrical and lighting packages from Glendale, downtown Los Angeles, Camarillo and Fremont, serving Los Angeles, Ventura, Orange, San Bernardino, Riverside and Santa Barbara counties and the Bay Area.

11. Related Reading

12. Frequently Asked Questions