Commercial LED Retrofit Title 24 Requirements
Not every LED upgrade is an alteration. Replacing lamps only, or drivers only, is a repair outside the lighting alteration rule, while whole fixtures and kits that replace lamp and ballast count toward a 10 percent trigger. Once 10 percent or more of the luminaires serving an enclosed space change, one of three routes in Section 141.0(b)2I applies.
- Send your plans
- Get a free quote
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Sort the upgrade by what comes out
Section 100.1 defines a luminaire alteration as adding luminaires, removing and reinstalling them, or the combined replacement of lamps and ballasts or drivers. Repairs such as lamps only, ballasts or drivers only, diffusers and covers are excluded, and Exception 5 to Section 141.0(b)2I excepts any alteration limited to adding controls or replacing lamps, ballasts or drivers. The Commission manual treats a retrofit kit that replaces both lamps and ballasts as a one-for-one luminaire alteration.
Counting the 10 percent
The manual's example has 100 fixtures in an office and retrofit kits in 20 of them. Twenty percent is above the 10 percent threshold, so a route applies. The count is per enclosed space. A space with only one luminaire is excepted, though that luminaire still counts toward the floor total of 50.
The three routes
- Full compliance with the Section 140.6 power limit plus the Table 141.0-F controls.
- No more than 80 percent of the Section 140.6 allowance, plus a lighter Table 141.0-F control set without multilevel, daylight responsive or demand responsive controls.
- A one-for-one luminaire alteration in a building or tenant space of 5,000 square feet or less, with the altered luminaires at least 40 percent lower in total wattage, plus that lighter control set.
In the office example the kit swap could use the third route if wattage fell by 40 percent. A one-for-one alteration of up to 50 luminaires per complete floor or tenant space per year is excepted, as are portable luminaires and luminaires on movable partitions.
What the retrofit may not do
An alteration may not stop existing unaltered controls from working or remove functions required by Section 130.1. Which controls attach on each route is covered on replacing commercial light fixtures. For the route logic see commercial lighting alterations, and for the dimming and sensing devices a retrofit often adds, see lighting control devices. High-bay conversions are worked through under warehouse lighting retrofit. Request a scope from the commercial page.
Common Title 24 Questions
- When does a commercial project need Title 24?
- Does an office tenant improvement need Title 24?
- Does a restaurant remodel need Title 24?
- Does a retail tenant improvement need Title 24?
- What plans are needed for a commercial Title 24 report?
- What is an NRCC certificate of compliance?
Frequently Asked Questions
Replacing lamps only is a repair under the Section 100.1 definition, and Exception 5 to Section 141.0(b)2I excepts it. Replacing both lamps and ballasts with a kit is treated as a one-for-one luminaire alteration.
The trigger is 10 percent or more of the luminaires in an enclosed space, with an exception for one-for-one alterations of up to 50 luminaires per floor or tenant space per year.
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