Commercial LED lighting retrofits and Title 24

When an LED swap becomes a Title 24 project

The California Energy Code, also called Title 24 Part 6, treats a lighting change as an alteration. Under Section 141.0(b)2I in the 2025 edition, which took effect January 1, 2026, an alteration that touches 10 percent or more of the fixtures serving an enclosed space must meet one of three paths:

1. Meet the lighting power limits in Section 140.6 and the control rules in Table 141.0-F.
2. Come in at 80 percent or less of the Section 140.6 power limit, with the same controls.
3. In a building or tenant space of 5,000 square feet or less, swap fixtures one for one and cut the total wattage by at least 40 percent.

Several changes skip all three. Replacing only lamps, ballasts or drivers is exempt. So is adding controls alone, a room with a single fixture, and a one-for-one swap of up to 50 fixtures per floor or per tenant space in a year. The service and repair page lists the same exemptions in a shorter form.

The Energy Commission’s compliance manual explains why option 2 and option 3 are popular. Because they end at a lower wattage, they do not require multi-level, daylighting or demand response controls. They still require the manual area and automatic shut-off controls. The manual linked below is the 2025 edition.

Controls and daylight sensors

Most tenants find the controls cost more thought than the fixtures. Option 1 pulls in automatic shut-off controls, multi-level lighting and, in rooms with enough window or skylight area, automatic daylighting controls. A warehouse with skylights is the usual case. The manual shows a daylighting control that must be able to cut lighting power by at least 65 percent when daylight fills the zone, for the skylight case it describes.

Ask the electrician which option the design uses and which controls come with it. Then ask who is responsible for the compliance forms. A designer may prepare them, and the installer signs a certificate that the work matches.

Parking lots, wall packs and pole lights

Outdoor lights sit under Section 141.0(b)2L, not the indoor rule. As summarized from the 2025 text:

• If the connected load goes up, added or altered fixtures must meet the outdoor lighting rules for that use.
• If the load stays the same and 10 percent or more of the fixtures are replaced, the new fixtures must meet the basic outdoor requirements.
• If 50 percent or more are replaced, the broader outdoor requirements apply too.
• Replacing fewer than five fixtures is excepted from the 10 percent rule.

For lots, the 2025 manual describes motion sensing controls on fixtures over 40 watts mounted 24 feet or lower, and outdoor controls that need an acceptance test certificate filed with the city. The dimming range, sensor coverage and exceptions are detailed in the manual. Confirm them against the edition the city applies. A parking lot also touches the commercial EV charging page when chargers are added later. The parking lot lighting page covers lot controls, shielding, lighting zones and the control tests in full.

Exit signs and emergency lighting

Exit signs and path lighting do not count as ordinary lighting. The California Building Code, Section 1008.3.1, calls for emergency power to run for not less than 90 minutes where two or more exits are required. Existing buildings can fall under different wording, with 60 minutes cited for some cases, so the building type matters.

After the retrofit the system still has to be tested. Riverside County Fire’s guidance, published through the City of Moreno Valley, asks for a functional test about every month for at least 30 seconds, a yearly test of 90 minutes on battery, and written records kept by the owner for the fire authority. A maintenance agreement is one way owners schedule those tests.

Utility programs, checked October 30, 2026

• LADWP Commercial Lighting Incentive Program: for customers above 200 kW of monthly use. Equipment generally must be on the DesignLights Consortium list, the project must save at least 25 percent, and LADWP must approve it before purchase. Rebates are paid per kWh saved, from $0.08 for lamps only up to $0.40 for LADWP Preferred fixtures, using rates dated July 1, 2024. Funds go first come, first served, and the page says the program can change or end without notice. The page shows an Apply Today button and no closure notice as of October 30, 2026.
• LADWP Commercial Direct Install: for customers at 250 kW or less. LADWP describes LED upgrades as free and utility funded under its terms. The page shows an Apply Today button and no closure notice as of October 30, 2026, but it does not say how much funding is left, so call before you plan around it.
• Riverside Public Utilities: commercial accounts can use a program for existing outdoor fixtures, limited by funding and one use per year.

This page does not state a current status for SCE or SDG&E lighting programs, because their pages could not be opened during research on October 30, 2026. Check each utility’s business savings page first. Many programs ask for approval before you order equipment, and a signed invoice can end your eligibility.

Permits and plan check

Permit rules for lighting are local. San Diego requires a permit for electrical work in general and gives nonresidential projects a no-plan track, with plans for jobs outside it. Long Beach’s express list allows a same-type, same-wattage fixture swap, and for nonresidential buildings only below 10 percent of the fixtures in a room. A bigger changeout falls outside that list, so ask the city. Where a permit is required, the electrician pulls it and the city inspects the work. A job that adds circuits or changes a panel is the likeliest to need one.

Cost

This page quotes no price, because fixture type, ceiling height, lift rental, controls and rebate eligibility change the total too much for one number. Get the fixture count first, then ask for a quote that splits fixtures, controls, labor and permit fees. The quote checklist shows the lines.

What to send

For a quote, send the building type, address, whether you are the tenant, owner or property manager, the number and type of fixtures, ceiling height, and what is wrong or planned, through the quote form.