Title 24 lighting requirements for nonresidential projects
Lighting power density, the mandatory controls, and the NRCC-LTI, NRCC-LTO and NRCC-LTS forms a plan checker looks for on a commercial or tenant-improvement job. Here is how each piece works.
Lighting power, and the controls that switch it
Nonresidential Title 24 lighting compliance is two tests, not one. The lighting has to fit under a lighting power limit, and it has to be switched by a set of mandatory controls — passing the first does not excuse the second. Both are documented on Certificates of Compliance: NRCC-LTI-E for indoor lighting, NRCC-LTO-E for outdoor, NRCC-LTS-E for signs. Those names are identical on the 2022 and 2025 form sets.
The indoor form carries most jobs. It documents indoor lighting on the prescriptive path for nonresidential and hotel/motel occupancies, and is also the form for multifamily occupancies, dormitory and senior living included. On a tenant improvement it rides along with the mechanical and envelope forms.
Lighting power density is one comparison
Lighting power density (LPD) is watts per square foot, and the prescriptive indoor test is a single comparison: adjusted lighting power must be no greater than allowed lighting power. Adjusted is the total designed wattage minus the lighting control credits — power adjustment factors — that the design earns.
Allowed power comes from one of two methods. The Complete Building Method applies only when a whole building or tenant space is permitted at once and one occupancy type makes up at least 90 percent of it. One LPD then governs the whole thing: an Office Building is allowed 0.60 W/sq. ft., a Parking Garage Building 0.13, all other buildings 0.40 — unchanged between 2022 and 2025. The Area Category Method works for any permit situation, tenant improvements included, and assigns an LPD to each primary function area: offices, lobbies, corridors. An Office Area larger than 250 square feet is allowed 0.60 W/sq. ft. of general lighting; 250 square feet or less is allowed 0.65. That table runs to dozens of rows, and which one applies depends on how each space is classified — which is where most of the argument in a lighting review happens.
There is a performance path as well. Indoor lighting is one of the systems inside the nonresidential energy budget, so lighting power can be traded against envelope and mechanical measures on the same permit application — but the CEC compliance manual is specific that indoor lighting can only be modeled together with the envelope, and that the performance approach does not reach outdoor lighting or sign lighting at all. The mandatory controls below apply either way. For 2025 the Tailored Method was dropped as a prescriptive indoor path, some of its allowances folded into the Area Category Method instead — one of several 2025 code changes that land on lighting. Allowed power is figured separately for conditioned and unconditioned areas, and the two cannot be traded against each other.
The mandatory controls
Section 130.1 sets the mandatory indoor lighting controls, and they apply no matter which path got the design under the power limit. Manual controls come first, in §130.1(a); multilevel, shut-off, daylight responsive and demand responsive follow in (b) through (e). The occupant-sensing rules that get argued about most sit inside the shut-off subsection.
- Multilevel — for general lighting in spaces of 100 square feet or larger with a connected lighting load greater than 0.5 W/sq. ft., dimming continuously from 100 percent down to 10 percent or lower. Restrooms, healthcare facilities and single-luminaire spaces are excepted.
- Automatic shut-off — for all installed indoor lighting: occupant sensing set to no more than a 20-minute delay, an automatic time-switch control, or another automatic control. Lighting is controlled separately on each floor, and control zones for a space enclosed by ceiling-height partitions cannot exceed 5,000 square feet.
- Occupant sensing, by room type — offices of 250 square feet or smaller, multipurpose rooms smaller than 1,000 square feet, classrooms, conference rooms and restrooms must shut all lighting off within 20 minutes. Offices larger than 250 square feet instead get zones no greater than 600 square feet, shown on the plans, with lighting down to 20 percent of full power or less within 20 minutes.
- Daylight responsive — called “automatic daylighting controls” through the 2022 cycle. Required where installed general lighting wattage in a skylit, primary sidelit or secondary sidelit daylit zone is 75 watts or greater, or 60 watts or greater in parking garages. Daylit zones have to be shown on the plans.
- Demand responsive — where nonresidential lighting has a total installed lighting power of 4,000 watts or greater and is subject to the multilevel requirement.
Outdoor and sign lighting
Outdoor lighting must be controlled independently from other electrical loads, and needs a photo control or astronomical time-switch plus automatic scheduling controls capable of cutting outdoor lighting power by 50 to 90 percent. Motion sensing is required on hardscape, parking lot, sales lot, service station and canopy lighting mounted 24 feet above grade or lower, with no more than 1,500 watts per sensor or zone. Luminaires rated 40 watts or less are exempt from the motion-sensing requirement.
There is no single outdoor power allowance. Allowances vary by Outdoor Lighting Zone, LZ0 through LZ4, assigned by statewide default location under Title 24 Part 1 §10-114 and amendable locally through a public process. Allowed power is a general hardscape allowance plus additional allowances for specific applications, and cannot be traded between outdoor and indoor areas. Signs have their own numbers: 12 watts per square foot of illuminated sign area internally illuminated, 2.3 watts per square foot externally, and on a double-faced sign only one face counts.
What triggers a lighting form on an alteration
Indoors the trigger is 10 percent. An alteration that includes 10 percent or more of the luminaires serving an enclosed space has to meet the §140.6 lighting power requirements and the Table 141.0-F controls, or one of two reduced-power alternatives. Alterations to lighting wiring count as alterations to the lighting system.
Acceptance testing is a different trade
Three certificates, three people, three stages. The NRCC is completed by the project proponent and submitted at plan check. The NRCI is completed by the installing contractor during construction. The NRCA is completed before the certificate of occupancy by the technician who checks the installation against the acceptance-test requirements — and for lighting controls that technician must be certified by a CEC-approved certification provider. I do not perform acceptance testing and I am not certified to.
What I do is the NRCC lighting documents, as documentation author. Send a lighting plan, a fixture schedule with wattages and a reflected ceiling plan, and a flat quote comes back the same business day. A lighting comment on forms somebody else prepared is a plan-check correction; the acronyms are in the Title 24 glossary.
Prices
Flat fees, in writing before I start. No hourly, no bid package, no change-order games — the number on the quote is the number on the invoice.
Your first report with me
One per client, homes under 3,000 square feet. Full energy model, CF1R and CHEERS registration. It’s a test run — send one job and see how it goes.
Every model after the first
The standard rate once you’re a client — the second building, ADU plus main house, the next project that walks in. Back in 3 business days.
Over 3,000 square feet
Quoted from the plans before any work starts, same day.
24×36 plan-sheet set
Your CF1R laid out full size, matched to your drawing set. Comes back as a PDF you drop straight in.
Revisions
Two revisions included, plus questions any time. Past two I quote first, before I touch it.
Commercial / tenant improvement
Send the plans and you’ll have a flat quote back the same day. No deposit, no minimum.
One honest note
I’m not a licensed engineer or architect, and I don’t stamp drawings. On the CF1R I’m the documentation author — you stay the responsible designer. Nothing about your role on the job changes.
That’s on purpose. I’m not after your scope or your clients. I do one piece of the permit set — the piece that usually holds it up — and I do it fast.
Lighting compliance questions
If yours isn’t here, see the full FAQ or call and ask.
Does an LED retrofit or a lamp swap need a Title 24 lighting report?
Not by itself. An alteration limited to adding lighting controls, or to replacing lamps, ballasts or drivers, is excepted from the indoor lighting alteration requirements. So is any enclosed space with only one luminaire, and so is a one-for-one luminaire alteration of up to 50 luminaires per complete floor, or per complete tenant space, per year.
Past those exceptions the 10 percent rule applies and the job has to show lighting power and controls. The one-for-one compliance path is itself narrow: a building or tenant space of 5,000 square feet or less, altered luminaires at least 40 percent below their pre-alteration wattage, and the Table 141.0-F controls. Send the fixture schedule and the scope and I will tell you which side of the line it falls on.
What changed for nonresidential lighting in the 2025 code?
Permit applications made on or after January 1, 2026 follow the 2025 code and the 2025 forms; anything applied for before that stays on the 2022 cycle. On lighting specifically, the Tailored Method was removed as a prescriptive indoor path, with some of its allowances moved into the Area Category Method as additional lighting power allowances.
The controls changed too. Multilevel controls now have to provide continuous dimming from 100 percent down to 10 percent or lower, and the old table of control steps is gone. “Automatic daylighting controls” became “daylight responsive controls,” and the wattage threshold moved into the requirement and came down — the 2022 code exempted daylit zones under 120 watts of general lighting, while 2025 requires the controls at 75 watts or greater. The 60-watt threshold for parking garages is unchanged. Manual controls now have to be in the same space as the lighting they control, or positioned so the controlled lighting or its status is visible while you operate them. And general lighting luminaires longer than 8 feet must be controlled in segments of 8 feet or less inside daylit zones. More at 2025 code changes.
Which Title 24 lighting form does my project need?
Indoor lighting is NRCC-LTI-E, outdoor lighting is NRCC-LTO-E, sign lighting is NRCC-LTS-E. A scope can pull in one, two or all three — a tenant improvement with new site lighting and an illuminated storefront sign can hit every one of them. Exit signs and traffic signs are not required to comply with the prescriptive sign requirements and do not need the sign form at all.
Sign lighting controls sit under §130.3: indoor sign lighting other than exit signs needs an automatic or astronomical time-switch control; outdoor sign lighting needs a photocontrol plus an automatic time-switch, or an astronomical time-switch; and outdoor sign lighting that is on both day and night needs a dimmer that automatically cuts sign lighting power by at least 65 percent at night.
If the scope is genuinely ambiguous, the CEC runs an Energy Code Support Center with a hotline for project-specific code questions, toll-free in California at 800-772-3300. I will also just look at it — send the plans.
Who performs lighting controls acceptance testing?
Not me. It is a separate certified trade. The Certificate of Acceptance (NRCA) for lighting controls must be completed by a technician certified by a CEC-approved certification provider — an acceptance test technician. Where Part 1 §10-103.1 certification applies, §130.4(c) names a Certified Lighting Controls Acceptance Test Technician, who has to disclose a valid certification ID number on the certificate.
The lighting acceptance forms are NRCA-LTI-02-A for shut-off controls, NRCA-LTI-03-A for daylighting responsive controls, NRCA-LTI-04-A for demand responsive controls, NRCA-LTI-05-A for institutional tuning, and NRCA-LTO-02-A for outdoor lighting controls. A certificate of acceptance for lighting and receptacle controls has to be submitted to the enforcement agency before an occupancy permit is granted. One carve-out worth knowing on alterations: acceptance testing under §130.4 is not required where lighting controls are added to control 20 or fewer luminaires, and the same 20-luminaire threshold applies outdoors.
Who signs the NRCC lighting forms?
Two people, the same way the CF1R works. The form carries a Documentation Author’s Declaration Statement, signed by whoever prepared it, and a separate Responsible Person’s Declaration Statement signed under penalty of perjury by the responsible designer — the person eligible under Division 3 of the Business and Professions Code to accept responsibility for the design, with a license field to fill in.
I am the documentation author. You stay the responsible designer and nothing about your role changes. I am not a licensed engineer or architect and I do not stamp drawings — see who can prepare a Title 24 report.
What does a nonresidential lighting compliance package cost?
Commercial and tenant-improvement scope varies too much to publish a flat rate, so it is quoted from the plans: send the drawings and a flat quote comes back the same business day. No deposit, no minimum. The residential rate card is on the cost page.
What helps most is a lighting plan, a fixture schedule with wattages and mounting heights, a reflected ceiling plan, and the site plan if there is exterior or sign lighting. Tenant improvements covers how the rest of a commercial package fits together.
Send me the lighting plans.
A lighting plan, a fixture schedule with wattages and a reflected ceiling plan is enough for a flat quote back the same business day.