On July 1, 2012 the newest Title 24 supplements go into effect. For building officials and plan checkers, there are several additional enforcement issues to implemented. The Building Standard Commission (BSC) is reintroducing light pollution into Part 11. As part of the plan review process, it will be necessary to verify if the proposed new project site lighting conforms to the new code standards. This article provides information and a basic guide to help with the plan review process.

How to comply and how to enforce

In the last few months, many of you have received the next code supplemental pages for all parts of Title 24 that go into effect July 1, 2012. In CALGreen, Part 11, there is a newly reinstated section that addresses the issue of light pollution.

On January 1, 2012 local governments began enforcing CALGreen. Section 5.106.8, Light Pollution, required newly constructed projects to comply with keeping all light generated on site from leaving the site by using reflectors, shields, screen walls, or any other method which complied the code’s intent. This section provided some unique challenges for certain types of applications and occupancies.

As a result of these challenges, a petition was submitted to the Building Standard Commission (BSC) regarding concerns with security for different types of installations. On April 19, 2011 the BSC repealed the language in Chapter 5 and Appendix A5. The BSC then created a stakeholder group to develop new light pollution requirements. During the intervening months, new light pollution requirements were created and placed in Appendix A5.
The BSC is now moving the new light pollution standards from Appendix A5 to the mandatory section of Chapter 5.

How will local agencies enforce the new requirements?
How will new projects comply with the new requirement?

The BSC non-residential guide states “the intent of this code provision is to ensure that newly constructed projects reduce the amount of light and glare from both interior and exterior light sources leaving the site.”

For local agencies, the method of enforcement has several variables that include staffing levels, the ability of the building department to implement the code section, and the internal policies and procedures of the building department regarding this topic. Larger building departments will review the submittal for conformance, while other cities may delegate the light pollution review to the planning department, or the city may defer to an outside consultant with guidance from the building department.

The initial code language was based on the Illumination Engineer Society of North America (IESNA) cutoff classification system with four classifications (full cutoff, cutoff, semicutoff, and noncutoff).

IESNA Standard TM-15-11 is a new light classification system that provides information to lighting professionals regarding light distribution based on lighting angels.

This new system was developed because of concerns with nuisance lighting in many cities and to deliver a clear system that will provide an evaluation of light distribution based on thorough and comprehensive data. This standard a Lighting Classification System (LCS) analyzes lighting distribution angles in three basic different angels, behind the light (Back), above the light (Uplight), and in front of the light (Glare). This standard uses manufacture photometric test data that allows designers to evaluate and compare the distribution of light from a given fixture to permit selecting the fixture that will comply the code requirements.

The new standard for light pollution is based on the IESNA Standard
TM-15-11 and compliance with the new CALGreen light pollution requirements;

  • Minimum light requirements in the California Energy Code for Lighting Zones 1-4
  • Backlight, Uplight, and Glare (BUG) ratings as defined in IESNA TM-15-11
  • Allowable BUG ratings not exceeding those shown in TABLE 5.106.8
  • Compliant with a local ordinance or this code section, whichever is more stringent.

Under the supplement, building officials or city plan checkers will be reviewing submitted documents for the following:

  • Declaration of the proper light zone classification,
  • Review of the Light Fixture Table that should show:
  • Review photometric plan and compare with the fixture table,
  • Review light manufacturer data sheets supplied with submittal documents that show BUG ratings,
  • Review for any exception as defined in California Energy Code Sec. 147 and emergency lighting.

During the plan review process there maybe some question regarding the BUG rating declaration, or if the fixture manufacture has not developed the BUG rating, it will be necessary to review IESNA TM-15-11 Addendum “A.”
This document provides four different tables that allow you to convert the light angle test data into the BUG ratings. The addendum can be used by the plan checker or design professional to evaluate if a fixture is appropriate for a given installation.

As a design professional who is beginning to develop a project lighting plan, make sure you understand what the code is requesting for compliance and the methods used to evaluate for compliance. Select your fixture manufacturer, obtain fixture data sheets that show the BUG ratings, develop your photometric plan, and create a light fixture table that guides the plan checker through a logical compliance analysis.

I highly recommend reviewing the IESNA TM -15-11 Standard, Addendum “A” of TM-15-11, BSC Guide to Non-Residential Green Building Standards, and 2010 CALGreen with July 1, 2012 supplements. After you review the documents, if you still have questions, drop me an email and I will assist you to the best of my ability. – Charles “Russ” Russell