Codes, standards, and policy guide lessons learned from California (UPDATED)

Design, defined by iconic 20^th-century designer Charles Eames, is “a plan for arranging elements to accomplish a particular purpose.” He eloquently articulated the idea that design, a fundamental process of solving human problems, thrives on constraints. Good regulations provide very clear and necessary constraints — we can all agree that rules governing life safety, energy use, and environmental impacts are essential to modern life, especially in light of recent events such as the tragic collapse of the condo building in Florida.

We can continue this reasoning to say that policy drives markets. Two recent examples are energy policies that stimulated the growth of solar technology and the evolution of high-color-rendering light sources in California as a result of changes to Title 24 in the current (2019) code.

Regulations have three different components — policy, standards, and codes. At least in California, the way they operate together is that policy creates broad goals and initiatives, codes enforce them, and standards provide the essential metrics and definitions by which to judge the success of the codes and policies.

The executive and legislative branches propose and pass bills that declare, for instance, that California will become carbon-neutral by 2045; they direct regulatory agencies to create codes that ensure this will happen; and these agencies rely on standards developed by many different bodies, including the National Institute for Standards and Technology (NIST, which happens to be involved in the investigation of the Surfside condo collapse); the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE); and the Illuminating Engineering Society (IES). Enforcement of energy codes in California is left to the local authorities, who grant occupancy permits only when projects meet code requirements. California prides itself in being a global leader in innovative energy and building codes, and this is largely a good thing, except when it isn’t.

California faces many complex and interconnected challenges in the regulatory environment when it comes to buildings and lighting. First, there is a significant gap in code enforcement and compliance. The job of enforcing codes falls to local jurisdictions, which often can’t afford the necessary staff to effect compliance and are frustrated by the increasing complexities of code. Policy makers often don’t understand the realities on the ground of construction, installation, and workforce development required to implement new technologies like advanced building controls and electric vehicle (EV) charging, for instance.

Participation in the rulemaking process, which is supposed to be open and transparent, is anything but — it’s increasingly driven by highly trained experts, the only ones who can master the complexities of codes, and utilities have an outsized influence on rulemaking in general. Efforts to “streamline” California’s energy codes, however well intentioned, don’t seem to be going anywhere. For instance, a recent proposal for the 2022 code cycle creates a completely separate section for multifamily residential buildings, something that will exacerbate compliance challenges.

But it’s well understood that regulation lags technology development, and this partly explains these challenges. I trust larger market forces to have a greater impact on regulation — specifically the need for a balanced, resilient energy grid in California, the US, and around the world. This is where it’s important to understand how lighting is having and will continue to have an impact in the regulatory environment, and its role in evolving a decarbonized, resilient energy grid.

The big disconnect (pun specifically intended) in the way the lighting industry has characterized the Internet of Things (IoT) and smart building technology in the past decade is that the discourse has been limited to benefits and return on investment (ROI) within the building envelope only — asset tracking, surveillance and security, improved operations and maintenance, health and wellness, energy efficiency, and of course the ability to collect vast piles of data that no one quite knows what to do with yet. These are all important benefits but collectively or individually have not proven to be the transformative factor in driving smart building evolution.

What is mostly likely to drive this is the need to balance the grid with renewables, advanced storage, and energy analytics and provide resilience. We need to literally think outside the building and consider its connection to the grid. Lighting provides a key connection here with incremental but critical steps like enabling demand response, controlled receptacles, and price signals to devices. Lighting technology is at the center of these developments, and work on policy, codes, and standards is beginning to enable key connections between buildings and the grid. Energy efficiency alone is no longer the main focus, especially in lighting. Reliable, safe, decarbonized, equitable, and decentralized power is the most important consideration now.

During the Strategies in Light panel, the speakers will explain the recent important changes in the 2022 California Title 24 code cycle and how they impact manufacturing, design, construction, and operations. They will describe in detail their recent efforts on initiatives for demand management, demand controlled receptacles, and the Central Nonresidential Data Repository proposal. And they will discuss how we can evolve the regulatory process to deal with the increasingly urgent challenges of climate change, pandemics, economic disruptions, equity, environmental justice, and political and social instability.

Register now to join us for Strategies in Light, which will be held online from Aug. 24–25, 2021, to explore the ramifications of codes and standards and more.

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CLIFTON STANLEY LEMON is CEO, Clifton Lemon Associates, and Strategies in Light co-chair.

*Updated July 7, 2021 2:05 PM for clarifications by Josh Dean, California Energy Alliance.

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