Energy Codes and Existing Buildings

Model energy codes and standards cover new construction and renovations. As of the time of writing, many types of retrofits, such as replacing lamps and ballasts, are not directly impacted by energy codes, although some jurisdictions may require a building permit for some lighting upgrades. With publication of the ASHRAE 90.1-2010 standard in the fall of 2010, this may begin to change, as 90-2010 is expected to include lamp and ballast retrofits in some manner. Below is a discussion of IECC and 90.1 language that applies to existing buildings. Any interpretations are solely mine, and are provided here solely for educational purposes; of course, the building official or other authority having jurisdiction (AHJ) has the final say.

Let’s begin with IECC 2006, which states:

“Except as specified in this chapter, this code shall not be used to require the removal, alteration or abandonment of, nor prevent the continued use and maintenance of, an existing building or building system lawfully in existence at the time of adoption of this code.”

In other words, simply, if the building already exists, it exists, and the code by itself does cannot compel its owner to do anything to it. The model code, however, goes on to state:

“Additions, alterations, renovations or repairs to an existing building, building system or portion thereof shall conform to the provisions of this code as they relate to new construction without requiring the unaltered portion(s) of the existing building or building system to comply with this code. Additions, alterations, renovations or repairs shall not create an unsafe or hazardous condition or overload existing building systems.”

So if a portion of the lighting system is altered, that portion must comply with the code and the alteration and subsequent code compliance cannot negatively impact safety, which might be interpreted to include reductions in light levels below IES-recommended levels. Unfortunately, the language—if you touch it, you must comply with code—is somewhat vague about whether lamp and ballast retrofits are covered. Some might argue that replacing lamps and ballasts maintenance and not an alteration or repair, while others might argue that the lamp and ballast does not constitute a complete system. For these reasons, lamp and ballast retrofits are often considered not covered by IECC. Again, the AHJ has the final say. The code also stipulates:

“Buildings undergoing a change in occupancy that would result in an increase in demand for either fossil fuel or electrical energy shall comply with this code.”

ASHRAE 90.1’s language is more specific about lighting alterations. Section 9.1.2 of ASHRAE 90.1-2004 states:

“The replacement of lighting systems in any building space shall comply with the lighting power density requirements of Section 9 applicable to that space. New lighting systems shall comply with the applicable lighting power density requirements of Section 9.”

At first, this sounds like it would include lamp and ballast retrofits. However, the 90.1 requirement defines “system” as a “combination of equipment and auxiliary devices … by which energy is transformed so it performs a specific function such as … lighting.” While “combination of equipment and auxiliary devices” may sound somewhat open to interpretation, the author understands the intent is a system consists of luminaires, meaning system replacement involves luminaire replacement. There is also a major exception to this requirement:

“Alterations that replace less than 50 percent of the luminaires in a space need not comply with these requirements provided that such alterations do not increase the installed interior lighting power.”

So the standard does not appear to apply to lamp and ballast retrofits nor does it apply to any spaces in projects in which less than half of the luminaires are being replaced. Regarding lighting controls:

“Any new control devices as a direct replacement of existing control devices shall comply with the specific requirements of [an applicable section of the standard relating to controls].”

Lighting controls must comply with code if they replace existing controls. But the same exception applies, so lighting controls must comply with code only if 1) they replace existing controls and 2) the alteration also involves 50 percent or more of the luminaires being replaced in whatever portion of the lighting system is being altered.

Standard 90.1-2010, due to be published in the fall of 2010, is expected to cover both indoor and outdoor lamp/ballast retrofits and all luminaire replacement, with the lighting in the space required to comply with the LPD and automatic shutoff requirements of the Standard. The exception would be alterations that involve less than 10% of the connected lighting load, as long as those alterations do not increased the installed LPD.

Craig DiLouie

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