The first question is which code, and who says so
Every lighting controls design rests on one fact that is easy to get wrong: which energy code edition, with which local amendments, the building department will enforce on this project. In our region the answer varies by state, by city and county, and sometimes by building type. Published summaries conflict, and adoption changes.
So we never assume. At the start of every project we confirm the code basis with the authority having jurisdiction and write it down. The question for you is whether your design team has that answer in writing before the drawings are done.
What current model codes ask of lighting controls
The three codes we work with most share a direction: more automatic control, finer dimming and proof by testing. This summary is a starting point. The details depend on space type, compliance path and local amendments.
| Requirement | ASHRAE 90.1-2022 | 2024 IECC | Title 24-2025 (California) |
|---|---|---|---|
| Local manual control | Required in most spaces | Required in most spaces | Required |
| Automatic shutoff | Occupancy or schedule based | Occupancy or schedule based | Required; occupancy sensor delay of 20 minutes or less |
| Daylight-responsive control | Required in daylight zones above set wattage thresholds | Required; the 2024 edition lowers the wattage threshold | Required at 75 W or more |
| Multi-level and dimming | Partial-off and multi-level control in many spaces | Light-reduction controls in many spaces | Continuous dimming down to 10% or lower |
| Exterior lighting | Daylight shutoff and after-hours reduction | Daylight shutoff and after-hours reduction | Required outdoor controls |
| Functional testing | Required | Required (C408.3), extended to high-end trim, demand-responsive and automatic receptacle controls where installed | Acceptance testing |
DOE determined that 90.1-2022 saves roughly 10% over 90.1-2019. Much of the practical difference for a lighting designer is in the controls, not the fixtures.
Multi-state portfolios
A retail chain or bank can build the same prototype in three states and face three different code bases. Two shortcuts cause trouble:
- Designing every site to the oldest code in the portfolio, which fails plan review where a newer edition applies.
- Designing every site to the strictest code, which adds cost where it isn’t required and can complicate local inspections.
Our approach is a portfolio code matrix. We design one prototype controls package to a common baseline, then track each jurisdiction’s differences as named deltas: a shorter sensor delay here, a lower daylight threshold there. Site teams build from the prototype and apply only their deltas.
COMcheck without surprises
COMcheck is DOE’s compliance software, and the lighting section is where submittals most often come back with comments. The usual causes are mechanical: a fixture schedule that changed after the COMcheck run, space types that don’t match the plan labels, or controls claimed in COMcheck that never appear on the drawings. We reconcile all three before submittal. The design professional responsible for the project signs the result.
Functional testing is where compliance is proven
Recent codes don’t stop at requiring controls. They require proof that the controls work, through functional testing documented and delivered to the owner. That is the same work as commissioning, so we write the test procedures during design and run them at the end of construction.
The signed records go into the Ledger Reports module in your Lytbit Ledger workspace, where they also serve utility programs that ask for verification. Our incentive management service reuses them so you don’t produce the same evidence twice.
