California Title 24 Lighting Requirements: What You Need for Your Photometric Plan

California Title 24 Part 6-the California Energy Code-imposes outdoor lighting requirements that are more restrictive and more documentation-intensive than the model energy codes used in most other states. Key requirements include Lighting Power Allowances (LPA) calculated by illuminated hardscape area, mandatory automatic controls (dimming, scheduling, and daylight sensing), BUG rating limits for luminaire uplight and glare, and specific compliance forms (NRCC-LTO) that must accompany the photometric plan submittal. The 2025 edition of Title 24 Part 6 took effect January 1, 2026, and applies to all projects with permit applications filed on or after that date. Projects permitted before January 1, 2026, are subject to the 2022 edition.

If you're pulling a building permit in California that involves any exterior lighting-new construction, addition, or alteration-you need to understand how Title 24 affects your photometric plan. A foot-candle grid alone won't pass review. California requires energy code documentation that most other states don't.

Why California is different

Most US jurisdictions adopt the International Energy Conservation Code (IECC) or ASHRAE 90.1 as their energy code baseline. California does neither. Title 24 Part 6 is a California-specific energy code developed and enforced by the California Energy Commission (CEC), updated every three years. For outdoor lighting, it is generally more restrictive than the national model codes in several respects:

Lighting Power Allowance, not just Lighting Power Density. While ASHRAE 90.1 uses a straightforward watts-per-square-foot approach, California's method is more granular. The allowed outdoor lighting power is calculated by multiplying the illuminated hardscape area by an Area Wattage Allowance (AWA), then adding a Linear Wattage Allowance (LWA) based on the perimeter of the hardscape area, plus a one-time Initial Wattage Allowance (IWA) per site. The formula is:

Total Allowed Power = (Hardscape Area × AWA) + (Perimeter × LWA) + IWA

This layered approach means the allowed wattage isn't a simple site-area multiplication. It requires measuring and calculating each component separately, which adds documentation work to the photometric plan.

Mandatory automatic controls. Title 24 requires specific controls for outdoor lighting that many other states don't mandate. These aren't optional energy-saving features-they're code requirements that must be documented in the permit submittal.

Lighting zones with real teeth. California defines five outdoor lighting zones (LZ0 through LZ4) that directly affect allowed wattage, BUG rating limits, and light trespass thresholds. The default zone for most of California is LZ2, but local jurisdictions can amend their zone designations. The 2022 edition changed how LZ1, LZ2, and LZ3 are applied, creating two distinct urban zone categories with updated classification criteria.

Compliance forms are non-negotiable. A photometric plan submitted to a California building department without the NRCC-LTO (Nonresidential Certificate of Compliance-Lighting, Outdoor) forms will be rejected before the reviewer even looks at the light levels.

The key outdoor lighting requirements

Lighting Power Allowance (Table 140.7-A)

The general hardscape LPA is the wattage ceiling for your outdoor lighting installation. It's calculated from Table 140.7-A of the Energy Code, which provides three components by lighting zone:

Area Wattage Allowance (AWA): Watts per square foot of illuminated hardscape. Since the 2022 code, asphalt and concrete parking surfaces are no longer differentiated-a change from the 2019 code that simplified the calculation. Per the 2025 Nonresidential Compliance Manual (CEC-400-2025-008), the AWA values for general hardscape are 0.019 W/ft² for LZ2 and 0.021 W/ft² for LZ3.

Linear Wattage Allowance (LWA): Watts per linear foot of hardscape perimeter. This component provides additional allowance for edges and boundaries where perimeter lighting is needed. Per the 2025 code, the LWA is 0.15 W/lf for LZ2 and 0.2 W/lf for LZ3.

Initial Wattage Allowance (IWA): A flat per-site allowance that provides a baseline for small sites or sites with unusual geometry. The IWA can only be used once per site. Per the 2025 code, the IWA is 200 watts for LZ2 and 250 watts for LZ3.

Beyond the general hardscape allowance, Table 140.7-B provides additional allowances for specific applications: outdoor sales lots, sales frontage, vehicle service station canopies, building facades, outdoor dining areas, and-new in the 2022 code-an allowance for security camera illumination when cameras are installed more than 10 feet from a building.

The critical concept: the total installed wattage of all non-exempt outdoor luminaires must not exceed the sum of the general hardscape allowance and any applicable specific-application allowances. Exceed the allowance, and the plan fails-regardless of whether the light levels are appropriate.

Mandatory controls (Section 130.2)

Title 24 requires the following controls for outdoor lighting-these must be documented in the compliance forms and shown on the construction documents:

Daylight availability (Section 130.2(c)1). All outdoor lighting must be controlled by a photocontrol or astronomical time-switch control that automatically turns off lighting when daylight is available. Manual switches alone are not compliant.

Automatic scheduling (Section 130.2(c)2). All outdoor lighting must be controlled by an automatic scheduling control capable of reducing lighting power by 50 to 90 percent and separately capable of turning lighting off. The control must be programmable for at least two nighttime periods-a scheduled occupied period and a scheduled unoccupied period-with different light levels for each.

Motion sensing for applicable luminaires (Section 130.2(c)3). Outdoor luminaires greater than 40 watts, where the bottom of the luminaire is mounted 24 feet or less above grade, must be controlled by motion-sensing controls when used for general hardscape lighting (including parking lots), vehicle service station lighting, or outdoor sales lot lighting. The motion-sensing controls must be capable of reducing power by 50 to 90 percent within 15 minutes of vacancy detection, and must control no more than 1,500 watts per single sensor or zone. Exemptions include building facades, ornamental hardscape, outdoor dining, luminaires ≤40 watts, and luminaires mounted above 24 feet.

For photometric plan purposes, the controls requirements mean that the fixture schedule must specify controllable luminaires, and the compliance forms must document the control strategy for each lighting zone. A plan that shows appropriate light levels but doesn't address controls will fail the compliance review.

BUG rating requirements (Section 130.2(b))

All outdoor luminaires rated at 6,200 initial lumens or greater must comply with the BUG (Backlight, Uplight, and Glare) zonal lumen limits specified in Title 24, Part 11 (CALGreen), Section 5.106.8. The maximum allowable BUG ratings are determined by the site's lighting zone-lower lighting zones (LZ0, LZ1) have stricter BUG limits.

This requirement means that fixture selection for California projects must consider not just photometric performance (light distribution, lumen output) but also the fixture's tested BUG classification. The BUG data comes from the manufacturer's IES file and should be included in the fixture schedule on the photometric plan.

Lighting zones and light trespass

California's five lighting zones correspond roughly to the ambient light character of the area:

Lighting Zone	Description	Examples
LZ0	No ambient lighting	Undeveloped parks, preserves, wilderness
LZ1	Low ambient lighting	Developed parks, rural residential, wildlife areas
LZ2	Moderate ambient lighting	Light commercial, mixed-use, suburban residential
LZ3	Moderately high ambient	Commercial corridors, industrial areas
LZ4	High ambient lighting	Urban core, entertainment districts, major commercial

The default for most of California is LZ2. Local jurisdictions can designate different zones through a public process, and many coastal and mountain communities have adopted LZ1 for all or part of their boundaries.

The lighting zone directly affects the allowed LPA, BUG rating limits, and maximum light trespass at property boundaries. A project designed assuming LZ3 that's actually in an LZ2 jurisdiction will exceed the allowed wattage and fail review.

What Title 24 compliance means for your photometric plan

A California photometric plan submittal requires more than the standard deliverables. Specifically:

Standard photometric plan. The point-by-point calculation grid, fixture schedule, and site plan overlay that any photometric plan includes. This is the baseline-but in California, it's only the beginning.

Lighting Power Allowance calculation. A worksheet showing the illuminated hardscape area, perimeter length, applicable AWA/LWA/IWA values for the site's lighting zone, any additional specific-application allowances, the total allowed wattage, and the actual installed wattage. The actual must not exceed the allowed.

NRCC-LTO compliance forms. The NRCC-LTO-E (exterior lighting) Certificate of Compliance is a CEC-published form that documents the outdoor lighting installation's compliance with Section 140.7. This form must be completed and submitted with the permit documents. California's Virtual Compliance Assistant tool, available through Energy Code Ace, can help generate these forms-but the data inputs come from the photometric plan.

Controls documentation. A schedule or narrative describing the automatic control strategy for each outdoor lighting zone: what controls are installed, how they operate, and how they meet the scheduling, dimming, and motion-sensing requirements of Section 130.2.

Fixture data confirming BUG ratings. For luminaires ≥6,200 initial lumens, the fixture schedule or supporting documentation must show the BUG classification and confirm it falls within the limits for the project's lighting zone.

Common Title 24 pitfalls

These are the issues that cause California photometric plans to fail review-most are avoidable with upfront knowledge.

Calculating LPA by total site area instead of illuminated hardscape area. Title 24 defines "illuminated hardscape area" very specifically: it's the hardscape area within a square pattern around each luminaire that is ten times the mounting height, minus areas within buildings, beyond hardscape, beyond property lines, or obstructed by structures. This is almost always a smaller number than the total site area, resulting in a smaller allowance. Using total site area inflates the allowance and fails review.

Forgetting the compliance forms. The most common rejection in California isn't a technical lighting issue-it's a missing NRCC-LTO form. The plan reviewer may not even evaluate the photometric plan until the compliance forms are submitted.

Using the wrong lighting zone. Assuming LZ3 when the jurisdiction has designated LZ2 or LZ1. The CEC's lighting zone designations are available through the California Energy Commission, and local amendments are published by the jurisdiction. Check before designing.

Not addressing scheduling and motion controls. The fixture schedule shows non-dimmable luminaires, or the compliance forms don't document the automatic scheduling strategy (50-90% reduction capability) and the motion-sensing strategy for luminaires >40W mounted ≤24 feet. This is a controls compliance issue that causes rejection even when the light levels are correct.

Submitting a standard photometric plan without California-specific documentation. A plan designed for a project in another state-even a technically excellent one-won't pass California review without the LPA calculations and NRCC-LTO forms.

Title 24 and dark sky: when both apply

Several California municipalities have adopted their own dark sky ordinances on top of Title 24. Communities like Malibu, Rancho Mirage, and portions of San Diego County have local outdoor lighting codes with provisions that go beyond Title 24's requirements-lower CCT limits, stricter BUG ratings, lumen caps, or curfew schedules.

When both Title 24 and a local dark sky ordinance apply, the more restrictive requirement governs for each parameter. The photometric plan must demonstrate compliance with both sets of regulations-Title 24's energy code calculations and the local ordinance's dark sky provisions. This layered compliance is where many project teams get into trouble, and where the cost of a professional photometric plan is most clearly justified.

Frequently asked questions

What edition of Title 24 is currently in effect?

The 2025 edition of Title 24 Part 6 took effect January 1, 2026. All projects with permit applications filed on or after that date must comply with the 2025 code. Projects permitted before that date may comply with the 2022 edition.

Does Title 24 apply to all outdoor lighting or just commercial?

Title 24 Part 6 applies to both nonresidential and residential outdoor lighting, but the requirements differ. The prescriptive requirements in Section 140.7-including the LPA calculations and controls requirements discussed in this article-apply to nonresidential and hotel/motel occupancies. Residential outdoor lighting has separate, generally simpler requirements under Section 150.0.

What happens if my photometric plan exceeds the Lighting Power Allowance?

The plan fails compliance review. You have two options: reduce installed wattage (by selecting more efficient fixtures, reducing fixture count, or using lower-wattage lamps) until the actual power falls at or below the allowance, or demonstrate compliance through the performance approach, which evaluates the entire building's energy budget holistically. For most standalone outdoor lighting projects, the prescriptive LPA approach is simpler.

Do I need a special form to submit with my photometric plan in California?

Yes. The NRCC-LTO-E (Certificate of Compliance-Lighting, Outdoor-Exterior) is required for nonresidential exterior lighting projects. This is a CEC-published form, and submitting a photometric plan without it will result in rejection before technical review begins.

Is Title 24 the same as CalGreen?

No. Title 24 Part 6 is the Energy Code-it governs energy efficiency requirements including lighting power and controls. CalGreen is Title 24 Part 11-the California Green Building Standards Code-which includes additional voluntary and mandatory requirements for sustainability, including some BUG rating limits for outdoor lighting. Both may apply to your project, but they are separate code sections with different requirements.

Can an out-of-state photometric designer prepare a Title 24 compliant plan?

Yes, provided they're familiar with California's specific requirements-the LPA calculation method, NRCC-LTO forms, lighting zone system, and controls mandates. There is no California licensing requirement specifically for photometric plan preparation. However, the compliance forms and energy code documentation are sufficiently California-specific that a designer unfamiliar with Title 24 is likely to produce an incomplete submittal.

If you need a refresher on what a permit-ready package includes before applying these California requirements, see our guide to photometric plans or the service overview.