Title 24 Demand Response Requirements

Demand response building code requirements are generally triggered by the construction of or additions to facilities but may also be triggered by the replacement of specific pieces of equipment. The building code requires the ability to participate in demand response events but does not require the actual participation in demand response events.

To listen to a recorded webinar on the demand response requirements in 2016 Title 24, please follow the links below:

Additional system and process information is found below.

HVAC Systems

Heating, Ventilation, and Air Conditioning systems with Direct Digital Control to Zone level must have ability to:

  1. Automatically adjust temperature set point by ±4° Fahrenheit in non-critical zones from a central point
  2. Return the system to its original state following the event
  3. Provide an adjustable rate of change
  4. Provide three operating states: Automated Demand Shed, Manual, and Disabled.

Thermostatic controls for all single zone air conditioners and heat pumps, shall comply with the requirements of Section 110.2(c) and Reference Joint Appendix (JA5). Similarly, for altered units, thermostats must comply with JA5 that defines technical specifications for occupant controlled smart thermostats (OCSTs), and requires units to be capable of demand responsive control.

Indoor Lighting Systems

Buildings greater than 10,000 ft² shall be capable of automatically reducing lighting power in response to a Demand Signal. Total lighting power must have the ability to automatically be lowered by a minimum of 15% of the installed wattage upon receipt of a demand response signal sent by demand response program implementers.

Buildings less than 10,000 ft² that respond to a Demand Signal can qualify for a Power Adjustment Factor (PAF) of 0.05. Reducing lighting in non-habitable spaces (bathrooms, storage, hallways, etc.) or spaces with LPD < 0.5 w/ft² does not qualify for this PAF.

In existing buildings, when are lighting controls required?

In existing buildings, the code makes a distinction between a modification in place and an alteration and may require demand response functionality in alterations. Alterations occur when the building is changing use types (e.g., was used for warehouse but is being converted to office space) or if fixtures are being relocated.

Alterations consist of:

  • Removing and reinstalling a total of 10% or more of the existing luminaires
  • Replacing or adding entire luminaires
  • Adding, removing, or replacing walls or ceilings along with any redesign of the lighting system

Luminaire Component Modifications, where 70 or more existing luminaires are modified, consist of:

  • Replacing the ballasts or drivers and the associated lamps in the luminaire
  • Permanently changing the light source of the luminaire
  • Changing the optical system of the luminaire

Table 141.0-E below from the 2016 Code describes Demand Responsive Controls when altering luminaires. If reducing lighting power more than 85% from existing, DR controls are not required.


Electronic Message Centers

Electronic Message Centers (also known as digital signage or digital billboards) with new connected lighting load >15 kW must be capable of reducing lighting power by at least 30%, unless not permitted by health and safety statue or another ordinance or regulation.


The California 2016 Building Energy Efficiency Standards, effective January 1, 2017 – December 31, 2019, includes demand response readiness requirements for the following systems and processes:

  • HVAC Systems – Sec. 120.2(h)
  • Indoor Lighting Systems – Sec.130.1(e)
  • Electronic Message Centers – Sec. 130.3

California’s Building Energy Efficiency Program website hosts a number of resources, including full Title 24 Building Code language and the Reference Appendices, including JA5, mentioned above.

Acceptance Documents are forms that must be completed to demonstrate compliance with Title 24.

The Title 24 Compliance Manual helps building owners, architects, engineers, designers, energy consultants, builders, enforcement agencies, contractors and installers, and manufacturers comply with and enforce the California Building Energy Efficiency Standards (Energy Standards) for nonresidential buildings.

For more information on how facilities can take advantage of demand response capabilities, please contact the PG&E Automated Demand Response program.

Frequently Asked Questions

  1. What is the base wattage that is taken pre-demand event? Do you need to account for occupancy sensors, daylighting, manual switching, tuning?

The baseline is the connected lighting load.  If a Power Adjustment Factor for task tuning is claimed, then the baseline is takes as the connected lighting load minus any permanent task tuning (can be thought of as the effective maximum load.)  The baseline does not consider further load reductions that may result from variable control strategies such as reduced lighting load from occupancy sensors, daylight harvesting, or manual switching.

Note that even if a task tuning Power Adjustment Factor is not claimed but task tuning is implemented, facility lighting systems still must be able to receive and respond to a demand response signal if the facility is 10,000 square feet or more and has a lighting power density of more than 0.5 watts per square foot.

  1. Does JA5 apply to residential, as well as commercial?

Yes, the Joint Appendices apply to both residential and non-residential. The Reference Appendices include 3 sections: specifically residential, specifically non-residential, and joint (as in both residential and non-residential) appendices.

  1. Does Title 24 specify OpenADR 2.0a or OpenADR 2.0b for Occupant Controlled Thermostats?

No, JA5 only requires OpenADR 2.0 and does not specify between a or b. Option a or b have different requirements based on whether the signal is initially sent to an off-site energy management system (EMS) or goes directly to the site.  Please see JA5.3.1 Communication Interface for more information. Smart Energy Profile 1.1 is also a recognized protocol but is typically seen in residential application.