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Submitter: Noel Williams Herriman, UT
Recommendation:
Add a new Exception to read as follows:
"Exception: Where other codes or standards limiting the amount of energy that may be used for lighting in a specified occupancy are
adopted by the authority having jurisdiction, the unit loads for those occupancies shall not be required to be larger than the maximum
unit load permitted for that occupancy."
Substantiation:
The existing unit loads for certain occupancies, especially office buildings and banks, are significantly higher (almost double) the unit
loads permitted by model energy codes for those same occupancies. For example, energy codes may limit lighting loads in office
buildings to about 1.8 VA per square foot, which is entirely adequate where electronic ballasts and T-8 fluorescent lamps are used. (In
fact, one intended effect of the energy codes is to require such energy efficient sources.) Nevertheless, these real loads are not permitted
to be used under the current language of this section.
The existing unit loads do not consider (or encourage or reward) the use of modern energy-efficient lighting sources. Furthermore, once
this artificially high calculated load is determined under 220.3(A), it must be treated as a continuous load for purposes of determining
minimum feeder or service capacity. Currently, Example D3 in Annex D shows a case in which the real load is slightly less than the
calculated load, and the calculated load is taken at 125 percent for sizing feeders or services. The difference is not significant in this
example, but the requirement illustrated by the example is very significant when the maximum load permitted by a jurisdiction is only
about half of the phantom "calculated" load derived from this section. This is a very severe penalty for occupancies with large floor
areas. Since the permission to reduce unit loads is conditional on the adoption of a limit on the use of energy, this proposal will not
compromise safety. Currently, the only way a jurisdiction can recognize lower calculations under the NEC is by special permission,
which means special permission must be issued on every such project. The primary argument in favor of retaining the higher numbers is
that it tends to build in a significant amount of spare capacity which may be used later under the provisions of 220-35. However, spare
capacity is not an intended outcome of complying with the NEC 90.1(B).
Panel Meeting Action: Reject
Panel Statement:
See the panel action and statement on Proposal 2-299 (Log #2880).
Number Eligible to Vote: 13
Affirmative: 13

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Panel Statement:
The current requirements of this section are not in conflict with energy codes. The requirements of Article 220 provide means to
calculate adequate service and feeder load capacities but does not require that this entire capacity be connected.
Number Eligible to Vote: 13
Affirmative: 11 Negative: 2 Ballot Results:
Explanation of Negative:
BECKER: I concur with Mr. Dobson's Explanation of Negative Vote.
DOBSON: The proposal seeks to allow the electrical designer the option to use different lighting power
densities based on other mandatory codes in a given jurisdiction. In specific localities with mandatory
maximum lighting power densities based on energy code requirements, power density maximums are less,
often by half, than those of the NEC. Yet the designer is not permitted to take advantage of the potentially
lower cost electrical system where higher efficiency fixtures are not only allowed, but required. An example
is the state of Massachusetts commercial energy code that specifies the interior and exterior lighting power
allowance permitted for different types of facilities; offices for example have a maximum of 1.3 watts per
square foot whereas the Table 220.3(A) specifies 3.5 watts per square foot.

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