01Key facts / TL;DR
Yes, a lighting-only tenant improvement can need Part 6 documentation even when HVAC and exterior walls remain unchanged.
It depends on the actual alteration: maintenance lamp replacement is not automatically the same scope as replacing luminaires or changing controls.
No, lower fixture wattage alone does not demonstrate every applicable lighting-control requirement.
It depends which certificates and testing apply; confirm the permit scope, application date and submission requirements with the AHJ.
02Lighting-only does not mean documentation-free
Commercial tenant work may leave the building shell and mechanical systems untouched while substantially changing lighting. New luminaires, altered layouts or controls create a different compliance question from maintenance work. Identify the work first rather than assuming a small tenant area or an LED product label establishes an exemption.
The CEC’s 2025 indoor lighting certificate addresses prescriptive compliance for new and altered lighting systems. Its project-scope and results sections distinguish affected areas, power calculations and controls compliance. The document is a useful educational reference, not a universal instruction to submit the same pages for every tenant.
A lighting-only package should identify what it covers and what is retained or outside scope. It is not permission to omit genuinely altered HVAC, envelope or other regulated systems from the broader permit. Conversely, do not commission a whole-building performance model solely because a lighting calculation is needed.
CEC 2025 indoor lighting certificateBroader tenant-improvement guide
03Maintenance, luminaire changes and controls are different decisions
Describe whether work replaces lamps, replaces entire luminaires, relocates fixtures, changes circuits or changes control functions. “Like for like” is incomplete without saying which of those facts stays the same. The applicable alteration method and conditions must be checked against the current requirements.
Do not assume every maintenance lamp swap requires a complete TI package, or that every one-for-one fixture change is exempt. The current certificate includes an alteration-method section with its own conditions. This guide does not create a numeric exemption threshold or grant a project a particular simplified method.
Controls deserve their own scope description. Identify applicable switching, dimming, occupancy/daylight response or other designed functions without assuming that a single sensor meets every requirement. The responsible designer should establish the required arrangement and show it consistently on plans and schedules.
04Lighting TI decision checklist for applicants
Use the following scope questions before requesting final certificates.
- +Application basis: record the AHJ, permit application date, tenant/building classification and whether this is lighting-only work or part of a larger TI.
- +Affected areas: identify tenant boundaries, room uses and areas, conditioned/unconditioned spaces and retained versus altered lighting. Do not use the whole shopping center area by default.
- +Fixture evidence: provide counts, tags, full luminaire descriptions and supported input wattage, including relevant drivers or track-system information.
- +Control evidence: supply the controls narrative, switching/control-zone drawings and product data. Mark existing controls retained and changes proposed.
- +Documentation stage: identify design certificates requested for permit, installer records and acceptance/verification tasks, with responsible participants assigned.
05Power density is one part of the answer
Lighting power density relates lighting power to an applicable area, but a low-looking number does not establish compliance by itself. The area classification, permitted method, fixture wattage basis and any supported adjustments matter. Do not count only lamp watts when the relevant evidence concerns the luminaire.
The CEC certificate includes Complete Building and Area Category calculation concepts, alongside controls compliance and applicable alteration sections. An Area Category approach can be relevant to tenant scopes, but the designer/preparer should establish the permitted approach for the actual project rather than borrowing a restaurant or office allowance without checking use.
Separate conditioned and unconditioned areas where required by the chosen documentation. Make room names and boundaries agree among the reflected ceiling plan, area schedule and certificate. A spreadsheet total that uses different rooms from the drawings is not a reliable submission simply because its arithmetic is correct.
06Which nonresidential forms—and who completes them?
NRCC is the design-compliance family. For relevant indoor lighting scopes, consult the current CEC NRCC-LTI resource and catalog to identify the appropriate certificate and completion method. “LTG” in an informal request is not enough to identify an edition, official form or responsible signer.
NRCI documents applicable installation work. NRCA records applicable acceptance testing, with qualified acceptance-testing participants where required; NRCV has its own verification purpose when applicable. Not every project needs every family. A completed design certificate does not certify installation or replace controls acceptance testing.
ECC is current terminology for applicable residential Energy Code field verification, with HERS appearing in older-cycle residential records. Commercial lighting acceptance testing is not simply renamed HERS testing. Keep the residential verification discussion separate from the actual nonresidential responsibilities.
Nonresidential form-family responsibilitiesCEC 2025 nonresidential forms catalog
07Worked example: an office lighting-only alteration
ILLUSTRATIVE ONLY: an applicant proposes replacing 18 luminaires in a 2,400-square-foot office while retaining HVAC and exterior walls. Initial intake supplies only fixture cutsheets. The preparer requests the reflected ceiling plan, room/area schedule, existing-versus-proposed fixture list, supported wattages and controls narrative.
A revised ceiling plan reveals separate meeting and open-office areas with different proposed controls. The designer resolves the intended controls, and the preparer checks the applicable lighting calculation/documentation method rather than assuming every room has the same conditions. These numbers describe the example, not an exemption, allowance or compliance result.
For permit, the team aligns the applicable NRCC evidence with the drawings. During construction, the contractor and any required acceptance-testing participant handle their separate records. If a fixture is substituted, the team reviews wattage and control compatibility before treating the original documents as unchanged.
08What to send and what the quote covers
Send a readable PDF plan set, reflected ceiling plan, fixture schedule, controls diagrams/narrative, tenant-area information and the complete correction letter if relevant. DWG/ZIP support may accompany the plans. Label revisions and the reviewed set so a preparer does not calculate an obsolete layout.
The 2025 Energy Code applies to permit applications on or after January 1, 2026. Confirm the AHJ-recorded date and use matching forms; a supplier quotation date does not choose the edition. Ask about amended or newly filed scopes instead of silently mixing an older certificate with current drawings.
Published commercial report pricing is $399 through 5,000 square feet, $599 for 5,001–15,000, and custom above 15,000. Commercial rush is +$149 for next-business-day production after complete inputs, not unconditional delivery or permit approval. Confirm the scoped area and deliverables through intake.
Field testing, acceptance testing, registry fees, CALGreen and AHJ permit fees are excluded. Energy documentation is not a lighting design commission or a guarantee of city review timing. Request a defined package and coordinate separate construction/testing participants before work is installed.
09Six lighting-only TI questions
Can lighting-only work require energy documents without HVAC changes?
Yes. Regulated lighting alterations can have their own Part 6 requirements. Clearly identify the lighting scope and confirm the required certificate without assuming all building systems changed.
Is every LED lamp replacement a regulated lighting TI?
Do not assume that. Distinguish maintenance lamp work from luminaire, layout and control alterations, then confirm applicable conditions with the responsible team and AHJ.
Does using less power remove the need to address controls?
No. Applicable control requirements are not satisfied solely by a lower wattage total. Document the designed functions, zones and relevant equipment consistently with the plans.
Should the calculation use the entire landlord building area?
Not automatically. Establish the permit and calculation boundaries, affected spaces and permitted method. A tenant scope should not silently use unrelated floor area to produce a favorable result.
Does an NRCC certificate include acceptance testing?
No. Design compliance, installation certification and applicable acceptance testing are separate responsibilities. The report scope excludes field/acceptance testing; coordinate those services when required.
What happens when fixtures change after permit documents are prepared?
Send the proposed substitution, wattage/control evidence and changed drawings for review. Do not assume an earlier calculation still describes the installed system or that every change needs the same revision scope.
10Choose the next documentation step
Use the published residential/commercial square-footage menu to understand report pricing, then send a scoped request rather than assuming a full model is necessary. Field testing, acceptance testing, registry fees, CALGreen and AHJ permit fees are separate. Intake is not payment, production acceptance or permit approval. This is educational information, not legal advice; confirm the applicable requirements and documentation with the authority having jurisdiction (AHJ).
Start with the Title 24 decision hubDo I need Title 24 for commercial?Do I need Title 24 for remodel?Do I need Title 24 for ev charger?Confirm the application’s code editionWhat to send for an energy reviewNonresidential form responsibilitiesSee published PricingGet a Quote / upload plans