DOCKETED  
Docket Number:  20-AAER -01 
Project Title:  Amendments to the Title 20 Appliance Efficiency Regulations 
Rulemaking  
TN #:  237318  
Document Title:  Final Statement of Reasons (FSOR)  
Description:  Final Statement of Reasons, including responses to comments 
received, for the 2020 Repeal of Self -Contained Lighting 
Controls and Other Amendments Rulemaking  
Filer:  Carlos Baez  
Organization:  California Energy Commission  
Submitter Role:  Commission Staff   
Submissio n Date:  3/26/2021 11:47:15 AM  
Docketed Date:  3/26/2021  
 STATE OF CALIFORNIA — NATURAL  RESOURCES AGENCY    Gavin Newsom, Governor 
CALIFORNIA ENERGY COMMISSION
1516 Ninth Street  
Sacramento, California 95814  
Main website: www.energy.ca.gov 
CEC -57 (Revised 1 /19)
FI
NAL STATEMENT OF REASONS 
2020 Repeal of Self -Contained Lighting Controls and Other Amendments  
Z # 2020- 0929- 03 
UPDATE OF THE INITIAL STATEMENT OF REASONS 
There were no modifications to the regulation text following the close of the public 
comment period. No changes or updates to the ISOR are necessary.  
LOCAL MANDATE DETERMINATION 
The California Energy Commission has determined that this action will not result in a 
local mandate on local agencies or school districts.  
CONSIDERATION OF ALTERNATIVE PROPOSALS 
The Energy Commission determined pursuant to Government Code S ection 
11346.9( a)(4) that no alternative before it would be more effective in carrying out the 
purpose for which this action is proposed, n o alternative would be as effective as and 
less burdensome to affected persons than the adoption of the proposed regulation,  or 
would be more cost  effective to affected private persons  and equally effective in 
implementing the statutory policy or other provision of law.   
Ex
cept as discussed in the summary and response to comments, no alternatives were 
recommended.  
ALTERNATIVES THAT WOULD LESSEN ADVERSE ECONOMIC IMPACT ON 
SMALL BUSINESSES The CEC considered impacts to small businesses and alternatives in the Notice of 
Proposed Action and the Initial Statement of Reasons, and hereby incorporates these discussions by reference. The CEC did not identify any small businesses that will be adversely impacted by the adopted regulations. The adopted regulations are not likely to have a significant adverse economic impact on small business and no alternatives 
were proposed that would lessen any adverse economic impact on small business. For the purposes of this analysis, the CEC used the consolidated definition of small business in Government Code section 11346.3(b)(4)(B).  
INCORPORATION BY REFERENCE  
No documents are proposed to be incorporated by reference.  
 
 
 
  2  
 SUMMARY OF RESPONSES TO PUBLIC COMMENTS RECEIVED  
All responses to public comments, including acceptance of recommendations and justification when recommendations were not accepted, are hereby incorporated by 
reference to this Final Statement of Reasons, and included in the rulemaking file. 1  
Written Comments Received  
2020 Repeal of Self -Contained Lighting Controls and Other Amendments  
Title 20, Division 2, Chapter 4, Article 4 California Code of Regulations  
45-Day Comment Period  
October 9, 2020 Through November 23, 2020  
 
Commenter’s Name  Comments/  
Suggested Revisions  Response  
Alex Boesenberg 
and Phil Squair,  
National Electrical 
Manufacturers 
Association  General Letter of Support  
 No response required  
Stephen R. Irving, 
Lutron Electronics 
Co., Inc.  Lutron supports the proposed removal of 
Self-Contained Lighting Controls from 
Title 20  Appliance Efficiency Regulations 
as it eliminates redundant requirements and reduces  confusion about 
certifications.  
 1. Elimination of Redundant 
Requirements  
As stated in the Initial Statement of Reasons (IS OR), requirements for 
Lighting Controls were transitioned to the 
Title 24 Building Energy Code during the 2019 revision, leaving duplicative requirements in Title 20. Elimination of these Title 20 requirements was anticipated during that development and 
continues to be appropriate today.  General comment of support.  
No Response required.  
Stephen R. Irving, 
Lutron Electronics 
Co., Inc.  2. Eliminate Customer Confusion 
regarding Certification Requirements  
Lutron has received several questions about certifications in the MAEDbS for Systems- Based  Lighting Controls from 
our customers in California. These 
customers were accustomed to  Comment Acknowledged.  
No changes required.   
Yes, if this rulemaking were to be approved and adopted, we would then archive all current listings of self-contained lighting controls in MAEDbS and 
prevent the submission of new models of lighting 
controls. The models will still be searchable for 2 Commenter’s Name  Comments/  
Suggested Revisions  Response  
certifications for our Self-Contained 
Lighting Controls and expected the same 
for our Systems -Based Lighting Controls. 
One can easily understand their confusion as the two types of controls are frequently used to fulfill the same customer need (use case).  
 Archiving existing certifications for Self -
Contained Lighting Controls in the MAEDbS is the best fix. Customers looking for certifications simply wanted to ensure that they comply with CEC requirements. There is no need to maintain certifications for Lighting Controls.  
 
To prevent further confusion during this transition, we recommend that all existing database entries be archived at the same time and that any MAEDbS searches for Lighting Controls return a simple explanation informing customers that certif ication is no longer required. This 
explanation will help prevent concern from customers and retailers who buy, use, 
and sell these energy -saving devices.  histori cal purposes, but new certifications will no 
longer be required or permitted. We will post notifications within the MAEDbS system to inform users of the changes and also send out a list server email notice.  
 
Steve McCarthy  
Vice President, Public Policy  
California Retailers 
Association  
  
Out of my own confusion I missed this morning’s hearing and had intended to testify.  I wonder if there is any remaining 
opportunity to have further conversation about portable luminaires, and specifically the requirement f or prepackaged 
bulbs?   We expressed our concern in last 
year’s proceeding on specialty bulbs that 
with the marketplace limited to high Comment Acknowledged  
No Change  
 
Thanks for reaching out  to us. Yes, we  recognize that 
the “bulb -in-the-box” requirement needs to be 
reassessed,  mainly due to subsequent appliance 
rulemakings and LED market transformation, which 
has increased efficiency in lighting.   
   
 3 Commenter’s Name  Comments/  
Suggested Revisions  Response  
efficiency bulbs, it would render obsolete 
the subsection (n)(4) that those bulbs be 
included pre- sale on portable 
lumina ires.  In fact, that requirement may 
now be a net contributor to the waste stream, in addition to making the products more expensive for consumers and limiting product options.  
We noted that this issue is not part of this particular update.   Would it be po ssible to 
connect on this?  
 My apologies for the lateness of this issue and thank you for any help you can provide.      
 
   Unfortunately, besides the proposed removal of the 
minimum light output requirement, no additional 
changes regarding portable luminaires can be made 
in this current rulemaking (docket 20- AAER -
01) because it would be outside of  the limited 
scope  for this rulemaking.  Staff considered  additional 
changes to portable luminaires  at the time the 
rulemaking was started, but realized 
that additional  changes  would involve other  products 
covered and/or efficiency requirements, which 
would  require significant research and staff report, an 
effort that could not be undertaken at the time.   
   
However, we anticipate a rulemaki ng in the future to 
fully address portable luminaire requirements in Title 
20. When this happens, we would reach out to 
industry to gain further insights into this topic. If you 
haven’t already, please subscribe to our “appliances” 
list server to receive e mail updates on all rulemaking 
activity for Title 20. You would receive an email when 
this new rulemaking is eventually initiated. You can 
sign up here:   
https://ww2.energy.ca.gov/listservers/index_cms.html   
 
 
 
 
 
    
   
 1  
Public Hearing Comments Received  
2020 Repeal of Self -Contained Lighting Control s and Other Amendments  
Title 20, Division 2, Chapter 4, Article 4 California Code of Regulations  
Public Hearing  
December 3, 2020  
 
Commenter’s Na me Comments / 
Suggest ed Revision s Response  
  
No Comments were received during the public hearing