Manufactured in Canton, Georgia | BACnet-Native | UL Listed | ASHRAE 90.1 & IECC 2021 Compliant
What BABA Is and Why It Matters for Lighting Control Specifications
The Build America, Buy America Act (BABA) was enacted November 15, 2021, as part of the Infrastructure Investment and Jobs Act (IIJA). It established the broadest domestic content requirement in U.S. history — applying a Buy America preference to all federal financial assistance used for infrastructure projects.
Before BABA, domestic content rules were a patchwork across agencies. FHWA had requirements for iron and steel. FTA had its own rules. Many agencies had nothing. BABA unified these into a single government-wide framework under 2 CFR Part 184, effective October 23, 2023.
IMPORTANT — This Applies to More Projects Than Most Engineers Expect
BABA applies whenever a project receives federal financial assistance — not only when the federal government directly procures the materials.
This includes: IIJA infrastructure grants, DOE energy efficiency grants, HUD-funded building projects, EPA-funded facilities, federal education funding (ESSER, E-Rate capital), and any state or local project that accepts federal grant dollars.
If your client’s project touches federal money in any form, lighting control panels permanently incorporated into the building are subject to BABA.
What BABA Requires for Manufactured Products (Including Lighting Controls)
Lighting control panels are classified as manufactured products under BABA. For a lighting control system to be BABA-compliant, it must meet two conditions:
| Condition | What It Means in Practice |
|---|---|
| All manufacturing must occur in the United States | Assembly, integration, testing, and all manufacturing processes must take place on U.S. soil. Importing a finished product and reboxing it does not qualify. |
| At least 55% of the cost of components must be domestic in origin | More than half the component cost by value must come from U.S.-mined, U.S.-produced, or U.S.-manufactured sources. This is the threshold that disqualifies many offshore-heavy manufacturers. |
| Domestic content threshold rises over time | 60% from 2023, 65% from 2024 under the Buy American Act (BAA). BABA’s 55% threshold applies to federally funded (non-direct-procurement) projects. Verify current thresholds at time of specification. |
| Self-certification by manufacturer | Compliance is certified by the manufacturer. Request written BABA compliance certification and component cost documentation for the project record. |
Sources: U.S. Department of Energy — Build America, Buy America; OMB Memorandum M-22-11; 2 CFR Part 184; Infrastructure Investment and Jobs Act (IIJA), Pub. L. No. 117-58.
BAA vs. BABA — Understanding Which Rule Applies
Two separate domestic content frameworks apply to lighting controls specifications, and the distinction matters for how you document compliance:
| Buy American Act (BAA) | Build America Buy America (BABA) | |
|---|---|---|
| Enacted | 1933 | 2021 (IIJA) |
| Applies to | Direct federal purchases (VA hospitals, military bases, federal offices) | Federally funded infrastructure projects (any project receiving federal grants or financial assistance) |
| Domestic component threshold | 65% (2024) → 75% (2029) | 55% of component cost |
| Manufacturing requirement | Must be manufactured in U.S. | All manufacturing processes must occur in U.S. |
| Who certifies | Manufacturer self-certification | Manufacturer self-certification — document for project record |
| Typical lighting control projects | Federal agency facilities, military installations | Schools, universities, hospitals, municipal buildings, transit, roads — any project touching federal grant money |
SPECIFIER TIP — Specification Language Tip
When writing lighting control specifications for projects with any federal funding, include a BABA compliance requirement in Division 26 or Division 16 Lighting Controls sections.
Request written manufacturer certification of BABA compliance, domestic manufacturing location, and component cost breakdown as a submittal requirement.
Blue Ridge Technologies can provide this documentation upon request.
Why Blue Ridge Technologies Is the Right Answer for BABA Projects
Blue Ridge Technologies is a privately held U.S. manufacturer. Founded in 2009, the company designs, manufactures, and ships lighting control systems from its facility in Marietta, Georgia. Products are assembled in the United States and the company holds multiple U.S. patents in energy management.
For MEP engineers specifying lighting controls for federally funded projects, this matters — and it matters in ways that affect both the specification and the project schedule.
U.S. ManufacturerDesigned and assembled in Marietta, Georgia. Not imported and reboxed. Domestic manufacturing documentation available for project submittals. |
UL Listed ProductsBRT products are tested and certified by Underwriters Laboratories (UL). UL508A compliance for industrial control panels. Appropriate for federal and institutional applications. |
BACnet International MemberBRT is a BACnet International member with BTL-listed products. Open protocol, vendor-neutral, integrates with any BAS platform without proprietary gateways. |
KEY POINT — What to Include in the Submittal Request
- Written BABA compliance certification from Blue Ridge Technologies
- Domestic manufacturing location (Marietta, Georgia)
- Component cost breakdown confirming domestic content threshold
- UL listing documentation
- BTL certification for BACnet compliance
- Product datasheets confirming U.S. country of origin
Contact: Andrew Dunkleberger — adunkleberger@brtint.com | 678-223-1173
California Title 24 2022 — What MEP Engineers Are Required to Specify
California’s Building Energy Efficiency Standards (Title 24, Part 6) represent the most demanding commercial lighting control code in the United States. The 2022 version, which took effect January 1, 2023, introduced significant changes to mandatory lighting control requirements for nonresidential buildings.
For MEP engineers working in California — or specifying systems for federal projects with California locations — these requirements define the minimum acceptable specification. Blue Ridge Technologies meets all of them natively.
2022 Title 24 Mandatory Lighting Control Requirements — At a Glance
| Control Requirement | Title 24 2022 Mandate | How Blue Ridge Meets It |
|---|---|---|
| Manual Area Controls | Required in all spaces. Separate switching for general, display, and ornamental lighting. | Standard in all BRT panels — relay outputs provide independent zone control per circuit. |
| Multilevel Lighting (Section 130.1) | All indoor spaces must support at least two lighting levels. Office spaces require partial-ON levels of 50–70% as an intermediate step. | 0-10V dimming via AU48 modules. Multilevel switching via relay configuration. Programmable in Essentials software. |
| Automatic Shutoff | ALL indoor lighting requires automatic shutoff via occupancy sensor (20-min max delay) or time-switch. No manual-only shutoff permitted. | Scheduling via CM controller. Occupancy sensor inputs via UI16/AU48 universal inputs. Time-switch built into Essentials software. |
| Occupancy Sensing — All Offices (NEW in 2022) | Required in ALL office areas regardless of size. Control zone limited to 600 sq ft. Vacancy sensors required in private offices. | Universal inputs (UI16, AU48) support any low-voltage occupancy or vacancy sensor. Zone configuration in Essentials. |
| Automatic Daylighting Controls | Required within 15 ft of windows and under skylights in spaces over 120 sq ft. Must dim or switch off when sufficient daylight is present. | 0-10V dimming via AU48 analog outputs. Light sensor inputs via UI16/AU48. Daylight setpoints configured in Essentials. |
| Demand-Responsive Controls (NEW scope in 2022) | Required for buildings 10,000 sq ft and larger. Must be capable of reducing lighting load to 80% or less in response to utility signal. Acceptance testing required. | BACnet demand response supported natively. Utility signal integration via BAS. Lighting load shed commands executed through CM. Acceptance test documentation available. |
| Plug Load Control — NEW in 2022 | Required in office spaces, kitchens, lobbies, conference rooms, copy rooms within 30 minutes of vacancy. | DU88 digital outputs (24VAC/VDC) control switched receptacles. Coordinated with occupancy sensing through Essentials logic. |
Sources: California Energy Commission, 2022 Building Energy Efficiency Standards (Title 24, Part 6); Electrical Contractor Magazine, Title 24 Requirements for Sensors and Controls (2023); Lighting Controls Academy, What’s in the New Title 24 (2022).
System Flexibility — Specifying BRT Across Project Types
One of the practical challenges MEP engineers face with lighting controls is that no two projects are identical. Federal funding requirements, state energy codes, building type, legacy infrastructure, and owner preferences all shape what a compliant specification looks like. Blue Ridge Technologies is designed to adapt to all of them.
| Project Scenario | The Challenge | BRT Solution |
|---|---|---|
| New federal building — BABA required | Must document domestic manufacturing and component cost. Proprietary systems may not qualify. | BRT manufactured in Marietta, GA. Written BABA certification and component documentation provided. Specify by name in Division 26. |
| California new construction — Title 24 2022 | Must meet occupancy sensing, daylighting, demand response, multilevel, and automatic shutoff simultaneously. | All control strategies supported natively. Single BACnet-native system handles all Title 24 mandatory requirements. One submittal, one vendor. |
| Federal building in California — BABA + Title 24 | Both compliance frameworks apply simultaneously. Documentation burden is high. | BRT is U.S.-manufactured (BABA) and meets all Title 24 2022 mandatory control requirements. One system, one documentation package. |
| K-12 school with ESSER or E-Rate funding | Federal education grants trigger BABA. Building may be in California (Title 24) or subject to IECC. | BRT supports BABA documentation, IECC compliance, and Title 24 compliance. Specify CP or RI depending on whether new or retrofit installation. |
| Healthcare facility — IIJA or HHS grant | Federal funding triggers BABA. UL924 emergency lighting required. 24/7 operation limits shutdown time. | RE04 and RE224 modules are UL924-rated for emergency lighting. BABA documentation available. Retrofit options minimize downtime. |
| Campus retrofit — phased federal funding | Existing infrastructure must be reused where possible. BABA applies to new equipment only. | Retrofit Kit (RK) and Retrofit Interior (RI) options reuse existing enclosures, relays, and wiring. New BRT control electronics are U.S.-manufactured and BABA-compliant. |
| Municipal building — EPA or DOE grant | BABA applies. BAS integration required. Owner demands open protocol. | BACnet-native — no proprietary gateways. Integrates with any BAS. Open protocol meets owner and agency requirements. BABA documentation provided. |
Specification Guide for MEP Engineers
Blue Ridge Technologies can be specified in Division 16 (Electrical) or Division 26 (Electrical — CSI MasterFormat 2004+), Section 26 09 23 Lighting Control Devices or 26 09 26 Lighting Control Panelboards.
Suggested Specification Language (Short Form)
Section 26 09 26 — Lighting Control Panelboards
Provide BACnet-native lighting control panels manufactured in the United States, compliant with the Build America, Buy America Act (BABA) requirements. Panels shall be assembled and manufactured at a domestic U.S. facility. Manufacturer shall provide written BABA compliance certification, domestic manufacturing documentation, and component cost breakdown upon request.
Acceptable manufacturer: Blue Ridge Technologies, Marietta, Georgia (brtint.com). Panels shall communicate natively on BACnet MS/TP or BACnet/IP without proprietary gateways. All control modules shall be UL listed. System shall support: (a) occupancy sensing on all universal inputs, (b) 0-10V dimming on analog outputs, (c) automatic shutoff scheduling, (d) demand response via BACnet, and (e) BAS integration through standard BACnet objects and properties.
For California projects: System shall meet all mandatory lighting control requirements of Title 24, Part 6, 2022 Edition, including Section 130.1 (interior controls), occupancy sensing in all office areas per Section 130.1(c), automatic daylighting controls per Section 130.1(d), and demand-responsive controls per Section 130.1(e).
Product Selection Guide for Specifiers
| Product | When to Specify | Key Capabilities |
|---|---|---|
| Control Panel (CP) | New construction or gut renovation | BACnet-native, relay switching (RO04/RE04), 0-10V dimming (AU48), occupancy inputs (UI16), demand response, UL listed. Full BABA documentation available. |
| Retrofit Interior (RI) | Existing enclosure reuse, failing relays | Same control capabilities as CP. Reuses existing enclosure and field wiring. New electronics and relays. Minimizes downtime in occupied buildings. |
| Retrofit Kit (RK) | Existing relays functional, controls failing | Replaces only control electronics. Existing relays, enclosures, and field wiring remain. Lowest cost upgrade path. BABA applies to new control electronics. |
| RE04 / RE224 Module | Projects with emergency lighting requirements | UL924-rated emergency relay modules. Required for egress and emergency lighting circuits. Compatible with all panel types. |
| BACnet MS/TP or IP CM | BAS integration — any platform | CM communicates natively on BACnet MS/TP or BACnet/IP. No gateways. No middleware. Compatible with Johnson Controls, Siemens, Honeywell, Tridium, Schneider, and others. |
Supporting Data — Energy Savings for Project Justification
For MEP engineers preparing energy models, life cycle cost analyses, or project justifications, the following data from independent research provides defensible baseline figures:
|
24–38%
Lighting energy reduction from controls, depending on strategy (occupancy, daylighting, scheduling, or combined) LBNL Meta-Analysis — DOE-Commissioned, 88 Studies |
47%
Average measured energy savings across 114 buildings with networked lighting controls DesignLights Consortium / NEEA, 2020 |
+30%
Additional HVAC load savings when lighting occupancy data is shared with the BAS — enabled by BACnet-native integration DesignLights Consortium, NLC Resources |
Contact Blue Ridge Technologies
For specification support, BABA compliance documentation, submittals, energy modeling data, or project-specific questions, contact:
Ready to discuss your project?
Andrew Dunkleberger
Director of Business Development
Blue Ridge Technologies | Marietta, Georgia
adunkleberger@brtint.com
(678) 223-1173
www.brtint.com
We can provide:
- BABA compliance certification letters
- Domestic manufacturing documentation
- Division 26 specification language
- Energy model support data (DOE/DLC sourced)
- Title 24 compliance confirmation
- Submittal packages and product datasheets
BABA data sources: U.S. DOE Build America Buy America; OMB M-22-11; 2 CFR Part 184; IIJA Pub. L. No. 117-58; US Made Supply BABA Guide. Title 24 sources: California Energy Commission 2022 Building Energy Efficiency Standards; Electrical Contractor Magazine (2023); Lighting Controls Academy (2022); California Title 24 Now. Energy savings: LBNL Meta-Analysis (DOE); DesignLights Consortium / NEEA (2020, 2023). BRT company information: brtint.com/about-us.
Can This System Be Retrofitted?
Not every lighting control system needs to be replaced.
Many legacy systems can be modernized while reusing existing panels, wiring, or relays.
Use our Lighting Control Retrofit Assessment to determine whether this system is best suited for:
- A retrofit kit
- A retrofit interior
- Or a full system replacement
This quick assessment provides a clear, high-level recommendation before pricing or design begins.
Call to action:
Start the Retrofit Assessment
If you have questions or prefer to speak with someone directly, contact sales@brtint.com.