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Here is some information we have found on Title 24 requirements for refrigeration lighting.  After review of the standard and discussion with the California Energy Commission for confirmation, dimming is not required for our walk-in applications. Freezers are specifically excluded from the dimming requirement. Coolers require at least 50% dimming and with our motion sensor, we provide 100% dimming. That is acceptable per the California Energy Commission.

For your reference, below are links to the actual code:  

1. Coolers - The requirement of Section 130.1(c)6A of the 2013 Building Energy Efficiency Standards is applicable to lighting in aisle ways and open area in warehouse and must be equipped with occupant sensing controls that automatically reduce the lighting power by at least 50%. If the control shuts them off entirely meaning it reduces the lighting power by 100% that would be compliant with the standards
2. Freezers – The provision in Section 140.6(a)3E of the above document states that walk-in freezers are exempt from the lighting wattage calculations – where freezer is defined as a space designed to operate at less than 28°F.  Meaning that the walk-in freezer refrigeration system is the only energy use used for calculations for acceptance to the standards requirements.