COMMENTARY: New regulatory changes may impact LED lamps and luminaires (MAGAZINE)

April 10, 2013
The ups and downs of regulatory changes for solid-state lighting.
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This article was published in the Winter 2013 issue of IIF Magazine.

View the Table of Contents and download the PDF file of the complete Winter 2013 issue, or view the E-zine version in your browser.

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There are changes coming to the US Department of Energy (DOE) Lighting Facts program that could lower the cost of LED-based lighting products, while California plans to heighten performance requirements on LED-based retrofit lamps. Whether you are a lighting designer/ specifier or work for a lighting company, both solid-state lighting (SSL)-centric regulatory changes may impact you, although in the case of the California action not necessarily in a positive manner.

At the Strategies in Light (SIL) conference, the DOE revealed that it will lessen the burden on lighting manufacturers seeking to have multiple related luminaires in a product family listed in the program. To date, manufacturers have had to test every product to the LM-79 standard to have the product listed — even when a series of products have relatively minor differences such as a range of lumen output options.

Beginning in April, manufacturers will be able to test one product in a related group of products, and calculate or extrapolate the performance specifications for the others. The change will greatly lessen the testing costs that lighting manufacturers now face, and should pave the way for lower-cost products.

I find it hard to find fault with the plan. The DOE will randomly perform a verification test on products bought on the commercial market. Manufacturers selected for a random test will have to pay for that test, but overall the manufacturers will spend far less money on testing. Only lighting companies with a clean Lighting Facts track record can participate. So I expect that the benefits of Lighting Facts — reliable data on the capabilities of a product — will be preserved.

I don’t know that I feel so good about the actions of the California Energy Commission (CEC). The agency has quietly launched a voluntary plan that establishes a more strict set of performance requirements for LED-based bulbs. “Voluntary” is in the title and is technically accurate although maybe not practically so. The CEC will ensure that major California utilities only provide rebates that comply with the new standards — that exceed Energy Star requirements in some areas.

For example, the specification requires a CCT of 2700K or 3000K for LED lamps. But there is solid science that documents applications where a cooler CCT might enhance productivity or wellbeing.

The new specification will also require a CRI of 90. There are many applications that need such high CRI, but many that don’t as well. Moreover higher CRI universally means less-efficient lighting — going from a CRI of 80 to a CRI of 90 results in a 20% reduction in lumens per watt.

I’m worried that the CEC action might ultimately slow the adoption of energy-efficient SSL products, or at least lessen the positive impact that the ongoing transition to the technology is having on energy usage. And the impact can go beyond California as the state’s actions have in the past led to broader regulatory changes in the US and as lighting manufacturers seek to develop a single product for sale across the country.