California missteps with Title 20 LED lamp regulations (MAGAZINE)

In January, the California Energy Commission (CEC) finalized new regulations that will impact LED-based general-service lamps including the ubiquitous A-lamps and small-diameter directional lamps.

California missteps with Title 20 LED lamp regulations
California missteps with Title 20 LED lamp regulations

In January, the California Energy Commission (CEC) finalized new regulations that will impact LED-based general-service lamps including the ubiquitous A-lamps and small-diameter directional lamps. After publishing voluntary guidance encouraging the move to higher-CRI products back in 2013, the agency will now mandate such products with the policy becoming active in January 2018. It seems, however, that the CEC has delivered new rules that don't make practical sense and could result in more energy being consumed while costing California residents more in lamps and energy to light their homes.

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Now the Title 20 Appliance Efficiency Regulations are hugely complex, and address far more than solid-state lighting. And even the regulations on lighting are overly complex and hard to digest. But the most controversial element of the policy is quite simple. The agency is requiring 90-CRI lamps. The document actually specifies a minimum of 82 CRI. But it also requires a minimum of 72 CRI for each of the eight pastel color samples that are averaged to determine the aggregate CRI that is sometimes referred to as Ra. The National Electrical Manufacturers Association (NEMA) said there are no 82-CRI lamps on the market that score 72 or better for the light-red-purple R8 color sample. Effectively, the regulation requires 90 CRI.

The CEC has said 90-CRI lamps provide a better user experience and are needed to ensure that residential customers don't reject LED technology the way compact fluorescent lamps (CFLs) were rejected for poor performance. But that argument doesn't really hold up to close scrutiny. Residential customers across the US are buying 80-CRI lamps in volume. NEMA has pointed out in its lobbying that any danger of LED lamps suffering a CFL-type fate has been skirted.

NEMA actively fought the CRI requirements based on its belief that consumers would end up buying more-expensive, less-efficient products. Moreover, NEMA has noted that price has been the biggest obstacle to broad adoption of LED lamps, and the recent rulemaking will simply keep prices higher than necessary.

My question for the CEC is why not let the customer decide when it comes to an issue such as color rendering? I want the freedom to buy a very-high-CRI lamp perhaps to accent a painting or photograph. But I'd want the option of buying the most efficient light possible for ambient lighting in a hallway, staircase, or garage. Even 80 CRI might be overkill in some cases.

Of course, we are talking about a forward-looking policy. The new rules won't take effect for almost two years. LED technology is quickly evolving. And the efficacy penalty associated with warm CCTs and good color rendering has been on a constant decline. Maybe 90-CRI lamps would be the standard offering by the beginning of 2018 regardless of government policy.

Still, the CEC's move to regulate CRI has been simply misguided. If technology maturity and economies of scale mean that 90 CRI is the standard product offering in 2018, then the CRI element of the rulemaking was not required. If the higher-CRI products remain more costly and less efficient, then NEMA is right and the citizens lose. The CEC has stepped into a situation that should be governed by the free market rather than government policy.

Maury Wright, Editor

mauryw@pennwell.com

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