Can Water Hyacinth Navigate? Should We Copy It?

The Weed from Hell. Can it Navigate?

I spend a lot of time in the California Delta, near the convergence of the Sacramento and San Joaquin rivers that drain the Central Valley. The Delta is, to me at least, an almost overwhelmingly complex ecosystem, chopped and sliced by the Army Corps of Engineers' extensive and aging levee system. Over the last 15 or so years, I've fished and hunted there and have seen many large scale environmental changes and fluctuations- mostly degradation- and it remains a source of fascination and ultimately concern, as we keep tinkering with the balance between uses and nature, all exacerbated by the increasing urgency of California's water situation, to potentially catastrophic ends.

The Delta I know best, the area around Frank's Tract, Big Break, and Sherman Island, is characterized by a very complex system of currents and tides. Tides can approach 4 feet at times, and they impact the direction of currents in the many main channels and back channels in a way that takes several decades to learn fully. After all my time out there, I'm only just beginning to develop a rudimentary sense of optimal tide and current conditions for fishing.

In summer months, water temperatures get well above 70 F, ideal conditions for invasive species like the water hyacinth (Eichhornia crassipes). I'm not sure of this, but one of the changes I think I've seen lately is a big increase in the amount of hyacinth. This could be linked to increased nitrate levels in water, perhaps exacerbated by the drought. At this time of year, water temperatures begin slowly dropping - this leads to a massive mobilization of hyacinth. Massive rafts of it can be seen wandering around on the water, seeking better growing conditions. Some of these clumps take on the size of small islands, and in low light conditions may easily be mistaken for them. On a boat you have to weave in and out of them frequently to avoid fouling your prop or worse. 

On a recent perfect Delta autumn day I was wandering around on the water myself, in my boat, looking for concentrations of striped bass (another famous non-native species common in the Delta) to tempt with a fly rod. I was parked at the corner of Potato Slough, on the main channel of the San Joaquin. While mechanically casting out and stripping in my line, I had occasion to contemplate the ubiquitous and vigorous hyacinth, which seems to be on a perpetual campaign to take over the known universe, evidencing very much the kind of will to survive at all costs that Charles Darwin apprehended so well. Having just read his On the Origin of Species, narrated by Richard Dawkins (highly recommend!), my mind was on this topic. The hyacinths seemed to be exhibiting an uncanny ability to move deliberately, something that few plants can do. They appeared to almost be "intelligent" about it, optimally using winds and current to end up, for a minute or a day or a month, in better growing conditions. 

Remembering a recent article about plant neurobiology by Michael Pollan, I suddenly thought "what if they're actually navigating? Or even communicating with each other while they're doing it?" If plants evidence neurobiological structures, as they appear to, then wouldn't a species like hyacinth (which seems to be like aspens, less a collection of individual plants than a single pulsating, maddeningly recombining organism) be able to move their roots and leaves slightly in order to harness wind and currents to drive them to water and conditions most suitable to growth? And thinking of Darwin, most certainly this adaptive behavior would have genetic roots. What if we were able to tease these genes out and use them for something else? Or if we were applying biomimetic design to something, say mechanisms for water treatment plants, how would we use this inspiration from nature? 

Or should we? Biomimicry likes to find examples from local environments as inspirations for design strategies. A good example is the design for the renovation of the San Francisco Mint, an elegant and beautiful project by the architecture firm HOK. I saw a recent presentation by HOK's Director of Design, Paul Woolford, who managed the project. Local species that inspired ideas for building systems- lighting, ventilation, thermal performance, and balance- included the California Brown Pelican, the spookfish (a new one for me), the Picasso Sponge, and the native California Salmon (I'm definitely familiar with that one!).

So here's a strange question- should we use biomimetic strategies from invasive species, like the hyacinth? Are there ethical or design issues here? According to the National Ocean Service an invasive species is "...an organism that causes ecological or economic harm in a new environment where it is not native." The key concepts here are "harm" and "native." Given the context, there may be a crucial difference between perceived economic harm and environmental harm. And the paradigm of perfection for species is whether they are "native" or not- we think of the salmon as more noble than the striped bass because it's more native. This kind of emotional mindset drives a lot of environmental policy. Ideally, things that are good for the environment should be good for the economy of humans too- as Janine Benyus is fond of saying "We are nature too." 

We're also the ultimate invasive species, so why don't we admire the scrappy and voracious water hyacinth and striped bass? Darwin had a lot to say about what was not then termed "invasive" species, there's a nice breakdown on that here. My sense is that he would be appropriately dispassionate about this, although in his time the massive invasions had not yet occurred on the scale we're seeing today, with the extensive systems of conveyance (global trade with ships and airplanes) we've given invasive species. 

Biomimicry is a powerful design tool that is a rich source of ideas from evolution. It didn't occur to me to bring ethical considerations into its use until I contemplated the irritating and rather terrifying water hyacinth, which, like kudzu and others like it, seems unstoppable. How might we go about learning from even plants and other creatures that are repellent to us? I'd love to hear from the Biomimicry folks on this.

NYT Op Ed Can't Ding Efficiency and Nakamura Nobel - Because It's Groundless

Shuji Nakamura in San Francisco in early 2012, shortly before
the launch of Soraa. Photo by Russell Abraham.

The impact of the well deserved award of the Nobel prize in physics to physicists Isamu Akasaki, Hiroshi Amano, and Shuji Nakamura for the invention of the blue LED was recently diminished by an Oct. 8 New York Times op ed by Michael Shellenberger & Ted Nordhaus, of the Breakthrough Institute. Shellenberger & Nordhaus, well known for advocating for nuclear energy and expanding natural gas production, seem to have a fundamental lack of understanding of the basic idea of energy efficiency and its role in economic development and policy. And they have a history of climate change denial and even attacking Rachel Carson. In their op ed, as they have done many times before, they beat the drum for the "rebound effect," claiming that LEDs, arguably the most important green technology to be developed in some time, will not reduce energy use. This is an unconscionable use of media attention to what should be seen as a milestone for energy efficiency- promoting an energy agenda that seems to me to be suspect and decidedly anti-environmental.

The Jevons Paradox or rebound effect is beginning to look like the Nosferatu of pop theories on energy and sustainability. No matter how many times a stake is hammered through its heart it just keeps popping up periodically out of the grave. For those of you who are not familiar with it, it goes like this, more or less: energy efficiency measures and technologies actually end up causing more energy use because they make energy cheaper. So basically, energy efficiency causes the opposite of its intended goal. How's that again? This is one of those ideas that may appear so appealing because it's supposedly "counterintuitive" - well intentioned but misguided efforts to do environmental good or right environmental wrongs can certainly go horribly wrong when they're not well thought out. (Things like introducing invasive cane toads to Australia to control invasive cane beetles come to mind right away). And of course upon apprehending this counterintuitive idea we can feel swell by congratulateing ourselves on knowing the real story and pass it on- it's a poisonous meme. Jevons is consistent with "neo-classical economics" and ideas like "free markets" and "trickle down theory" that have repeatedly been shown to be pretty much worthless but persist because they provide simplistic explanations and justifications for the undue concentration of wealth.

The person doing the most stake hammering is David Goldstein of NRDC, who over the years has done an admirable job of debunking rebound effect. His excellent and timely rebuttal to the Shellenberger and Nordhous piece, as well as several earlier pieces, spell it out clearly: rebound effects have not been demonstrated to be significant, if they exist at all. I will add to this clearly reasoned argument just a few items from my own unique perspective.

The first problem with this particular op ed at this particular time is that even though its claims are baseless it may have a deleterious effect on energy efficiency measures because of how the argument is constructed. Although the authors are careful to praise the Nobel prize winners, the effect of their argument is to imply that energy efficiency actually causes increased energy use, therefore people can't help concluding that all energy efficiency efforts are basically useless. Whether it's intentional or not (you decide after perusing the Breakthrough website), this conclusion plays quite well to oil, gas, and nuclear lobbies who would prefer to distract us from efficiency and get back to the business of burning fossil fuels and building unfeasible nuclear plants. The logical problem with the argument (one of the most common problems with data reported by media, and even with much science) is that it confuses causation with correlation.

According to Daniel Kahneman (2002 Nobel prize winner for economic sciences) in his book Thinking, Fast and Slow, the reason this problem exists is that the human mind, in its fast thinking, emotional mode, constantly seeks causes and explanations for things that may show correlation but in reality are not causally related. Making decisions with this faulty logic may result in grave errors of judgement, a typical failing of humans both individually and in groups. So the fact that energy use is perceived to be growing in some areas may reflect the fact that populations with access to cheaper energy are themselves growing- it doesn't mean that cheap energy causes more overall energy use. A plausible outcome is that in addition to widely adopting LEDs, we will decide we have enough light and not increase our use of it- there are real limits to how much we really need after all. As Goldstein alludes to in his article, one very important consequence of efficiency measures and technologies is that when successful, as they have been in many global economies, they often serve to focus more attention on energy use in general and lead to further efficiency measures, the net effect of which is a reduction in energy use, the original point. So energy efficiency actually results in...saving energy. Whoa dude!

Shellenberger & Nordhaus' sloppy reasoning includes statements such as "The I.E.A. and I.P.C.C. estimate that the rebound could be over 50 percent globally" without providing any solid evidence of such. Statements like this certainly risk being misinterpreted by our "fast thinking" brains and lead to incorrect judgements about energy efficiency policy and technology.

There is one area of lighting in which new LED technology has resulted in overlighting with poor quality light, and that is street lighting, a serious environmental problem at the moment. From what I can gather about the causes for this, many municipalities in the US and Europe moved too quickly into adopting LED streetlight systems, in the interest of saving energy, before adequately understanding how to transition from the old technology to LEDs. This resulted in much light encroachment and light pollution with overly blue light, which is hated by many residents and may harm plants and other critters. But this was not caused by energy efficiency, it was caused by a lack of appropriate application of technology and poor planning.

Energy efficiency in many economic regions, including California, is in fact now the largest source of energy. New technologies that make significant efficiency possible on a large scale are rare- LEDs are the first new lighting technology of consequence to come along in a long time. Many of the "clean energy" sources that Shellenberger & Nordhaus claim are more important to invest in will take decades to scale, although prospects are good for solar and many renewables. And efficiency and clean energy are not opposing, either/or propositions - we need as much of both as we can get, as fast as we can get it. For the time being, we will be relying on fossil fuels for a very large share of our energy, and almost all efficiency efforts are worth considering and investing in, for many reasons. Slamming energy efficiency, especially now, when we have reached what can be perceived as a milestone in validating LEDs, is not doing any good for us or the planet.

Seeing the City for the Trees

Janine Benyus at the 2014 Geodesign Conference

I always saw myself as a "big picture" person. But like in Wayne's World, I am not even close to worthy compared to Janine Benyus, founder of the Biomomicry Institute, especially so after watching her keynote at the Geodesign conference put on by ESRI, the global GIS (geographic information systems) leader, in January of 2014. Basically it's about applying biomimetic design principals at the scale of cities, not just Nike shoes, teapots, or garden hoses (not that doing so isn't also wonderful- it is). And combined with the data processing and visualizing power of GIS, biomimicry presents a blindingly complex yet thoroughly inspiring future of possibilities. Developing metrics, gathering data, choosing locations, crunching the data, analyzing interrelationships, integrating this into design tools that can be open source and enable shared visualization of urban design at large scales- that's about as big picture as anything we humans do.

Yet this is what Ms. Benyus is talking about here, and it's exciting and fascinating to see how biomimicry can apply to urban design, a field that is nothing if not big picture, dauntingly so because of the sheer scale and timelines of the projects. I recall a conversation I had several years ago with one of the founding fathers of New Urbanism, Stefanos Polyzoides of the urban planning and architecture firm Moule & Polyzoides, where he expressed some dismay at the results of his work on the strategic plan for downtown Los Angeles. To him at the time, as I recall, the effort was just too big and chaotic to see clear and positive results. But it's now a 30 year project, and I would expect that with the recent advent of cheap and powerful GIS tools, is beginning to show success.  

Before I read Ms. Benyus' groundbreaking work, Biomimicry, Innovation Inspired by Nature, I expected something rather metaphorical and tree huggerish. But I quickly apprehended the extent of her training and knowledge as a scientist, not just as a designer, and as a designer I was sold and immediately wanted to put biomimicry to use. The most surprising thing for me about the book was the utter breadth of the scope of the whole idea of learning from nature, and even more surprising was the idea of learning from other animals' social structures. The mindset I got from Biomimicry is invaluable, and helped me in my reading of things like E.O. Wilson's Social Conquest of Earth, which points out that we are one of only about 30 eusocial species on earth. I'm now looking at how other species make "architecture" in my ongoing exploration of the human built environment.

For most of us, it's relatively easy to understand biomimetic design concepts applied to things we can hold and touch- consumer products and artifacts like telephones or engine parts: I'm thinking of the lattice structures applied to bicycle frameworks, as demonstrated by Autodesk's Carl Bass in this cool talk. But few people on the planet have the vision that Janine Benyus does in applying these concepts to things as large as cities, which are both collections of artifacts (buildings and equipment and such) as well as ecosystems themselves. 

What's crucial to biomimicry is a concept of man as a part of nature, not separate or opposed to it. This conceptual leap is persistently quite difficult for most of us in Western culture, especially in the U.S., where "nature" had to take on adversarial status so we could "conquer" it in the process of building an imperial empire. It goes deeper than that and farther back to our Judeo-Christian roots, where the dominant narrative has Adam and Eve thrown out Eden (Nature) and hence eternally separate from it. We seem to have only two cognitive categories for spaces: Nature and Built Environment, and never the twain shall meet. This dualistic narrative is becoming irrelevant, and Ms. Benyus shows us the obvious with great eloquence, humility, and poetry. 

Urban design today is in an unprecedented state- not only are planners and designers dealing with ongoing redevelopment of established cities and towns, in places like Asia, whole cities are springing up fully formed-built rapidly all at once, without evolving over centuries or millenia. Will they suffer the fate of planned cities like Brasilia, or will we learn from our mistakes? With such rapid deployment there's little room for error, and many localities are sure to make grievous errors in copying architecture suited for one location but not for theirs. And GlassBoxitis, the relentless and ruinous trend in global architecture continues to exact its toll on the environment, with no signs yet of slowing down.

In thinking about the design of cities Ms Benyus proposes asking questions like "how can a city function like a forest?"; and "what is the genius of the place?" Rather than seeing the city as encroaching on "nature," she sees the very real possibility that cities can indeed provide environmental "services" as described by Amory Lovins, Hunter Lovins, and Paul Hawkin in their landmark work Natural Capitalism. Human "infrastructure" and "ecostructure" can work together to be mutually beneficial.

Without a culture that instinctively values what we call the "services" performed by the environment, we capitalists must resort to the narrative device of monetizing resources and services, so that environmental assets and losses can be characterized in a way similar to financial assets and losses. This requires devising and implementing a system of metrics she calls Environmental Performance Standards: things like tons of carbon sequestered per building; gallons of water desalinated per square unit of wetlands; energy generated per square block. In the past, meeting the sheer computational load of gathering and managing all this data would have been unthinkable, but today we're awash in data and cheap computing, so we can do it. The new data-based design tools that are available are amazing. And so is cheap, widely available map-based data visualization. 

Her post keynote conversation with ESRI CEO Jack Dangermond explores the vision of merging what she calls BIS (biological information systems, which don't quite exist yet, although the Biomimicry Institute is working on it) with GIS. This would give designers tools that would allow them, on a software level, to draw upon the design strategies of local organisms for things like providing shelter, water conservation and purification, resilience to weather events, and replenishing nutrients into the soil, and to incorporate these into designs, prototypes, and models. And right onstage she makes a deal to collaborate with ESRI on Singapore's emerging smart building network to incorporate biomimetic design and data gathering. 

Nobody today is really asking the kinds of bold questions that Ms. Benyus does: "How do we become native to our places?" ""How would nature solve this?" "Can the city be generous?" These are, in a way, poetic questions, and I'm reminded of the use of poetry in describing quantum physics. You can arrive at descriptions of very complex phenomena or conclusions to deep questions by analytical, rational, and mathematical means, but there comes a point in which only poetry will do to elegantly contain the human reality and experience. If she stays the course, which by all indications she will indeed, Janine Benyous will help to make not only cities generous, but perhaps, someday, our culture.

More Thoughts on T24 for Lighting

My latest overly lengthy post on California's Title 24 changes received some comments from my excellent colleague Jay Shuler, CEO of Cool Lumens, a Santa Cruz LED startup. His comments are in blue, and my responses below.

1. Dictate results, not technologies or technological implementation. This is the Prime Directive of standards. Do not squelch innovation by limiting how people achieve your goals. 

I agree totally on technology neutrality. In my mind there are some problems with the current proposals in this regard. Tech neutrality should also be seen in the context of what's between the lines. It's always the stated intent in regulation, but very often things are wired so that only one technology can fit the regulatory goal. In the case of LEDs, this is true to some extent. But there is no real viable replacement on the horizon, and LED as a general class of technology is incredibly broad and has much potential. Where I see issues are in provisions that require integrated fixtures vs simple lamp retrofits. As I explained in my last blog, some of these issues speak to the tradeoffs necessary in achieving a balance between private profit and public good. 

I'm not worried about squelching innovation as a bad thing- I think we should squelch it and slow it down so that we can understand what we're doing better before find ourselves in RobotLand and the IOT is the oppressive global government, like in Brave New World.

2. Dictate results that matter, and be application aware. For example, color quality is important to a much different degree in different applications. Where visibility is the primary concern, CRI matters only to provide color contrast in addition to luminance contrast. It is obviously much more important in retail and hospitality, including home. A reasonable metric would provide minimum CRI standards for different applications. But don't get too strict... CRI is a matter of opinion, not science.

"Results that matter" should always be the goal of regulation and standards, it's just that we don't really have agreement on how CRI matters. There's a lot of science behind it, and once again, we don't have agreement on how the science matters. The relevance of color varies greatly in different applications, this is true. Most of the proposed T24 changes seem to recognize this and have been carefully considered according to different applications. The reasonable metric with minimum CRI is pretty much exactly what needs to be worked out, it's complicated.

3. Efficiency is incredibly important to global warming and other things that one could easily argue are more important than being able to see red a little better. However, given the need for color in many apps, a sliding metric that computes efficacy and CRi together might make sense... something like setting a minimum value for LPW x CRI. (low LPW x high CRI = high LPW x low CRI). 

Yes, efficiency is crucial and often overlooked and taken for granted in lighting today. The connection between quality and adoption however remains very clear to me, but unfortunately not to everyone. I appreciate Jay's being willing to take a look at different metrics or combinations of metrics. LPW and CRI are of course both important. I'm not sure if multiplying them will give the result, and there is a danger in using a single metric for everything, it simply can't tell the whole story no matter how accurate it is, especially with CRI. I like the idea of a "sliding" metric- more like a scale. I hope the CEC sees enough creative thinking here to develop a good approach- it's not obvious now what that might be, but that shouldn't keep us from trying.

4. Watch out for efforts to save the industry from itself... trust the market to some extent. In other words, crappy products will fail in the market; you don't have to disallow them. This has been the mission of the DOE for a long time, and it is laudable to establish voluntary standards of quality... a Good Housekeeping stamp of approval, if you will... but hesitate to be heavy handed. EnergyStar and DLC are great and laudable efforts, and good enough.

I really don't always trust the market alone. For one thing, it's moving too fast now for regulation to keep up. And this rapid movement results in dramatically increased inequalities- everyone's aware of these issues. The key thing is a healthy stable balance between markets and government- this kind of thing is simply too difficult for most Americans to envision. I'm workin' on that.

I would beg to differ about Energy Star and would argue that their efforts have come across as somewhat heavy handed. Heavy handedness is very much to be avoided, as it carries a serious risk of backlash. When overly zealous energy regulations are put in place at the expense of quality and other practical considerations, people start to hate the entire idea of regulation at all and the whole house of cards starts to fall. This is happening in Europe and all over the globe, I'm disturbed by it. As I see it, the biggest problem is the lack of coordination between industry, consumers, and government. Our interests can all align, it just takes more work, and in a society that often seems to be rapidly disintegrating and losing social cohesiveness, it's a lot more work.

5. Under "It's About R9" I have a few additional comments. The blue pump is usually but not always 450-460nm. The traditional LED phosphor is yellow, not green or red, although different formulations are emerging. Blue+Yellow = White (perceived). Blue + Green + Red = white (perceived) but with a better chance at high CRI and efficacy together. Blue leaks through not by accident but on purpose, to balance the Yellow (or Red + Green) to make the perception of white. LED spectrum is actually pretty smooth compared to other phosphor-converted sources, only lacking (or more accurately, weak in) Cyan and Red in traditional YAG phosphor products, and presumably smaller slices in RGB formulas.

Good comments. It is important to realize that most (certainly not all) LED spectra are smoother- this is good in general, although the spike that occurs in most is at the 450nm range in general, the wavelength to which circadian processes are most sensitive, quite an unfortunate accident. Personally I feel that LEDs have and will continue to advance rapidly enough that we can have basically any spectrum we want, from low candelight to noonday summer sun in Marrakech and anything in between. Cyan gaps have closed and R9 is up on many "blue pump" sources these days. Phosphor engineering is a fascinating field these days- I'm always impressed by what Intematix is up to, for instance. 

California's T24 - Weigh In on Residential Quality of Light

Revisions to California’s Title 24 2016 code now being considered. I know- you’d probably rather have a root canal than think about regulatory issues. And even if you are engaged in them, it’s basically impossible to learn everything you need to know in the time you have available. But…you do have an impact on this process, and it’s important that you know how to exercise this right.

I’ve appointed myself an independent advisor to any and all who will listen, well…read that is, to present my summary analysis of the main points of this pending legislation that will affect your professional and personal lives, and to give you guidelines on how to comment effectively. Disclaimer: although I am active in the Illuminating Engineering Society (IES), and the International Association of Lighting Designers (IALD), my opinions and recommendations are presented completely independently of these groups. I am also greatly indebted to Jim Benya for his excellent comments and help. He's very actively involved in this effort, probably knows more about it than anyone on the planet, and has been at it for far longer than most of us, especially me. I’ve drawn heavily on his recommendations in making my own. I apologize for the length of this, but there's a lot to consider without serious oversimplification.

Regulation, Why Bother?
There’s much debate about the role of regulatory actions in the market- should they drive technology or follow it? This is a particularly pertinent question today with lighting, as technology is advancing so quickly that it’s impossible for regulations to keep pace. Maybe for now, regulations are following technology. Either way, regulations must allow for healthy innovation, energy efficiency, market development, health and wellness, and environmental justice without destroying the balance between private profit and public good. “Disruption” may be good for innovation (or not, that’s now quite debatable) but it’s not conducive to stable, participatory government. Poorly crafted regulation, despite the best of intentions, can do more harm than good.

I’ve limited myself to commenting only on parts of the Residential Lighting part of the code that I know enough about to form an opinion. As part of my effort here I attended the June 24 hearing at the California Energy Commission (CEC) in Sacramento.

But if you’re so inclined, I encourage you to comment on any part of the proposed changes to the code. Anyone from anywhere can comment, even people from other states or countries. Since California has traditionally been a leader in energy efficiency regulation, I think that looking towards how other regions and countries can apply our successes is important. By the same token, we in California don’t come up with all the great ideas and legislative practices - incorporating comments from outside our regional framework is healthy.

Public Comments Close July 23
The process of developing and revising codes, including Title 24, takes a long time and there are many stages during which different levels of comments, revisions, and review are incorporated. The comment period in question is for proposed changes to the 2016 code, and for now, the most important date is July 23, which is the deadline to send public comments to the CEC. After that, there will be more workshops and increasingly tight code language to review by the CEC, who will ultimately adopt it into the 2016 code.

Quality, Adoption, and Complexity
One of the many complex dimensions of T24 is that its primary purpose is to legislate energy efficiency, not “quality” per se- quality of life, indoor quality, or quality of light specifically. But the reason to include “quality” based measures, such as CRI, into the standard is that they dramatically impact the broad adoption of energy efficiency measures, especially in lighting. Efforts to improve CFL adoption, especially in residential application, failed- not because of poor regulation specifically, but because of poor product quality (actual and perceived). CRI is a key metric used to judge light quality, and it’s not necessarily a perfect metric, but in lighting we have few of those anyway, and legislation is not about perfection, it’s about results. I’ll talk more about CRI below.

A consistent refrain from those within my network who are inside the regulatory process is that there is not enough industry and user feedback. In regulatory affairs today, legislation is usually dominated by the few key players who choose to (or more importantly, in the case of well funded entrenched interests, can afford to) show up and mouth off. Participation in this process, as complicated and inconvenient as it may be for Ma and Pa Public and small businesses, is a “use it or lose it” right.

In any proposed legislation, especially that which deals with energy efficiency or environmental issues, the incumbent players’ first reaction is typically to proclaim in stentorian tones that tightening standards will be economically ruinous, imperil jobs, and hasten the demise of Western Civilization. And very often, well crafted legislation that is done with appropriate support and input from all stakeholders, including end users, overcomes these initial objections and achieves its purpose. In the current proposed changes, there is much that still needs to be worked out, and entrenched industry interests have some legitimate concerns, as do homeowners, manufacturers, industry groups, and practitioners.

Why Color Quality is Important
Residential lighting regulations are so important because in our homes, color quality in lighting is generally perceived to be more important than in public spaces. So even though residential lighting does not represent the largest percentage of overall energy use, it has a large influence on how the public perceives and supports LED technology in non-residential uses. The last breakthrough lighting technology (CFLs) failed in residential applications because quality was not a priority for manufacturers, and because incandescent light sources were not being banned. Now incandescents are being banned, and CFLs, while improved in quality, are no longer viable. LED is widely understood to be the technology of the future- fortunately it’s incredibly flexible scalable, and efficient. We will eventually enjoy much better quality of light at much higher energy efficiency.

It’s About R9
Not to be overly reductionist, but the biggest quality issue with LEDs so far has been color performance- both in temperature (CCT) and rendering (CRI). People perceive that LEDs are too blue. This is largely because most LEDs are made with a blue “fundamental emitter” or "pump"- the LED die itself emits blue light at approximately 450-460 nm, which excites the red and green (or yellow) phosphors in the LED package to create white light. Because the blue fundamental emission is used in combination with red and green to create white, a blue phosphor isn’t required – this makes the LED cheaper to produce. First generation LEDs settled for “broken” spectra, that don’t include all colors in light in balanced proportions, so the blue leaks through and shows up disproportionately (many newer LEDs, including Soraa’s especially, have improved spectral design and color rendering). This is similar to the color problem in fluorescent lamps, which also work by exciting phosphors. Because of their large surface area, a lot of phosphors are required, and manufacturers realized they could produce light cheaply by taking spectral “shortcuts”- leaving out large bands of the spectrum of white light. Both fluorescents and first generation LEDs suffer from low R9 values- the deep red part of the spectrum. This plus the high blue component of their spectra makes them look greenish or blue.

Most of the problems with LED color performance center on poorly balanced spectra and low R9- not enough red or deep red- not necessarily low CRI per se. It’s possible to achieve a high CRI value and still have low R9, as CRI is an average of all the R values. In order to look right to most people, electric light, including LEDs, especially in lower color temperatures (below 3500K), needs a full balanced spectrum and high R9 value. Even in higher color temperatures (above 3500K), full spectrum light is better, although we’re not used to it and don’t expect it because we don’t see it very often- few manufacturers make sources like this anymore.

CRI may not be the ideal metric for color, but it’s adequate for our purposes now, where it matters most, in lower color temperature residential lighting. It also has the advantage of being widely accepted and understood, at least by lighting professionals. It’s a standard that can appear on lighting product packaging- even though most of the public doesn’t understand it now, they will eventually.

Flicker, the Persistent Irritant
Manufacturers hate the flicker problem because it’s evidently so difficult to deal with. People hate flicker in LEDs because it looks unnatural, and there are health concerns. In my opinion we don’t know enough about how harmful flicker may be to have health concerns drive regulation, I’m sure many will disagree with me here. But like light quality, it’s something that will slow adoption, so must be dealt with in T24 for that reason.

Compatibility, Another Persistent Irritant
Compatibility issues with LEDs represent a widespread case of unexpected consequences –no one foresaw or wanted these problems. The entire electrical infrastructure of the US and most industrialized countries was built primarily for incandescent light sources first, in fact lighting was the primary driver for electrification in the US. And since LEDs are a technology fundamentally different from incandescent or fluorescent, they deal with power very differently and are much more sensitive to the inevitable variations in power that occur in any system like the electrical grid- it’s even more complicated than that, I’m only scratching the surface here.

In many cases, LEDs can be simply plug-and-play, changed out in existing sockets with no performance problems. In other cases, they won’t dim, they flicker, or worse, they just won’t work. Being fundamentally unidirectional, LED lamps are also necessarily configured differently than omni-directional ones- this contributes greatly to both their lamp and fixture efficiency. Unfortunately they often won’t fit in fixtures designed for incandescent or fluorescent sources. And dimmers, drivers, and other components designed for incandescent and fluorescent sources don’t always work with LEDs. This has slowed adoption, as people are used to simply switching out lamps, as was the case with CFLs, instead of having to retrofit the entire electrical system for a building just to get the benefits of LEDs.

The wide extent of compatibility problems is greatly exacerbated by the need to simultaneously embark on a replacement strategy, where many lamps are switched out for high efficiency sources, and to develop completely new components, controls, and infrastructure that are compatible with LEDs. To make things even harder to deal with, the pace of technology change means that something that works now will probably be completely outmoded in 2-3 years, when the building project you specify LEDs for today will be completed. In my opinion, the only way we can deal with these issues is to incentivize manufacturers to plan for flexibility, maintenance, and eventual obsolescence of any lighting components or system, a very difficult thing to envision, let alone execute. Still, compatibility problems will eventually be ironed out. Now the goal is to craft regulations that encourage both rapid, balanced replacement as well as innovation at the system level.

My Recommendations:

1. Revisit California Quality Lighting Initiative (CQLI)
Many of the proposed changes to T24 are the result of the CQLI, most of which I like. I recommend we take another look at the 90 CRI requirement, perhaps considering lowering it very slightly to 87, even 85, if this also includes the R9>50 (or greater) requirement. However, this may not be necessary. The EPA last year failed to include a >80 CRI requirement in the Energy star standard, claiming that the market would find a way to develop higher CRI light sources without being motivated by regulations. In fact this is what happened- most of the top LED manufacturers now offer high CRI products. I like to think that this happened because the market demanded it, and that some manufacturers foresaw eventual regulation toward this direction. In any case, the CRI requirement is one of, if not the most, important parts of the suggested changes, and regulation should be consistent with what the market is already doing, as well as make it easier for all manufacturers to offer high quality products.

2. Address Lower CCTs and Color Changing
In the 2013 standard JA8, LED lighting is required to have at least 90 CRI and a color temperature between 2700K and 4000K for indoor lighting. Because there is so much demand today for very low CCT sources, I recommend we lower this to at least 2400K. I also recommend we address color changing sources and systems, as they’re already in the market and will be a part of how we use lighting in the future.

3. Get a Handle on Flicker
Flicker mitigation is important in efforts to improve LED quality. One of the problems now is that there is no widely accepted testing and certification procedure for flicker. It’s also poorly understood, if at all, by consumers. I recommend not regulating it until we have a testing procedure in place that will support rating, certification, and labeling to consumers. By the time manufacturers begin to deal with this issue, a process should be in place. More about flicker here:

http://www.ledsmagazine.com/articles/print/volume-11/issue-4/features/developer-forum/proper-driver-design-eliminates-led-light-strobe-flicker.html

http://www.e3tnw.org/Documents/2011%20IES%20flicker%20paper%20poplawski-miller-FINAL.pdf

4. Ensure Dimmers & Transformers Are All LED Capable
Manufacturers are already making many new LED compatible transformers and dimmers. Regulations should require them, and allow for certification and labeling.

5. Support the Screw Base Proposal
Bans on conventional incandescent lamps are expected to mature by 2017, and everyone will need to begin replacing them long before that. Indeed, when LEDs become an obviously superior choice to consumers, as they surely will very soon, we need to not impede adoption by making it difficult to install LEDS in existing fixtures. The proposal to allow screw base (Edison) lamps to comply with T24 has wide acceptance, and should be supported. I’m in favor of things that make lighting consumer friendly, and Edison lamps are easy to use, as opposed to many types of connections. Connection standards in lighting should be more like the successful ones in consumer electronics, like USB, that are well designed, consumer friendly, and gain wide acceptance.

6. Review the Recessed and Enclosed Provisions
One of the proposals on the table is to require that all enclosed and recessed lighting be high efficacy and “hardwired”, meaning a dedicated fixture without removable lamp. I’m of two opinions on this. I wouldn’t support it because it does not in practice pass the “technology neutral” test, as “hardwired” fixtures, or integrated LEDs, have traditionally been expensive, and they’re a perfect example of something that will be outmoded soon after installation. With the appropriate fixture and lamp combination, you can do the same thing as an integrated luminaire for a lot less money, and you can swap out the lamp when you get a better one. However, the real reason for this proposed requirement is that there are widespread thermal performance issues with LEDs- even though they run cooler than incandescents, they can generate a lot of heat in enclosed fixtures and much more sensitive to higher temperatures. In recessed and enclosed fixtures they can pose a fire hazard. Also, integrated fixtures are becoming much more affordable, so until thermal performance issues are resolved with LED lamps, the rationale is that it doesn’t make sense to allow them as high efficacy sources in enclosed and recessed fixtures. Maybe we have to wait on this one.

7. Rethink Lifetime Expectations
This is a problem that I’m not sure I have a regulatory answer for. LED lifetimes claimed by manufacturers are largely irrelevant and don’t bear much relation to real-world conditions, for several reasons: 1.) Actual lifetimes depend on other components like drivers, which are not necessarily as long-lived as lamps, 2.) Actual lifetimes are difficult to predict, as the testing system depends on extrapolation- 50,000 hours of over 6 years of 24/7 use, 3.) LEDs don’t fail noticeably, they slowly degrade, so it’s difficult to tell when to replace them, 4.) Manufacturers often claim long lifetimes because they don’t often have much that differentiates their products, the initial high price of LEDs needs to be justified with long life, and consumers simply think that longer is always better, and 5.) LEDs will certainly improve dramatically, with lower cost, higher quality, and increased efficiency well within five years, and installations of current products will most likely be replaced anyway. The bottom line for manufacturers is that lowering lifetime thresholds will make LEDs cheaper, speeding up adoption, bringing down price, and saving more energy sooner. It seems counterintuitive, but maybe we could argue for lowering lifetime requirements.

8. Convene More Roundtables
In my opinion, ( and Mr. Benya’s) more industry roundtables on LED lamps, fixtures, and controls should be convened ASAP. Manufacturers should be invited and consensus should be reached on all proposed changed to the Standard. If you're a manufacturer, make sure you're represented at these meetings.

A Brilliant Future, If We Get it Right
Despite the formidable technical, economic, environmental, regulatory, and political challenges involved in the current transition in lighting, I believe that the future holds the very real possibility of better electric lighting everywhere- higher quality, cheaper, more flexible, and significantly more energy efficient. The new technology is too compellingly better in almost every way, but technology alone is not enough, nor is any single part of the process. Industry, government, consumers, and NGOs all need to work together to get the regulations right. If we don’t, we run the risk of delaying crucially needed energy use reductions and improvements in light and indoor environmental quality. You can play a part in this by making informed comments to the CEC.

How to Comment
The best contact method is email at docket@energy.ca.gov. Please include the docket number #2014-BSTD-01 and indicate 2016 Building Standards Update in the subject line. Please include your name and any organization name. Comments should be in a downloadable, searchable format such as Microsoft Word (.doc) or Adobe Acrobat (.pdf)

Light...By the People and For the People

Kickin' it the Merkan way with my boy U-Sam in Troy, NY.
Snap by George Gruel.

In a recent LI discussion group post about the role of government regulation in lighting, one ornery contributor took issue with my use of the term “environmental justice,” referring to it as a “silly term” coined by meddlesome “statists.” This made me realize that perhaps some people out there may not see eye-to-eye with me about shaping the regulatory environment around lighting, could it be? So I thought I’d better explain myself on this idea in a forum where the shouting is somewhat more filtered out.

I love it when I’m deeply ruminating on something (in this case it was the entire idea of government and how we believe it’s generally irrelevant) and I read a piece that neatly sums up a position and conclusions I’m already coming to on my own and points to a path of action. In this case it was Nathan Heller’s brilliant piece on the current clash of real people and the invading technocracy in my hometown San Francisco, California Screaming in the July 7 New Yorker. Here he points out that government is pretty much the opposite of innovation (kissin’ cousin of the recently mortally wounded meme whose name is Disruption) and the exquisitely efficient transfer of information that has come to define our culture today. Government is slow, participatory, painful, endlessly iterative, analog, and frustrating, but it still works. (It does, OK? Who builds the roads and delivers the water?) The really radical thing for Silicon Valley companies and people to do would be to embrace and enhance government as it is rather than constantly trying to reinvent it, or turn it into software-driven private enterprise. Of course information technology has made many functions of government infinitely better, like paying parking tickets. That doesn’t mean that the idea of government is over, or dead. That’s basically what Ted Cruz and the Tea Party want you to believe.

EPA (an agency I’m not always in agreement with) defines environmental justice as “…the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” Also, “EPA has this goal for all communities and persons across this Nation. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment in which to live, learn, and work.” That works for me: equal distribution of income, equal protection, equal opportunity. If that’s silly to you, call me a communist, or worse, a liberal. But if you’re not participating, step aside. I’ve got work to do.

My radical idea is to consider the built environment, especially indoors, where we spend almost all of our time, as probably the most important part of the “environment,” especially when it comes to lighting. This is something we’ve never really done before as far as I can tell. I mean, sure, jungles and spotted owls and rivers are worth saving for future generations, but let’s also focus on buildings, cities, all the built environment in the public domain, and apply ideas of environmental justice to its financing, regulation, design, construction, maintenance, and use of materials, energy, and water.

We’re still at a global tipping point with lighting. We have suffered far too long from crappy lighting in most of the global built environment. Incandescent lights have acceptable quality, in fact they’re mostly what we still recognize as lighting when we’re not at Walmart or in general commercial office wasteland, but now we know they use way too much energy. Fluorescent lights have to go- we hate the way they make things look, and they don’t save enough energy. LEDs will provide wonderful light in the future, save a lot of energy, and solve most lighting problems, but only if we get the regulations right. With incandescents being phased out globally, manufacturers will continue to just make the cheapest LED lighting they can and consumers and businesses won’t have much choice unless we get involved. We won’t revert to incandescents and we won’t suddenly adopt more CFLs- that’s a dead technology. LEDS superior in all ways than incandescents are already on the market, it’s just a matter of how quickly they’ll be adopted. Rapid adoption of LEDs is good for reducing global energy use sooner, but their quality has to be as good as incandescents. It already is, most people just don’t know it yet. Regulation will play a catalytic role in making better LED lighting widespread. We all have to get much more involved in order to make this happen, and we have to believe that getting involved matters and that government works- they do, trust me. You can help, more on this below.

I started a Facebook page on July 4th last year: People Against Bad Lighting. It was tongue-in-cheek and part of a product marketing effort, but there was some real political purpose there beyond selling LED lights. In the process of doing this I got to riff on the Declaration of Independence, which involved actually reading it, something I highly recommend. Lately I’m realizing that on some level, I’m still proud of being an American and of the basic blueprint of our government, flawed and tenuous and constantly embattled as it is. In my mind the best thing about it is that it contains instructions for ongoing reinvention, retrofitting, and renovation. If that makes me a “statist,” one who believes in the idea of “states,” with participatory government, then I’m guilty as charged. I’m not exactly sure what the viable alternative to being a “statist” is today, unless it’s reverting to tribal nomadic social structure. Ghengis Khan did the nomadic thing pretty well actually, but he evolved into a statist, and one with startlingly modern notions about religious freedom and equal distribution of rights and resources. Besides, he’s been gone kind of a long time and there are a few more people on the planet now than there were in his time.

Environmental justice in lighting means that all people have the right to high quality lighting indoors and out, just as we have the right to high quality water and air indoors and out. Egregious violations of our basic environmental rights as humans with lighting may not seem as life threatening or heinous as water and air pollution and carcinogenic pesticides, but they’re still important- more so because they’re largely unrecognized.

There is global awareness of the problems of light pollution, overlighting, and encroachment in outdoor lighting- all exacerbated by the recent rapid adoption of high blue spectrum LED light, harmful to humans and other living species. Public outdoor lighting has historically often been highly contentious and politicized, as it should be. We’re trying to figure out the extent of negative health effects from poor quality indoor fluorescent and LED lighting, but it will be quite some time before we can draw enough conclusions to effect real legislation around this issue. In the meantime, the fact that bad indoor lighting is ugly and demoralizing as well as too energy intensive is enough to consider it a serious environmental problem.

There are other important benefits to encompassing lighting within the concept of environmental justice. From my experience in green building, I know that lighting retrofits are responsible for “jump starting” a huge number of energy efficiency projects, as lighting is the single most visible use of electricity. Projects that start with the “low hanging fruit” of lighting replacement very often go beyond that as people start to look at buildings more holistically. And while LEDs now may still seem to many to be too expensive and only for richer people and fancier buildings, the technology will soon become prevalent and widely available to everyone, in high quality. In fact it will also provide electric light for the first time to many who have not yet adopted incandescents or fluorescents, just as many people in developing countries who never had landlines now use cell phones.

For those in the lighting world, and for that matter anyone concerned with energy use, “resilience, “sustainability” and global warming, now is the time to weigh in on proposed changes to California’s Title 24 energy code around lighting. Here’s where to start participating http://www.energy.ca.gov/title24/participation.html. In addition, I and some of my colleagues will be providing summaries of the proposed changes and recommendations about how to comment. Do this even if you don't live or work in California, or the U.S. as the quality provisions being considered here will affect lighting far beyond the state.

The best example I’ve seen so far of true participatory “redesign” of government was the UK’s Government Digital Service’s revamping of government websites. This is inspiring to me as a designer, a writer, a marketing person, a web developer, a researcher, and a citizen. If we could have this level of effort and results in lighting regulation and the subsequent transition to a new lighting and energy infrastructure, there would really be justice in the world.

Day Light, Night Light, and Control of Fire

If "disruptive" lighting technology is the answer, what's the question? We know it's more than "how can we make lighting more energy efficient?"- CFLs did that at the cost of quality of light. Perhaps we can look at human evolution for some more interesting questions, and eventually, answers.

A 2009 book by Harvard biological anthropologist Richard Wrangham, Catching Fire, presents a startling new theory: control of fire was the defining event in human evolution, as it led to cooking, which allowed us to absorb nutrients more effectively and led to big brains. Wrangham’s theory is particularly well argued and seems to be generally well received in the scientific community. One big fan (besides me) is food writer Michael Pollan, who cites the theory several times in his latest work,Cooked, which, among many things, explores how cooking impacts social cohesion.

Wrangham is mainly concerned with fire’s dramatic impact on human alimentary processes and the changes that followed from that. Cooked food is absorbed much more easily than raw (even wild animals prefer it), so it ultimately freed up time previously spent in chewing, digesting, and other tedious forms of processing raw food. Humans who adapted well to the control of fire obviously survived to evolve and prosper. What if we examined the evolutionary effects of fire on vision? If fire was indeed the evolutionary turning point, doesn’t it make sense to ask whether some of our behavior around light and energy use may be instinctive or genetically driven? Could we have a “fire gene” (or genes)?

We know that light has a strong impact on cognition, behavior, and emotional response. One rarely considered behavior that lighting impacts is how we use energy, as lighting is the most visible use of electricity, which can be seen as “sublimated fire.” We’ve lost a direct connection to energy since the electrification of the world. One way to understand energy in a very visceral way is to gather wood for cooking while backpacking in the wilderness- energy spent on acquiring fuel can be directly measured in the output of the fuel one gathers.

If we could incorporate an evolutionary biology perspective in research on light, what would that mean?

It may provide a new theoretical framework for understanding light and lighting, especially spectral design, in the context of new technologies- our current exposure to ubiquitous “broken spectra” light sources is analogous to the empty calorie diets we now consume, as Soraa CTO Mike Krames points out in his latest blog. Humans obviously evolved with only two types of light spectrum- daylight (in all its permutations) and “night light” (from incandescent sources). Exposing ourselves for long periods to light with unnatural spectra that deviate in basic ways from these two seems as unadvisable as ingesting pesticides, breathing polluted air, and eating a diet of overly refined industrial foods.

Research done from evolutionary perspective might give lighting design more and richer kinds of evidence upon which to strengthen practitioners’ role as “behavior modifiers” in the built environment. The best designers today operate equally well on both technical and aesthetic levels, but it’s the behavioral part of design that is least understood, and probably most important.

The revolution in lighting technology we are now undergoing provides us with unprecedented flexibility in designing lighting for healthier, more productive, and efficient buildings. Much more research is needed for us to develop a better understanding of the behavioral impacts of light on humans and other living organisms, so that we can finally apply optimal lighting on a wide scale in the near future.