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.
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:
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 firstname.lastname@example.org. 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)