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.
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.
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.
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.
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