On Jan. 27, the California Energy Commission (CEC) approved the Title 20 appliance efficiency regulations that apply to general service LED lamps (“bulbs,” in consumer terms). This move sets the first in-state energy efficiency standards for LED lamps used in household fixtures and chandeliers, as well as directional lamps with a diameter of 2.25 inches or less, which are the type of lamp often used in tracklighting for retail, hotel, and museum applications. Sounds like a good thing, right? It would, except there’s more here than meets the eye. Because California operates according to stricter energy guidelines than other states, they are allowed, as outlined in the Energy and Independence Security Act of 2007, to adopt rules two years in advance of federal passage. But should the federal government meet its rulemaking deadlines on time, then the federal regulation supersedes anything at the state level.
The National Electrical Manufacturers Association (NEMA) usually agrees with the CEC on matters pertaining to lighting regulation—but not in this case. NEMA reached out to the CEC repeatedly during the 45-day comment period, which began in December 2015, stating its reasoning and providing data to support its position. While the CEC did respond to a few of NEMA’s requests for additional information, it did not fundamentally change its stance on the issue. As the vote approached on Jan. 27, NEMA reached out again and provided a 16-page comment response to the CEC, which is available on its website.
One of the main issues that has set NEMA and the CEC at odds is the role of color—color rendering index (CRI), specifically—as it relates to energy efficiency. Starting in January 2018, all lamps in California will have to meet certain CRI requirements and have a lamp life of 10,000 hours. The smaller, directional lamps will have to have a lamp life of 25,000 hours. According to the Associated Press, the CEC has suggested this requirement “will save consumers more than $4 billion in utility bills over 13 years.”
But as NEMA points out, the Title 20 rulemaking language advocates for a high CRI requirement for R8 values. In order to achieve this, manufacturers would have to produce lamps with a minimum CRI of 90 to meet the requirement, rather than lamps with a CRI of 82, which the new rules permit in other applications. Higher CRI lamps are less energy efficient and cost more to produce. The CEC move would mean California consumers would have to buy more expensive, less efficient, higher CRI lamps, compared to consumers in other states. Price point is regularly cited as one of the main barriers to adoption of LED lamps.
While the CEC has already voted and approved this measure, the disagreement between the two groups highlights the bureaucratic nature of regulatory discussions and the archaic, opaque nature of the review and comment process. No one comes out a winner, least of all the consumer.
The pace of LED developments is far faster than the regulatory process. All stakeholders—from manufacturers to government agencies—have to figure out a better way to work toward energy efficiency that allows consumers choice and doesn’t regulate “design” out of lighting design. However, all this could be moot as the U.S. Department of Energy holds it hearings on general service lamps on April 20 in Washington, D.C. Depending on the outcome, it could supersede most, if not all, of the energy standards adopted in the Title 20 rulemaking. •
Elizabeth Donoff
Editor-in-Chief
edonoff@hanleywood.com
