Comments on Review Study and Working Document

Transcription

1 Comments on Review Study and Working Document The International Association of Lighting Designers (IALD) are pleased to be able to provide professional insight and comment on Review Study of the stage 6 requirements of Commission Regulation (EC) No. 244/2009. Our comments are necessarily somewhat truncated due to the materials not having been available to us until 25 October 2013; nevertheless, we offer the perspective of independent professionals who design lighting in the built environment and specify lighting devices for all types of applications. While we always design the most energy efficient schemes possible that deliver the project requirement, we believe that the proposals in the working document both hinder the delivery of effective energy efficient lighting schemes and will seriously adversely affect existing lighting installations without any reliable expectation of an effective energy saving. We recommend abolition of the stage 6 requirements of the regulation without further future review. Our reasoning is straightforward and grounded in both available data and experience: current regulations have actually inhibited the development of more efficient incandescent technologies because of uncertainties about the path of future regulation. If the expectation is that LED technology will advance and prices drop as expected in the review study, then the halogen replacement lamp will disappear at the point where users decide there is no longer a market. If LED technology or a reduction in price fails to deliver viable alternatives, then the market will demand higher efficiency Medium Voltage Tungsten Halogen (MVTH,) and the lamp industry will develop product in the same way that they filled the market demand with MVTH lamps after There appear to be major gaps in the information as currently presented in, the Review study on the stage 6 requirements of Commission Regulation (EC) No 244/2009. Final Report and associated Commission staff working document. As was acknowledged during the previous consultations on EcoDesign requirements for domestic lighting, decisions made have a significant impact on users of the affected lamps in the commercial and public realms. There remains no separate market information to determine the split between tertiary and domestic users of the affected lamps. As previously Lock In is discussed solely from the domestic perspective. For aspects of the tertiary sector, this remains a very significant issue. For many projects, MVTH has successfully replaced conventional incandescent, In contrast, SLL (Solid State Lighting, [usually LED]) replacements lamps have to date been problematic in several key areas: 1 Dimming: LED replacement products are offered that are supposed to dim. There are major technological incompatibilities that cause this to be challenging, particularly when producing a product to a price. The dimming behavior and characteristics do not match MVTH. The US DoE Caliper report Dimming LEDs with Phase-Cut Dimmers: The Specifier s Process for Maximizing Success 1 published in October 2013 usefully describes the problems and indicates the increased work load on lighting designers to try and ensure effective design outcomes. 1.1 LED replacement lamps do not dim to extinction. None of the LED lamps we have tested will start at minimum dimmer settings. This makes them totally unsuitable for use in situations where this is a necessity, such as theatre house lights, presentation suites, houses of worship, etc. The failure to restart at low settings creates safety 1 1

2 issues. In the tertiary area, control systems are not able to reliably recall low lighting levels. In the domestic setting where a dimmer is part of a two-way switching circuit (such is typical in stairs and corridors), if the dimmer is set low and the light is switched off from the counterpart switch, say at the top of the stairs, then lamps do not re-light when switched back on. Obviously, a stairway or corridor, that may have furniture obstructions, cannot be safely traversed in the dark, particularly in an urgent or panic situation. 1.2 LED lamps do not appear warmer as they dim. Many present an apparent cooler appearance as they are dimmed and colour rendering appears reduced. This makes them particularly unsuitable in many hospitality situations, such as restaurants, lounges, etc. LED products that do apparently warm as they dim are becoming available as complete systems or luminaires. The complexity of control required suggests that this is unachievable in a replacement lamp form factor that will work with existing installed wiring and dimming. 2 Physical factors. To achieve the required heat dissipation, LED lamp replacement products need to be heavy. This causes significant problems with historic light fittings, existing suspensions (particularly of the rise and fall type), fittings, and also desk-mounted task lights that rely on balance, friction or springs to allow adjustment of position. This application has also precluded the use of Compact Fluorescent Ballast integrated lamps (CFLi) which, as well as excess weight, also exhibit problems due to excess UV in this application as was acknowledged in the Scientific Committee on Emerging and Newly Identified Health Risks (SCHNIR) discussion. This has serious impact in the tertiary sector as these fitting types are widely used in offices, education and health care. By nature, these applications tend to be for intermittent, short period use with frequent switching, making MVTH by far the most suitable source. In the discussion on MVTH, the proposal to remove R7 and G9 cap lamps from the market also has very significant impact on the tertiary sector: R7: The compact linear form factor of this lamp makes it specifically suitable for optical control. Its simple technology and controllability suit it to many applications that are not possible to serve with replacement technology. Specialist applications that also require dimming include museum displays. The higher wattages are also extensively used in theatre; therefore, continued supply will remain necessary for what are specialist applications as defined in regulation 244/2009 that are exempt from the provisions of the legislation. Attempting to regulate the supply of these will only increase the burden on the already stretched resources of the EU countries market surveillance systems. Tungsten Halogen Infra Red (THIR) versions of these lamps have been in the market but have failed to achieve major market penetration. These very nearly achieve class B performance. Manufacturers must be facilitated and encouraged to maintain or introduce the higher efficiency versions of these lamps. Currently these lamps are not being specified for new architectural lighting applications therefore lamps will only be required to supply the existing and diminishing stock of fittings with these lamp bases. G9: The arguments for removing these lamps from the market are wholly unconvincing. The two examples of G9 adaptors for screw base lamp holders that we are aware of are niche products that are highly unlikely to become mass market products. On the basis of the exemption in the existing regulations, many fitting manufac- 2

3 turers have re-designed fittings previously using screw base sockets for G9 bases. Many of these are used particularly in high-end hospitality projects associated with large scale dimming systems that would also require extensive modification or replacement. As Independent Professional Lighting Designers, we have specified these products on the basis of the exemption in the existing regulation. The implication of removing G9 MVTH lamps is that Lighting Designers who have specified these since the publication of the legislation would be subject to claims by the clients who have installed this equipment as, if lamps are not available for the reasonable life of such equipment it would no longer be fit for purpose. It is extremely difficult to put a value on this potential risk, but individual claims would be sufficient to cause individual designers Professional Indemnity insurance costs to increase in each and every future year. Claims can also result in refusal of future insurance, thus potentially preventing individual designers from continuing in independent practice. It is not possible to canvass the profession within the timescale available for these comments to determine the scale of this potential issue. In respect to the lamp adapters for existing screw and bayonet bases, these provide a reasonable option for historic light fittings where the lamp shape is an important part of the fitting design. There is a wide range of lamp shapes used historically, and there is no evidence that any other than the most common will be available as LED replacements. The cost of tooling for the low volumes required for a niche market are not economic. Lamp shapes that are not currently available include twisted candle in three different sizes, flame in two sizes, tipped candle, and long candle. Lamp bases such as B14, E14, E12 and E10 are too small to sustain the necessary electronics or weight of heat sinks required for either LED replacement lamps or for a low voltage converter without considerable risk of damage to existing lighting equipment, which may be of particular historic significance. We would value development of the G9 base MVTH and production of higher efficiency versions. However, this will not be encouraged by placing time limits or further threat of review on the energy requirements for these lamps. With specific reference to the report as a whole, we agree with the CLASP comments that the report as presented is incomplete and refers to outdated data. For example: Page 17, footnote 13: The data relating to mercury emissions is out of date. The source is not cited. The most recent figures available indicate mercury emissions from electricity generation to be mg/kw As an average across EU27 for Due to the rapid withdrawal of coal fired generation in favor of renewables and gas, the speed of reduction in mercury emissions from generation is far faster than the data VITO have used suggestsuggests. ENVIRONMENTAL IMPACT ASSESSMENT: Environmental Impact Assessment: 2 Mercury emissions for thermal electricity generation derived from generation output figures derived from 3

4 This is very incomplete and relies on gross estimation of energy savings that do not appear to be based on data currently available currently. References to data and methodology used for the previous study in 2007 / 2008 are not reliable. Although not specific to this study, evidence needs to be presented proving the reliability of the estimates made in 2007 / 2008 for energy savings achieved by this regulation, based on the available data on for actual electricity usage through records published in the period from 2009 to date. Preliminary work undertaken last year in the UK suggested that there had been no actual reduction in energy demand during peak domestic lighting hours other than that attributable to the general reduction in economic activity resulting from the 2008 financial crisis. There is no discussion whatsoever of the embodied energy in the various lamp technologies. LED replacement lamps contain a considerable volume and weight of aluminium for heat sinks and a considerably higher electronic component count with increased complexity particularly for dimmable types. The data for the original study by VITO for the regulation is still unreliable due to deficiencies in the Ecoreport tool used. Additional research is needed to adequately populate the existing and new materials required for LED lamp production. The issue of end of life disposal is also not addressed. Estimates for post consumer recovery and recycling used in the 2007 /2008 study have proven wildly optimistic. There have been many issues reported where inappropriate disposal has caused risk and injury. The very small number of lamps collected through retail and local authority sites, compared to the number of lamps introduced to the market, means that the majority of energy saving lamps disposed of by domestic users and smallscale tertiary users are ending up in normal domestic waste. The consequence for CFLi is the introduction of considerably more mercury to the ecosystem than is anticipated in the previous study. The lack of recycling also significantly increases the requirement of prime materials and increases other undesirable waste in landfill and incineration. ECONOMICS The payback period data would also seem to be unreliable. All are based on projected 2016 costs, which are based on gross estimates for retail prices of LED lamps. It is notable that the volume lamp sellers have settled on a unit price of around 3.50 for energy saving lamps or either CFLi and MVTH. Prior to the activation of regulation 244/2009, the MVTH- LVTH lamps that were available typically retailed around 2. Currently, through secondary retail sources, MVTHLVTH are frequently available at 1.7. On 3 November , we noted that IKEA are is selling MVTH at 0.98 ( approximately 1.6 ).) Also, they have no energy saving product other than MVTH that meets the current Eco Design and Ecolabelling requirements for equivalent output to 100W incandescent other than 70W MVTH. The LED replacement lamps were retailing at 7. On the same day Saisbury s were selling MVTH at 1.99 or 2 for 3 as a brand match offer. LED replacement lamps were selling at While it is understood that the major retailers (supermarket chains and DIY sheds) rather than the lamp manufacturers decide final selling price, there does seem to be a question as to whether there are reasons for this apparent price inflation that are distinctly disadvantaging the consumer. Expectation for efficiency improvements in LED replacement lamps are also questionable. It is unlikely that theses products will achieve 125Lm/W while maintaining colour temperature of 2700K and a CRI in the region of 80. Current manufacturers claims and projections for improved efficiency relate only to high colour temperature and poor colour rendering products. There are physical limitations to energy efficiency for LEDs these include losses in phosphor conversion of blue or violet light produced by the LED chip to white and absolute 4

5 limit to the amount of light energy that can be extracted from any specific size of die due to the relationship between the volume and area of the physical device. The cost benefit overview is also substantially unreliable for the aforementioned reasons Throughout the report, where figures are provided for reductions in energy use, the word potential or possible should be inserted for accuracy to indicate that these are not proven figures and remain conjectural. HEALTH ISSUES: There is no discussion of the impacts of flicker and strobing that are endemic with LED products. Subsequent to the SCENHIR report, work by Professor Arnold Wilkins published in Lighting Research and Technology (LRT) 3 shows that strobing at frequencies at least as high as 10KHz are visible to human subjects. The USA CALIPER study on troffers 4 has extensive information on different flicker and strobing characteristics, particularly with dimmed LED products. Continuing work on the intrinsically photosensitive ganglion cells and the effect of blue light, in particular, on suppression of melatonin production is highly relevant to the use of LEDs in the evening, especially in the domestic environment. Levels as low as 1 Lux at the eye of the specific active range of wavelengths is shown to significantly alter melatonin production and therefore disrupt the circadian cycle and sleep patterns. The list studies referred to in Annex E is either incomplete or selective. The development and placing on the market of lighting products is far in advance of research on the impacts of these products on normal and diseased people. It is therefore essential that alternatives are left available in production for affected people or people who wish to make informed choices based on the evidence (or lack thereof) for the harm or safety of new lighting products. The recognition of this is included in the addition of photosensitivity to the specific specialist uses in DIM2. We recommend that such exception be extended to domestic use of lamps by people who have recognized photosensitive diseases or reason to believe that they will suffer from the use of any particular type or types of lamp. SAFETY ISSUES There is no discussion of product safety issues specifically related to LED replacement lamps. In the past year, there have been a number of high profile recalls of LED replacement lamps due to design or manufacturing failure. In many of these cases, the failure mode has resulted in the aluminum portion of the lamp becoming live to mains voltage. These safety issues have been brought to the public s attention by larger manufacturers. It is highly likely that other products have suffered from similar problems; however, the smaller importer or manufacturers may not have been so punctilious about declaring the problems. We also have evidence that a major manufacturer who is a member of LightingEurope has activated a silent recall for similar problems, recalling lamps from the supply chain rather than advising the general public of a major potential safety issue. RATE OF PRODUCT DEVELOPMENT As is evidenced by the failure of the industry to produce B class MVTH, which was predicted based on a single complex product that never made it to the mass market, the technical 3 Roberts J.E. and Wilkins, A.J. (2013). Flicker can be perceived during saccades at frequencies in excess of 1kHz. Lighting Research and Technology, 45,

6 studies have not proven reliably accurate in predicting developments in the lighting market. The expectation that all of the problems currently affecting the LED replacement lamp will be resolved by 2016, as stated in the Commission Staff Working Document that accompanied the report, is highly unlikely in our opinion. Some of the problems, such as weight and size, electronic component reliability, effective electrical load characteristics, complexity of electronics, optics, etc., are quite fundamental to the product class and are not likely to change ever, let alone in 3 years. Regarding the provision to ensure that luminaires sold after 1 September 2015 are compatible with LED technology, we do not understand how such a provision can be drafted unless this is a proposal to ban the E27, B22, E15, G9, R7 and other sockets that are primarily designed for direct mains voltage supply to lamps. This proposal also fails to address the much larger issue of existing domestic and tertiary sector wiring and lighting controls. This also fails to take into account the expected lifetime of light fittings and light fitting designs. Many fittings remain in the market that were designed in the 1930s or earlier. These include historic designs suitable for older buildings and more modern appearing designs whose longevity are testament to their fundamental quality and lighting performance. Is this proposal an attempt to re-introduce regulation of luminaire efficiency? This subject was previously wellrehearsed, and the problems and challenges previously discussed at length. CONCLUSION In conclusion, we believe that the correct course of action is the total abolition of the stage 6 requirements without further review. We would recommend to the Lamp Industry that it should undertake necessary research to improve the efficiency of MVTH lamps. We would also recommend that it maintain the expertise and employment of lamp manufacturing within the EU 27. As mentioned, the EU has available research funding; however, this has solely been targeted at LED development. If specific funding was made available for other lighting products and technologies, it would be easier for the manufacturers to develop efficient MVTH and LVTH lamps and provide genuine energy savings without the problems associated with technologies better suited for integration in complete new products and systems. Respectfully, Kevan Shaw Lighting Design, as consultant to: The International Association of Lighting Designers 6