By Maury Wright
Editor in Chief, LEDs Magazine
New CEC lighting regulations for general-service and small directional lamps will result in improved color rendering with a trade off in energy efficiency.
The California Energy Commission (CEC) has approved the new Title 20 Appliance Efficiency Regulations document that includes regulations on the performance of LED-based replacement lamps. Both general-service A-lamps and small directional lamps sold in California will now have to meet more stringent color rendering requirements that some in the industry believe will both cost more and use more energy than do the most popular lamps on the market today. Indeed, the National Electrical Manufacturers Association (NEMA) lobbied the CEC against the rule making, but the CEC also received numerous comments in support of the new lighting regulations.
NEMA has asserted that the most-popular and
most-affordable LED lamps on the market today feature a CRI of 80, and that
level of color rendering is suitable for most residential applications. Note
that there are lamps on the market with CRI of 90 and above and customers might
choose such more expensive products when the application at hand warrants such
The new CA Title 20 lighting regulations
only require a small bump in performance to 82 CRI, presumably. But NEMA and
other dissenters claims that the policy will actually result in lamps with a
much higher CRI. The new regulations actually set the requisite that lamps
deliver a score of 72 or greater for each of the eight pastel color samples
that comprise the mainstream CRI palette that is sometimes referred to as Ra.
NEMA has said that requiring a CRI of 72 for the R8 color sample, a light
red-purple hue, will practically mean a move to a CRI Ra of 90. The agency said
that no 82-CRI lamps on the market can meet the 72 R8 requirement.
The CEC action has a relatively long
history and came to public light when the CEC and the California Lighting
Technology Center published the "Voluntary
California quality LED lamp specification" in 2013. The
guidelines specified a 90 CRI and were intended to make sure that consumers had
good experiences with LED lamps whereas many consumers had very bad first
experiences with compact fluorescent lamps (CFLs), and those bad experiences
slowed adoption of the more-efficient CFL technology.
NEMA and the CEC agree on pursuing a goal
of increasing the proliferation of energy-efficient LED lamps, but completely
disagree on the policy. "Electrical manufacturers want to increase the
sales, efficiency gains, and overall use of LED products in California — we are
not at odds with that CEC objective," said NEMA president and CEO Kevin
Cosgriff after the CEC vote on the new policy. But he added, "The
regulations approved today were based on poorly analyzed data of the emerging
LED lamp market."
The range of comments from the public
leading up to the vote were generally in favor of the rule making.But many of
the supporting comments include identical language, making it appear that it
was an organized group of supporters behind those comments lobbying the CEC.
Generally, the supporters said more efficient lamps that don't match
incandescent color rendering are only delivering on half of the LED lamp value
proposition to consumers.
NEMA counters, however, that pricier 90-CRI
lamps will derail adoption while also using a bit more energy than popular
lamps on the market. "Today’s market price of general-service LED lamps is
nearing parity with the product they are primarily intended to offset, the
halogen incandescent lamp," said NEMAs Cosgriff. "And their price is
continuing to fall. By contrast, CEC staff analysis acknowledges the Title 20 proposal
enacted today will increase the price of LED lamps and that the proposed
designs are less energy-efficient than today’s more popular LED options."
NEMA has also pointed out that the US
Department of Energy is separately working on LED-lamp-performance regulations.
And the state and federal policy could end up misaligned. On the other hand,
California environmental regulations have often set precedents that were
adopted elsewhere in the US and around the globe.