By Alex Boesenberg, NEMA Regulatory Affairs Manager
The National Electrical Manufacturers Association (NEMA) called on the California Energy Commission (CEC) today to ensure that California consumers have access to the most efficient and cost-effective LED bulbs currently on the market. A regulatory proposal under consideration at the CEC would compel California residents to buy more costly, less energy-efficient LED bulbs for their homes than consumers in other states without countervailing benefit.
NEMA has urged the CEC to revise the proposed energy-efficiency targets for decorative, reflector, and directional LED lights and agrees with the proposed starting energy-efficiency target for omnidirectional LED bulbs, which are viewed as aggressive yet achievable. The targets for each type of LED bulb must be achievable with current technology, striking an appropriate balance between efficiency, product availability, and consumer needs and cost.
NEMA’s disagreement with the CEC’s proposed regulation for LED bulbs is centered on the consumer’s perception of the color of the light. It is a nuanced technical point in lighting science about which experts disagree, but the CEC proposal ignores crucial tradeoffs that innovative manufacturers make to ensure that consumers are satisfied: first, that consumers get the right quality of light for their particular needs; second, that the price of the light bulb will continue to decrease; and third, that they continue to stimulate demand for the most efficient LED bulb. The CEC proposal fails all three of these tests because it would overregulate the LED bulb color specifications that California consumers will be forced to buy, creating unnecessary barriers to achieving California efficiency targets.
Under the proposed regulation, an LED bulb would be required to meet very specific requirements for individual color elements that make up the color rendition of artificial light. The regulation focuses on a lighting performance parameter known as color rendering index (CRI), which attempts to express how colors shift when compared to a defined source, such as incandescent light. Differences in consumer appeal for lamps with a CRI of 80 or, alternatively, 90 or higher are typically application-dependent. However, a very high CRI is not essential in many tasks, and many people either see little or no difference between a high CRI of 80 and a very high CRI of 90 or have no preference for CRI above 80. In limited applications, a very high CRI can be desirable.
A light bulb’s CRI represents an average of eight individual test colors. The CRI by itself has nothing to do with energy efficiency, but LED bulbs with a very high CRI are less efficient and more costly to manufacture. Most LED bulbs today achieve a CRI at or slightly above 80, and they are increasingly affordable. LED bulbs with a CRI of 90 or higher are available as well, but they are less energy-efficient and more costly because of additional required components. NEMA urged the CEC to ensure that consumers continue to have a choice among high and very high CRI options at different price points to avoid financial barriers to adoption of the LED lamp technology by consumers.
The ENERGY STAR® program that identifies high-performance, energy-efficient products requires a minimum CRI of 80 for LED bulbs. Last year, the ENERGY STAR Lamps program accounted for almost eighty million LED bulb sales nationwide, and the vast majority of these bulbs were 80-CRI products. With its proposed specifications for individual colors, the CEC is forcing consumers to buy LED bulbs with the higher 90 CRI. The CEC staff believes the higher CRI will impact consumer satisfaction, but the sales data from ENERGY STAR establishes that consumers are satisfied, for most of their needs, with more affordable LED bulbs.
If the regulations are adopted without NEMA’s proposed revisions, California consumers will have fewer LED options, and those options will be noticeably more expensive and less energy-efficient than other lighting options, which will undermine California’s energy-efficiency objectives.
The CEC could adopt a proposed regulation as early as January 13, 2016.
See NEMA’s fact sheet for more information on this issue.