In comments filed with the California Energy Commission (CEC), the National Electrical Manufacturers Association (NEMA) and its Lighting Systems Division Members s expressed its appreciation to the CEC for including a number of NEMA recommendations in recently adopted revisions to the Title 24 Building Energy Efficiency Regulations. NEMA further reiterated its support for NEMA’s lamp flicker standard that was not included in Title 24 at this time and thanked the CEC for fostering a collaborative standards development environment over the course of the rulemaking proceeding.
NEMA and CEC worked alongside lighting industry experts to assist representatives from the California Investor Owned Utilities and inform the Codes and Standards Enhancement (CASE) teams on product performance and design considerations for lighting controls and luminaires paired with them. Research from this two-year collaboration resulted in improvements to the quality and accuracy of the CASE proposals, which helped inform CEC’s decision-making.
The NEMA proposal to allow NEMA Standard 77-2017 as an alternate test and performance standard for LED lamp flicker was not incorporated into the final regulation, and we continue to reiterate the need for its adoption. NEMA Standard 77 is an effective, data-driven, accurate test and metric for LED Flicker. Its increasing, voluntary use across a broad spectrum of scientists and industry continues to bear out our position.
On balance, the final regulation did improve the clarity and content for Luminaire Alterations in Place in Section 141.0 as well as in Chapter 4 (Section 130) for controls interactions, daylighting and luminaire classifications. These changes to Luminaire Alterations will improve conformance and understanding for building engineers, designers, and installers as well as allow them more flexibility to use lighting controls more often and more effectively.