Posts

Part L of the Building Regulations Code in the United Kingdom – A Mini EISA Scenario?

Here at JimOnLight.com, sense is trying to be made of the current labyrinth (movie starring Jennifer Connolly and David Bowie) that is the Energy Independence and Safety Act (EISA).  As we dig deeper and deeper into a piece of legislation that could actually do some good if it wasn’t so heavily balanced on income, news of some changes in a similar-but-not-same legislation in another country has some interesting components that need discussing.  it’s called PART L of the Building Regulations in the United Kingdom.  Ever heard of it?

PART L is a bit of legislation in England and Wales that generally tries to legislate the consumption of fuel and power in buildings.  Obviously there is a lot to this document; and in a document that has a lot, it’s bound to have flaws.  How many of these flaws will be allowed to get through?  A lot of people think time will tell, but the time to act to change some of the absurdity is running out to affect a change to get implemented any time soon.  The next opportunity to make a change?  2016.

If you’re interested in checking out the actual verbage of PART L, here’s a link directly to it.  Here’s the latest changes to the PART L document, too.

Basically, PART L is broken up into four parts.  L1 pertains to dwellings, L2 pertains to non-dwellings:

  • L1A:  New dwellings
  • L1B:  Existing Dwellings
  • L2A:  New Buildings other than Dwellings
  • L2B:  Existing Buildings other than dwellings

From what I understand, one large portion of the hullaballoo with PART L right now is in the way it deals with “energy efficiency.”  Generally, the issue is in the way that said energy efficiency is actually legislated.  Right now, PART L deals with a luminaire’s efficacy, and people involved in wanting to improve the legislation want to move to a lighting systems-based efficacy.  Doesn’t that kinda make more sense?  It does seem like we should be done with relying on the good ol’ toggle light switch, it is 2011 after all.

I had a quick conversation with lighting designer and Twitter persona Liz Peck about this PART L business – to get more information on it from someone who’s right in the middle of it.  Liz gave an excellent PowerPoint presentation on the PART L Regulations, and has been published in LUX Magazine.  Liz is also principal at LPA Lighting, her lighting design firm.

The interview:

JOL:  Liz, can you fill me in on what PART L means for people living where PART L would be implemented? What would an outside observer to PART L need to know?

Liz Peck:  Part L of the Building Regulations governs the “conservation of fuel and power” and it applies to all new and refurbished buildings in England & Wales. Scotland & Northern Ireland have different building regulations but in essence they all follow the same pattern. It’s divided into domestic and non-domestic buildings, but for both, compliance with Part L is based almost entirely on luminaire or lamp efficacy. This means that the application of lighting is often lost, especially in projects where specialist lighting designers are not involved – the principle is that as long as the luminaire complies, then it’s an energy efficient scheme.

As a lighting engineer, what does PART L mean?
It means very little as it’s so easy to comply with. I don’t think it really influences how we approach the lighting of buildings; most lighting designers would comply with Part L without even trying.

PART L seems a little like the Energy Independence and Security Act (EISA) here in the United States.  EISA has a lot of very confusing aspects to it, and people in the US generally have no idea what it means.  Is PART L a lot like that with respect to its complex nature? What could be done to alleviate confusion?
From what I know of it, the ambitions of the EISA are a little greater, though they certainly have some similarities in the use of energy efficient light sources. The confusion in Part L lies predominantly with its flaws, of which there are many. For instance, in non-domestic buildings, it allows an efficient luminaire to be left on in an empty building because there is no need for controls beyond a manual on/off switch. How can that ever be thought of as efficient? Equally, for some areas in the building, the targets remain on lamp efficacy with no regard to luminaire performance, so in theory you could have a ‘black box’ luminaire with zero light output but if it contained T5 lamps, it would be compliant! In domestic buildings, it’s not much better: the requirement is for 75% of “light fixtures” to be energy efficient (40 l/w) but there is no requirement for the fixtures to be dedicated, so the reality is that the plans get approved with either CFL or LED lamps specified in traditional lampholders and then as soon as the occupants move in, they switch the lamps to less efficient sources that they prefer!

Are there cons to PART L with respect to the way it legislates luminaires instead of systems?
I think it’s the lack of need for controls which is its biggest flaw; we’re a decade into the 21st Century and the ‘recommended’ controls strategy is a manual switch. We really need to move on; the controls aspect is so out of date, it’s almost unbelievable. To have a situation in 2010 when absence and daylight sensors are considered advanced lighting controls for new buildings is a joke. These are basic controls which no new building should be without unless they have very good reason. The old adage of the most efficient luminaire is the one which is switched off when it’s not needed doesn’t apply to Part L. Things have to change.

What else should people know?
Trying to get most people to understand lumens per watt is fruitless; most people running a building, whether it’s their own home or a commercial office understand only two metrics: energy and money. Metering is becoming more prevalent in commercial buildings and is being introduced into the domestic market – maybe when people can see just how much energy they are using through lighting, they will start to think about improving it, but all the time the Building Regulations only require the use of efficient sources and not their application, we will (sadly) continue to see inefficient lighting schemes being installed. We must move to a systems-based approach, with targets on energy consumption, if we are to really make a difference in the future.

I also did some digging and found an interesting article at LUX Magazine on this subject, written by Iain Carlile of DPA Lighting Design.  Iain’s article, entitled “Why We Must Fight for PART L,” had some very direct commentary on PART L legislation.  In reference to why PART L needs changing:

Part L is correct in its requirement to reduce energy consumption, but the metrics used for lighting are quite crude and predominantly only cover the efficacy of the luminaire — not the total energy consumption of the lighting system.

This leaves us in a ludicrous situation. The lighting scheme can comply with the requirements of Part L but still waste energy through the unnecessary lighting of unoccupied or daylit areas.

For example, look at many commercial properties where all of the lighting is on throughout the night when the space is unoccupied. These installations can have efficient luminaires and lamps, achieving low installed electrical load per unit area and high luminaire efficacies. But the absence of simple occupancy controls means the lighting can remain on for more than twice the required operational hours, wasting a huge amount of energy.

The installation may meet the requirements of Part L, yet in fact the installation can be quite wasteful of energy because the lighting is not switched off when it is not required.
Recent advances in technology make it possible to specify LEDs for ambient lighting that emit an excellent quality of light across the visual spectrum, with a colour temperature and colour rendering properties that compare favourably with tungsten lamps.

Iain’s resolution to PART L?

For this situation to be resolved, future revisions of Part L must change the metric used for measuring the energy efficiency of a lighting installation.

We must as an industry challenge the existing legislation and push for a suitable metric that considers not just the efficacies of lamps and luminaires but also includes factors such as lighting controls, dimming levels, hours of operation, daylight linking and presence detection.

Only then will we have legislation that allows the intelligent application of the ‘right light, right place, right time’ philosophy.

Personally, I am glad to see that the Society of Light and Lighting is pushing for a move to systems-based targets in the next revision of Part L.

If you’re looking for a quick five-minute overview on PART L, check out this video below:

Do you think that the public would feel good about PART L if they had someone explain it to them so that it made sense?  As far as EISA goes, that seems to be a lot of the problem.  Perhaps if more people knew about the legislation that the government was trying to put in place they could make a more informed decision.  It’s nice to know that at least America isn’t the only country in the world in which its people have to actually TRY to find out the real truth about things in which its government is involved.

Something I found pertinent and relevant from the LUX Mag article was a quote from Martin Valentine, a lighting expert in Abu Dhabi City.  He talks about the way we need to go forward:

‘We need to be looking at controls and overall limits as well as luminaire efficiency. But we also need to not lose sight of light quality. The four things work hand in hand.’

Valentine warned that the danger with complicated legislation is that nobody really knows what is going on. He believes Part L is a good thing but needs to move with the times, rather be caught behind.

He said: ‘It needs to evolve and it needs to be clear cut. People need to know what’s going on and benchmarks need to be in place.’

Thanks to LUX Mag, Liz Peck, iRed, and Wikipedia!