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!

The Whole World v. The Incandescent Lamp

We’ve been reading over the last year or so about the war on incandescent lamps – people preach hate for them but people buy them in droves.  Why is this?  A good reasoning is money, money, and money – To buy a 6-pack of regular incandescent lamps (not Reveals or energy efficient models) costs about as much as a stick of beef jerky at the gas station.  When you’re living month to month, week to week, or unfortunately day to day as many of our fellow Americans are doing, a six pack of light bulbs for $1.12 seems a lot more cost efficient when looking at a $4.00 compact fluorescent or even a $40.00 LED replacement.

Your next question should be something along the lines of “but you’ll save so much down the road if you buy something energy efficient!” and you’d be right – but when you’re staring down debt in the face and trying to fight to stay in your home, generic peanut butter sounds better than none at all, know what I mean?

But never mind all that – what about those of us designers who think that the incandescent lamp should be an available choice?  A lot of us feel that “banning” the incandescent lamp is a bit rash of a decision – including the IALD.  There is no good replacement product for them yet.  It’s a poor decision, in my very humble opinion – and the public still wants incandescent light.  Whether it’s cheaper, people prefer them over the cold and sometimes green light that CFLs bring into homes, or lighting designers want to have incandescent choices, incandescents are certainly popular.  But that’s like saying margarine is popular.

When the US Congress passed the New Direction for Energy Independence, National Security and Consumer Protection Act (H.R. 3221), and the Renewable Energy and Energy Conservation Tax Act (H.R. 2776), lots and lots of people wrote, and I’m paraphrasing here:

Oh, lordy lordy, the incandescent lamp is so dead it’s mummified!  Viva la 2012!

*Ahem*

Other folks realized that these new standards that just got passed virtually make it so that no current incandescent lamp on the market would meet the standard requirements.  Seems like an obvious concern, doesn’t it?

Don’t get me wrong, I’m not naive or stupid with respect to this subject.  What we need is something that is way bright, gives us the color temperature we want, isn’t a zillion dollars per unit, and consumes as little electricity as possible.  What we have right now, in a feasible, sellable form, are incandescent lamps, which give off heat and consume lots of electricity; LED lamps, which have great color, output is improving, and consumption is ridiculously low with a long lamp life; and CFL (compact fluorescent lamp) sources that can put off really terrible color, contain mercury, and are difficult to dispose of properly.  They also rock the consumption rate, but they have their problems.

Well, the bills passed by the Congress certainly put new standards to meet, that is no lie.  What this has done, as things always do when pushed to meet a deadline, is force companies to take the regular ol’ incandescent lamp and turn it into something that acts efficiently, people like, and is cost effective.  GE put out an improved version of the incandescent, the HEI – or High Efficieny Incandescent, which is lacking in title creativity but not good intentions.  Philips just put out an energy saving incandescent, the halogen Energy Saver line.  It’s 70 watts and emits the same amount of illumination as a 100 watt lamp.

Ok, that’s a start! However, at this new 70 watt efficiency, the CFL world is still consuming 75% less than it.

Scientists are starting to see growth in the really horrible (comparatively, of course) incandescent output of 15 lumens per watt – they’re up to twice that now.  There’s tough competition in the LED and CFL categories for consumption levels for incandescent lamps, but we’ve just started.  It is a real shame though that it took some competition to get a train of thought started on improving incandescent lamp efficiencies, isn’t it?

What are your thoughts on this subject?  Please post in the comments below!

Sources: 1 2 3 4 5

US Congress to the EPA: Drop Your Energy Star Criteria

More policy news – it’s always good to know what’s going on, as it affects everything we do, and lighting is no exception.  Just recently, on March 27, the United State Congress told the Environmental Proetction Agency to dump their Energy Star criteria – you might remember that the EPA and the Department of Energy were having some disagreements as to what the Energy Star standards should be, and the government was trying to pass some legislation telling them what it should be.  The DoE and the EPA told Congress that they could figure this out amongst themselves without having to pass some legislation, but Congress told the EPA that the DoE should be administering the Energy Star standards for solid-state lighting.  I’m interested in hearing what the EPA has to say to Congress.

I would really, really like to know what readers think.  Please post your opinions in the comments.

Here’s the text of the letter:

Congress of the United States
Washington, DC 20515
March 27, 2009

Administrator Lisa Jackson
Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460

Dear Administrator Jackson,

We are writing to urge you to quickly bring to resolution the ongoing conflict between the Environmental Protection Agency and the Department of Energy regarding Energy Star criteria for residential solid-state lighting (SSL) products, commonly referred to as “LED lighting,” by rescinding the EPA Energy Star criteria for SSL as soon as possible.

We recognize and appreciate the EPA’s longstanding leadership in the Energy Star program, and we understand that the Agency’s SSL criteria were developed with intent consistent with the Energy Star mission. However, the current state of affairs, in which two federal agencies have put forth two separate standards, is untenable. The overlapping standards are creating uncertainty in the industry [and the] resulting confusion is threatening American leadership in this growing industry and could erode the integrity of the Energy Star brand if allowed to continue.

The future of the SSL industry is very promising. The market for high-brightness LEDs used in lighting was $205 million in 2006, and projected to grow to approximately $1 billion by 2011. The United States currently enjoys a leadership position in this industry. Because Energy Star certification is a vital step in the commercialization of any new energy efficient technology, a single agency must ultimately take the lead so as not to undermine the SSL industry at a critical point in its development.

We have come to the conclusion that the DOE should administer the Energy Star program for SSL based on our interpretation of section 912(b) of the Energy Policy Act of 2005 and input from experts in the SSL industry. We understand the past precedent with the respect to the division of responsibility between DOE and EPA and a justifiable interpretation of relevant legislation led the Agency to develop Energy Star criteria for SSL. We hope that report language accompanying the FY2009 Omnibus Appropriations Act provides sufficient clarification as to the intent of Congress in this matter.

The EPA and the Energy Star program have played an invaluable role in making America more energy efficient, and will continue [to] serve an important function in our Nation’s efforts to achieve energy independence, reduce greenhouse gas emissions, and create good jobs for Americans. In interest of preserving the integrity of the Energy Star brand and supporting American leadership in the SSL industry, we urge you to defer to the DOE’s SSL Energy Star criteria.

Sincerely,

Jay Inslee (Member of Congress, D-WA)
Andre Carson (Member of Congress, D-IN)
Russ Carnahan (Member of Congress, D-MO)
Jim Himes (Member of Congress, D-CT)
Mike Honda (Member of Congress, D-CA)
Jerry Moran (Member of Congress, R-KS)
David Price (Member of Congress, D-NC)
Betty Sutton (Member of Congress, D-OH)
Paul Tonko (Member of Congress, D-NY)

cc: Steven Chu, Secretary of Energy
cc: Nancy Sutley, Council on Environmental Quality

Energy Star: EPA and DoE VS. US Senate

Right now, the Department of Energy and the Environmental Protection Agency are trying to convince the Senate that they can work out the details of the Energy Star program without legislative help.  The Senate has some members who want to go ahead an legislate the Energy Star program and decide what the standards are, regardless of what the two agencies decide. The Obama administration says that the Senate should take out some pending legislation that says the DoE and the EPA have to cooperate in a revised agreement for the Energy Star program. The EPA and the DoE have 45 days or so to get written dispute resolution to the Senate Energy and Natural Resources Committee.

Some people are not happy about this – about the legislation, that is:

Some witnesses at the hearings discussed problems they have encountered with Energy Star, a labeling program launched by EPA in 1992 to help consumers identify the most efficient products.

Kyle Pitsor of the National Electrical Manufacturers Association said there has been confusion in the lighting industry because of competing EPA and DOE programs that address solid state lighting technologies that can provide major energy savings.

Pitsor, the group’s vice president of government relations, said the first DOE specifications for solid-state lighting products were finalized in March of last year. But he said that last year EPA’s Energy Star program also began addressing light fixtures that use solid state lighting. “Companies are investing and making decisions on new LED lighting and … conflicting Energy Star programs will impede acceptance of this developing lighting technology,” he said, and recommended Energy Star programs for solid state lighting be under DOE only.

This is important.  If you’re affected by the potential outcomes either way by this, please post in the comments.

epa-doe

Check out the original article at the NYT.