BSR/RESNET/ICC 301-2014 Addendum G-20xx, draft PDS-01, Solid State Lighting Comments Submitted

The following comments have been submitted:

Comment #1

Page Number: draft amendment vs email lumens/watt
Comment Intent: Not an Objection
Comment Type: Editorial

Comment:

The email sent out to communicate regarding this amendment lists 60 and 90 lumens/watt, whereas the draft amendment lists 50 and 80 lumens/watt. I'm just making sure that the email language was incorrect, and the standard is accurate, or vice versa.

Comment #2

Page Number: 1
Paragraph / Figure / Table / Note: 3.2
Comment Intent: Objection
Comment Type: Technical

Comment:

Many light fixtures do not contain lamps or bulbs that are separable from the fixture, and thus cannot have their efficacy measured separately from the fixture.

Proposed Change:

3.2 Definitions 
Qualifying Tier II Light Fixture – A light fixture located in a Qualifying Light Fixture Location that contains lamps/light bulbs with an average luminous efficacy equal to or greater than 50 80 lumens/watt or an outdoor light fixture that is controlled by a photocell or an indoor fixture controlled by a motion sensor. 
Qualifying Tier I Light Fixture – A light fixture located in a Qualifying Light Fixture Location that contains lamps/light bulbs with an average luminous efficacy equal to or greater than 50 lumens/watt and less than 80 lumens/watt. For fixtures whose light source efficacy is not measurable separately from the fixture, the fixture efficacy shall be at least equal to or greater than 50 lumens/watt and less than 80 lumens/watt.
Qualifying Light Fixture Locations – For the purposes of rating, those light fixtures located in kitchens, dining rooms, living rooms, family rooms/dens, bathrooms, hallways, stairways, entrances, bedrooms, garage, utility rooms, home offices, and all outdoor fixtures mounted on a building or pole.  This excludes plug-in lamps, closets, unfinished basements, and landscape lighting.

Comment #3

Page Number: 1-2
Paragraph / Figure / Table / Note: whole document
Comment Intent: Objection
Comment Type: Technical

Comment:

The proposed change substitutes language from the working draft of ASHRAE 90.2. It is a good idea substantively in that it credits extra-high efficiency lighting. However, it could be better: the proposal establishes an arbitrary definition of extra-high efficiency that will be obsolete by 2020 or so, and the credit is quantized for no apparent reason, rather than continuous. It also fails to credit lighting controls that are just as effective at saving energy than efficacy improvements, and may enable future Demand Response savings as well.

This amendment is preferable for the substantive reasons noted above and for a key process reason: it uses language that has already been subject to ANSI public review without receiving any adverse comment; and it harmonizes with the expected language in ASHRAE 90.2-201x (which otherwise mostly harmonizes with RESNET 301). The language was originally developed and vetted by the Lighting Subcommittee of ASHRAE SSPC 90.2, which includes members with greater lighting expertise than is available on the RESNET SDC.

The concept behind this proposal is that:

  • Control credits are provided for controls above and beyond the normally-installed on-off switch based on utility studies of metered energy savings
  • The credit is based on the ratio of luminous efficacy observed by the rater compared to a base case of typical 2006 practice.
    • However, the credit cannot be larger than the reduction in installed wattage compared to a base case; thus
      • High-intensity use of efficient lighting such that lighting power density is not reduced is not credited; and
      • Credit can be given for efficient portable lighting that the rater can inspect, because the absence of inspectable lighting triggers a default to the reference house for that room.
Proposed Change:

The contents of the proposal are as follows: [note that a cleaner copy can be sent to the SDC on request].

  1. Delete sections 4.2.2.5.1.3 and .4 as their contents will migrate to Table 4.2.2 (1)
  2. Delete  section 4.2.2.5.2.2 and .3 as their contents will also migrate to Table 4.2.2(1)
  3. Add in definitions from ASHRAE 90.2 working draft as the SDC wishes
  4. Add the following to Table 4.2.2 (1)

Table

Building Component

ERI Reference Home

Proposed

Home

[notes]

Internal gains from lighting

As specified below

The internal gains due to lighting shall be reduced by the difference between the standard reference design lighting energy use and the proposed design lighting energy use.

 

Internal Loads from lighting

As specified below

The internal gains due to lighting shall be reduced by the difference between the standard The internal gains due to lighting shall be reduced by the difference between the standard reference design lighting energy use and the proposed design lighting energy use.reference design lighting energy use and the proposed design lighting energy use.

 

 

 

 

 

c,d

For interior lighting, low

efficacy sources (< 45 lm/W) assumed to average 20 lumens per watt and only controlled with standard on/off toggle switches.

Choose wattage equal

to standard reference design or follow the procedures below.

 

For interior lighting:

 

Use the larger of:

We could choose to include ASHRAE informative Appendix H as an Appendix to standard 301. It is appended below

 

P
4.2.2(1) Specifications for the HERS Reference and Rated Homes

 

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Interior lighting

For interior lighting, assume 20 lumens per watt and only controlled by standard on/off  toggle switches.

Lighting power

density of 1.1 W/ft2

PP

 

 

Schedule for interior lighting: assume that the equivalent Full Load Hours Per Year

=414,000/CFA + 727

 

Annual Energy Use, interior=1.1 W/ft2xCFA x Full Load Hours/yr

2

 

CFA x Full Load Hours

Per Year (IP)

 

Interior = SI-11 W/m2

PP

x CFA x Full Load

Hours Per Year (SI)

 

 

 

 

CFA = conditioned floor area

Choose wattage equal to standard reference design or follow the procedures below:

 

For interior lighting

 

Use the larger of:

 

1) actual lighting power

 

or

 

2)1.1 W/ft2

PP                                                        P                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 P

divided by the ratio of the power- weighted efficacy of installed lighting compared to 20 lumens per watt x CFA

 

 

 

 

ER = Efficacy Ratio = (total lumens / total watts) / 20

 

See informative appendix H for detailed examples.

 

Using the same lighting schedule as in the Standard Reference Design: Annual Energy Use = wattage as calculated above x CFA x Full Load Hours Per Per Year( Per Year [Full Load Hours Per Year is same as in standard reference design]

 

Garage and Exterior

c,db,

 

 

Exterior Lighting Hours

Per Year = 365 x 2.6 =

950 hours per year

 

Annual Energy Use Exterior = (100 + 0.05 x CFA)W x 950 hours

The larger of:

 

1) Actual installed lighting power

 

OR

 

2) The wattage in the reference building

This changes the existing Section 4.2.2.5.2.3 by reducing the hours of use for garages because ASHRAE felt that the implied 1000 hours per year was unrealistic.

 

 

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  27. Interior = 1.1 W/ ftP       P                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   x
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  64. LightingP


 

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Garage and Exterior Lighitng

Exterior Lighting

 

Exterior lighting hours Per Year =365 x 2.6= 905 Hours per year

 

Annual energy use =(100+0.05 x CFA) x 950 hours/yr

 

 

 

 

 

 

Garage

 

Schedule for Garage Hours Per Year = 548 hours per year

 

Annual Energy Use

Garage = 100W x 548

= 54,800Wh = 54.8 kWh per year

The larger of:

 

1) Actual installed lighting power

 

OR

 

2) The wattage in the reference building divided by the ratio

of the power- weighted efficacy of installed lighting compared to 20 lumens per watt for exterior and 50 lumens per watt for garage lighting.

 

ER = Efficacy Ratio = (total lumens / total watts) / 20 or 50

 

 

b

Standard on/off toggle

switches

Occupancy sensor

control – 10%

credit

 

Dimmer lighting controls – 20% credit

 

Credit for multiple controls is determined multiplicatively.e

P

 

Alternatively, control credits in Table B-2 shall be permitted to be used. .

 

 

 

  1.  
  2. NOTES
  3.  
  4. 1)     Installed lighting means lighting that is visible upon inspection for compliance with this standard, and includes plug-in lighting as well as permanently installed lighting.
  5.  
  6. 2                                                                                                                                                                                                                                                  2
  7.   If there is no installed lighting in a living space, or less than .10 W/ftP       P                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               (1.1 W/mP       P) of lighting
  8. 2                                                                                                                                                  2

power in a living space, assume 1.1 W/ftP       P                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    (11 W/mP       P) for that room and 20 lumens per watt.

  1.  

 

3) If a space uses both occupancy/vacancy sensors and dimmers then credit is determined multiplicatively. For example, in a kitchen that uses both an occupancy sensor and dimmer, the control credit would be 1-(1.0 - 0.32) X (1.0 -0.40) = 59%.

 

 

Table B-2 Lighting Control Credits

  1.  

 

Room Type

Occupancy/Vacancy Sensor

Dimmer

Basement

7

6

Bathroom

19

19

Bedroom

11

20

Closet

7

0

Dining Room

5

22

Exterior

20

0

Garage

10

0

Hall

18

17

Kitchen

32

40

Laundry/Utility Room

6

0

Living/Family Room

18

60

Office

2

6

Other

4

6
  1.  
  2. Source: CEE Residential Lighting Market Characterization Jan. 2014.
  3.  
  4. B1.2.1 When calculating internal loads that result from interior lighting, the methods prescribed above shall be used in Section 4.2.2.5.2.2. of RESNET/ICC Standard 301 replacing
  5. Informative Appendix H: Step-by-step approach for calculating lighting
  6. energy using the performance path
  7. Prefatory notes:
  8. 1. This calculation is optional: the rater is allowed to default to the reference house wattage.
  9. 2. This presentation is intended to illustrate how a software application can guide the user to
  10. input as much information as he or she wants to collect and process it in the energy calculation
  11. software.
  12. If the builder wants to take credit for savings, it is best to do this room by room:
  13. Begin with the kitchen: the designer installs 120 lumens per watt in an overhead luminaire and an equal
  14. wattage of 60 lumens per watt of under-cabinet and over-cabinet lights. The average lumens per watt is
  15. 90 for the room. This is 4.5 times higher than the default of 20. The kitchen is 200 ftP
  16. 2
  17. P (19 mP
  18. 2
  19. P). Total
  20. wattage installed is 40 W, which is so low because the target illumination level was a little on the dim
  21. side.
  22. The wattage by criterion 2 is 200 ftP
  23. 2
  24. P*1.1 W/ ftP
  25. 2
  26. Por 220 W divided by the ratio 4.5, or 49 watts. Criterion 1
  27. gives 40 W. The input must be the higher of 40 or 49 watts, and the appropriate entry is 49 watts.
  28. The next step is the family room of 400 ftP
  29. 2
  30. P (37 mP
  31. 2
  32. P). The lighting all has an efficacy or 60 lumens per watt
  33. and consumes 150 watts. It uses a control with a credit of 10%. The ratio of efficacy is 3. The ratio
  34. method gives 400 ftP
  35. 2
  36. P * 1.1/3 or 147 W; with a 10% control credit the wattage is .9*147 or 132W. The
  37. actual installed wattage is 150 * .9 (control credit) or 135 W. The higher of criterion 1 and 2 is 135 W.
  38. The bedroom of 180 ftP
  39. 2
  40. Phas just one fixture with a 12 watt LED. This is below the threshold of 0.1 W/ ftP
  41. 2
  42. P
  43. so it defaults to 1.1 W/ ftP
  44. 2
  45. P. The assumption is that one LED will not provide sufficient lighting and the
  46. user will install additional lighting that the inspector cannot look at.
  47. The second bedroom of 200 ftP
  48. 2
  49. P is intended as a home office and has 150 W of linear fluorescent lighting
  50. at an efficacy of 100 lumens per watt. The ratio of efficacy is 5, so by criterion 2 the wattage is
  51. 200*1.1/5 or 44 watts. But using criterion 1 the actual wattage is 150 so that is what should be entered.
  52. In this case, the builder is being penalized for using such intense lighting but nevertheless gets some
  53. credit because 150 W is less than 220W (equals 200 ftP
  54. 2
  55. P *1.1 W/ ftP
  56. 2
  57. P).
  58. Other bedrooms and bathrooms are just too much work for the rater and he allows them to default to
  59. 1.1 W/ ftP
  60. 2
  61. P. But the builder is able to take credit for 220 W minus 49 W in the kitchen, 440W minus 135
  62. W in the family room, and 220 W minus 150 in the second bedroom. Assume the house has a CFA of
  63. 1800 ftP
  64. 2
  65. P; then the equivalent full load hours is 957, so the energy savings that is credited amounts to 522
  66. kWh per year of credit, plus a reduction in cooling load.
  67. BSR/ASHRAE/IES Standard 90.2-2007R a revision to ANSI/ASHRAE/IES Standard 90.2-2007 - Energy-Efficient Design
  68. of Low-Rise Residential Buildings
  69. First Public Review Draft
  70. If the rating wants to consider efficient lighting in other rooms, the savings credit can increase in parallel
  71. with the level of inspection and calculation effort.

Comment #4

Page Number: 1-2
Paragraph / Figure / Table / Note: 3.2
Comment Intent: Not an Objection
Comment Type: Technical

Comment:

Traditionally, lighting efficiency has been measured separately for lamps and for luminaires (fixtures). However, for many solid state lighting (SSL) products, including recessed downlight trim kits, the light source cannot be separated from the luminaire. RESNET standards have to-date focused on the “luminous efficacy” of the “lamp/light bulbs” and ignored the optical efficiency of the luminaire. A typical recessed downlight luminaire/fixture is only 50-60% efficient, meaning up to half of the light output is wasted. (Reference: http://www.cool.conservation-us.org/byorg/us-doe/recessed_downlight.pdf)

Where a SSL “lamp/light bulb” is used (most commonly an omnidirectional screw-in bulb) it makes sense to treat it the same as any other lamp/light bulb, as this draft does. However, because the light source in many integrated SSL products is inseparable (i.e., the entire product must be replaced at end of life) we believe it would be more appropriate to compare that product’s “luminaire efficacy” to the system efficacy of a standard bulb in a recessed downlight fixture. In order to do this, we propose adding a new threshold of 65 lumens/watt that would be applicable to “integrated solid state lighting luminaires.” At that threshold, a qualifying luminaire would be equivalent to 100+ lumens/watt bulb in the typical recessed downlight.

Proposed Change:

3.2 Definitions

Qualifying Tier II Light Fixture – A light fixture located in a Qualifying Light Fixture Location that contains lamps/light bulbs with an average luminous efficacy equal to or greater than 80 lumens/watt; an integrated solid state lighting fixture with a luminaire efficacy of 65 lumens/watt; or an outdoor light fixture that is controlled by a photocell; or an indoor fixture controlled by a motion sensor.

Qualifying Tier I Light Fixture – A light fixture located in a Qualifying Light Fixture Location that contains lamps/light bulbs with an average luminous efficacy equal to or greater than 50 lumens/watt and less than 80 lumens/watt.

Qualifying Light Fixture Locations – For the purposes of rating, those light fixtures located in kitchens, dining rooms, living rooms, family rooms/dens, bathrooms, hallways, stairways, entrances, bedrooms, garage, utility rooms, home offices, and all outdoor fixtures mounted on a building or pole. This excludes plug-in lamps, closets, unfinished basements, and landscape lighting.