BSR/RESNET/ICC 301-2014 Addendum G-021x, draft PDS-02, Solid State Lighting Comments Submitted

The following comments have been submitted:

Comment #1

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


The Standards Committee of the North East Home Energy Rating Alliance, which represents more than 350 Raters and 11 Providers, offers the following comments and suggested edits.

The premise of this change on its face value appears to be benign. However, the notion that such detailed technical requirements for lighting, luminaires, lamps, et al., find their way into the Rating Standards is worrisome. In the interest of making the standards, with regard to lighting, simple and verifiable for the rank and file HERS Rater and QA Provider, we feel a simple definition is best. The overall goal is to increase the consistency and accuracy of ratings, however, this item is only as good as the software inputs available for HERS Ratings. Therefore, the rationale to simplify this is as follows:

  • HERS Raters and builders may not be familiar with the terminology.
  • Most Electrical sub-contractors and distributors do not commonly use this language.
  • Construction drawings for residential projects consisting of 1-4 units rarely if ever have a luminaire schedule let alone a lamp schedule on the drawings. Lamp wattage, if mentioned at all, is referenced in a general note at best.
  • Lamp and luminaire efficacy is not something that is verifiable on the jobsite.
  • Many solid state light fixtures have data imprinted on a label that is not readily accessible once the fixture is installed. In some instances, removal of the fixture would be required to access data. The packaging for such fixtures does not have data needed to determine efficacy- typically only a model number.
  • Given the simplified inputs in rating software which require a percentage of lighting of one type or another, a general categorization by lamp type should be all that is required.
  • We are doubtful that builders will find value in having HERS Raters spend an inordinate amount of time calculating lamp & luminaire efficacy, nor will many if any builders spend the time on their own to do this. They will also not likely pay for the required effort

Therefore we propose a simple language that categorizes lamps & luminaires by type, that are easily identifiable and therefore easy to input into Rating software:

Proposed Change:

3.2 Definitions

Qualifying Tier II Light Fixtures - – A light fixture located in a Qualifying Light Fixture Location that contains LED lamps/light bulbs with an average luminous efficacy equal to or greater than 80 lumens/Watt; an integrated solid state lighting fixture, whose light source efficacy is not measurable separately from the 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 Compact Florescent (CFL) lamps/light bulbs with an average luminous efficacy of greater than 50 Lumens/Watt and less than 80 Lumens/Watt. and all other lamps/light bulbs excluding incandescent and metal halide.