As I posted in March, the Emerging Technologies Program of the DOE’s Building Technologies Office asked for pubic comments on extending the minimum efficacy of incandescent lamps used in general illumination applications, specifically:
- Incandescent lamps that currently do not have a suitable replacement lamp meeting or exceeding 45 lumens per watt (lm/W).
- Gaps in technology that impede (or would likely impede) the design, development and future sale lamps of greater than or equal to 45 lm/W.
On May 13th the IALD published their response. The broad outline of their comments are that, first, the proposed rule to increase efficacy to a minimum of 45 lm/W is almost irrelevant because “the market is already addressing the issue of energy savings from lighting.” They go on to note that according to a recent Commercial Buildings Energy Consumption Survey, the use of electricity for lighting fell by 46% between 2003 and 2012. Second, there is little to be gained by requiring an increased efficacy for lamps that do not currently have a minimum due to the relatively low numbers of lamps involved. Third, the available technologies (primarily LEDs) do not adapt well to certain lamp types and exhibit a range of problems with dimming.
I support the IALD’s response. Quite frankly, with the low LPDs that are written into the various energy conservation codes, we’re already designing under very tight power budgets. The DOE’s proposal will have no effect on decreasing power consumption because it lags so far behind Standard 90.1 and the IECC.