The U.S. Department of Energy (DOE) has put forward efficiency regulations on 4- and 8-ft. linear fluorescent lamps and halogen PAR lamps and is accepting comments for the near future (60 days after the publication of the regulations in the Federal Register, and as of February 6, 2009, this apparently has not happened yet, according to the DOE website). The proposed regulations are expected to eliminate most 4- and 8-ft. T12 lamps and current halogen PAR lamps, leaving only some shapes of high-efficiency halogen IR lamps.
Halogen IR lamp technology uses an infrared reflective coating on the tungsten halogen capsule, which refocuses waste heat back onto the filament, resulting in higher light output without higher lamp wattage. Image courtesy of Sylvania.
A copy of the proposed regulation can be downloaded here.
Soon after the IES Legislative and Regulatory Committee announced that the proposed regulations were available for public comment, lighting designer Howard Brandston responded to DOE and asked me to publish his letter as an open letter to DOE. This letter is below.
To the U.S. Department of Energy:
This letter is a request to have you cease all work on regulating light source efficacy. If you continue in the direction you are taking, you will destroy the ability of those who practice lighting design to do good work. Further, you will accomplish little in the way of energy conservation. The potential regressive impact on the quality of work and living space habitability might, in fact, reduce productivity and indeed have a negative result.
Other areas of conservation would have the potential to yield greater reduction in energy usage and would not be seriously damaging the professional lighting designer’s ability to responsibly meet their client’s needs. One example would be to reduce the heating temperature in institutional types of work spaces with occupancy of 10 people or more. To ameliorate what some might feel is a chilly space, the government could issue a voucher to purchase a sweater and a piece of warming headgear. The fuel saved in heating tens of millions of square feet of office and other facilities would do more to promote energy conservation in a week than regulating lamp efficacy ever will.
This same program is proposing to outlaw and replace most incandescent lamps with compact fluorescent sources. The data being used to justify this is in error. Many papers have been published documenting this error, which in truth is a deception of the general public. I do not believe that this ‘deception’ is fully understood by those engaged in promulgating this misinformation.
I am a firm believer in energy conservation and have served on committees to further that end. I wrote the mathematical equation that was used in the first ASHRAE.IES Standard 90.1 to set the upper power limit for lighting in that first energy document. That Standard has also become too stringent in my opinion.
Where does this “opinion” come from? It comes from over 50 years of lighting design practice. I am a Past President of the IESNA and the founding partner of the Brandston Partnership, a firm with over 3000 projects in about 60 countries. I am now retired but still active in the lighting industry. Please visit my personal web site www.concerninglight.com for a more detailed perspective in what I have accomplished.
The DOE has certainly made some remarkable strides. Please do not tarnish that record by continuing to follow this particular direction. Please feel free to contact me to discuss this subject in more detail.
Respectfully submitted.
Howard M. Brandston, LC, FIES, Hon. FCIBSE, FIALD, PLDA, MSLL
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