Friday, Jan 30, 2015
By Tim Shotbolt MBldgSc LFIES RLP (Lighting designer)
I recently attended a Government industry-briefing, where some statements were made raising concerns in my mind about the "tools" / technologies we are left working with for the future. These statements were based on the document:
Product Profile - Incandescent, Halogen and Compact Fluorescent Lamps, 25 November 2014
By: © Commonwealth of Australia (Department of Industry) 2014.
This document is available at the Energy Rating website: http://www.energyrating.gov.au/wp-content/uploads/Energy_Rating_Documents/Product_Profiles/Lighting/Report_Incandescent-CFL-Product-Profile_25Nov2014.pdf
I write this as I am quite disappointed in what is being proposed and call upon fellow lighting professionals not to accept an unnecessary imposition when adequate energy performance restrictions are already in place in Section J6 of the BCA. If you also disagree with the proposed changes please voice your opinions via the links as indicated:
Feedback from industry stakeholders will be important in formulating the most appropriate policy approach, and responses to the Key Questions below will be of particular assistance.
Comments should be sent by email and be received by 13 February 2015. The subject should be clearly titled ‘Incandescent, Halogen and Compact Fluorescent Lamps Product Profile’ and sent to: EER-Lighting@industry.gov.au
Although I encourage you to read as much of the document as practical, three relevant sections from the document are cited here as follows:
6.4.7 AS 4934.2 Scope
Decorative carbon filament lamps (old-style tungsten; Figure 24) are currently omitted in the scope of AS 4934.2 and the GEMS determination. These inefficient lamps (and similar look-alike tungsten filament versions) have become popular in cafes and as a decorative feature light in the residential sector. Decorative LED lamps are becoming available that provide point source or filament style lines of light in clear bulbs. It should be considered if carbon filament lamps remain excluded from MEPS – note that many are 25 W and thus outside the MEPS scope of "> 25 W".
6.4.9 Sales of Halogen Lamps over CFLs
… the ongoing use of halogen lamps is a lost opportunity with respect to savings that could otherwise be made with a full transition to CFL and LED lamps.
8.4.4 AS 4934.2 Scope
Rough use lamps and carbon filament lamps are currently not within the scope of AS 4934.2. Halogen, CFL and/or LED alternatives for these lamps have become available. Many of the carbon filament lamps (and tungsten filament lamps of similar style) available are 25 W and are outside the current scope of MEPS which applies to candle, fancy round and decorative lamps.
15. Option: include rough use and carbon filament lamps in the scope of MEPS
16. Option: consider lowering or removing the current > 25W MEPS scope limit.
Although I am usually at the forefront in embracing new technology and absolutely recognise the need for drastic reduction of all of our "Carbon Footprints", it is my personal view that this is inappropriate and mindless driving of Watts to the exclusion of any other consideration.
At the Government presentation it was indicated that the "nostalgia" (i.e. carbon filament) lamps were a deliberate defiance of the Government’s efforts to limit power consumption and that this should be prevented by either including carbon filament within the AS 4934.2 and MEPS (thereby making it illegal) or by lowering the wattage limit of MEPS to much less than 25W thereby excluding the lamps and again making them illegal.
Lamps such as carbon filament have been around for decades and have rarely featured strongly in sales. At the moment it is a trend but the lamps are expensive and have a short life although they add that extra ambience to an interior. In time the trend will change as fashion does. This "Watts only" mentality exclusion is horrendous and we can all cite examples of past Green Star miserable working environment failures which achieved wonderful Wattage ratings.
Enough of the "Watts only" mentality focus.
If the proposed installation meets the energy limitations imposed by the BCA Section J6 using a mix of LED and carbon filament and the interior designer, architect or property owner likes the ambience of feature carbon filament lamps in the overall installation, then that is both responsible and appropriate design;
There is absolutely no defiance of Government contemplated or intended, simply design scope provided by professionals.
Both options 15 and 16 of item 8.4.4 above should therefore be completely rejected as inappropriate and unnecessary.
Note that halogens are also targeted (6.4.9) for removal with only LED and CFL to remain as legal options on a Wattage basis.
I repeat – and if you agree, I encourage you to write to the Department of Industry lodging your view as a design professional before the closing date (13 February 2015).
Make a difference in 2015 the International Year of Light.
Write to: EER-Lighting@industry.gov.au