1 year earlier than required by the federal program. Although Nevada has declined to exercise this option, the California Energy Commission adopted regulations implementing the federal standards 1 year earlier, so the standards shown in Table 2.1 above are being implemented 1 year earlier in California, which started in January 2011.

Some states, such as Texas and South Carolina, have adopted or proposed legislation exempting any lamps manufactured entirely within that state from the federal EISA 2007 requirements.7 However, it is unlikely that any lamps and all their components are or will be manufactured entirely in a single state, and, thus, these state bills (which have also been introduced but not passed in other states) have more symbolic than practical effect.

In California, which has begun to implement the requirements 1 year in advance of the rest of the United States, no significant opposition or problems have been encountered by the initial implementation of the EISA 2007 requirements.

FINDING: The EISA 2007 requirements for phasing out inefficient lighting have sparked significant resistance by some legislators, states, and citizens in advance of the implementations of the requirements.


Model Building Codes

In addition to the regulation of the energy efficiency of individual lighting products by federal and state laws (discussed above), lighting energy use in the United States is also regulated by state-administered building codes that govern the installed power and/or energy use of lighting installations in new construction projects and major renovations that require a building permit. In particular, the American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) and the International Code Council (ICC) both publish “model energy codes” for states to adopt. ASHRAE has two minimum codes applicable to new construction: Standard 90.1 for commercial and industrial buildings and Standard 90.2 for residential buildings. The ICC develops the International Energy Conservation Code (IECC) that covers both residential and non-residential requirements. In addition, some states—especially California, Oregon, and Washington—have a history of developing their own codes. At the highest level, all of these codes approach the issue in a similar way—by setting a maximum allowed installed lighting power density (LPD) and prescribing the minimum lighting controls that must be used in commercial and industrial buildings. LPD refers to the spatial average power consumption of the installed luminaires in a building or in a space and is expressed in units of watts per square feet of floor area (W/ft2). In residential buildings, the maximum LPD is not typically standardized, but the minimum efficacy of lamps is often given, in addition to prescribing some requirements for lighting controls.

The LPD cannot be arbitrarily low. The Illuminating Engineering Society (IES) defines recommended illumination levels for a large variety of visual tasks, and building codes for commercial and industrial buildings take these recommendations into account. In order to reduce energy use and costs, the trend over the past decade has been for builders to lower the LPDs to the point that the International Association of Lighting Designers (IALD) has published a statement indicating that they do not support any further lowering of the LPDs beyond ASHRAE Standard 90.1-2010 (IALD, 2011). Additional lowering of lighting power densities would only be acceptable if the illumination levels remain unchanged, which requires an increase in efficacy of the light source. The position expressed by IALD is based on the performance of currently available technology, which is commonly used as a criterion for changes in building energy codes.

FINDING: Given the currently available lighting technologies, LPD allowances for commercial buildings have reached their practical lower limits, according to lighting professionals. In the long term, SSL may permit LPD allowances in building codes to be reduced further.

Siale Building Codes

Although states are required by federal law (EPACT 92) to either adopt the latest version of a model building energy code or develop one that is considered equivalent to such an energy code, there is no penalty for not complying with this requirement. As of late 2011, about half of the states have adopted a commercial building energy code corresponding to ASHRAE Standard 90.1-2007, and nearly the same number have adopted a residential model building code corresponding to 2009 IECC.8 However, the 2010 version of ASHRAE Standard 90.1 offers significant energy savings over its predecessor, as shown in determinations performed by PNNL. Large architectural engineering firms design buildings at least to the requirements of the latest standards. However many design-build contractors, who provide the bulk of the smaller buildings, typically minimize the initial cost of the building, resulting in lower performance. Furthermore, enforcement of building energy code requirements is sometimes inadequate or inconsistent at the state level. Even in California, where the energy code process is among the best in the nation, the California Energy Commission lacked enforcement authority until 2011, when the California


7 Texas HB 2510, 82(R) Sess. (2011) (signed into law June 17, 2011, effective January 1, 2012); H. 3735, South Carolina General Assembly, 119th Session, 2011-2012 (introduced February 11, 2011, pending in state senate at end of session).

8 However, states are not required to meet ASHRAE Standard 90.1-2007 until July 20, 2013, 2 years after DOE issued a final determination on 90.1-2007 and the 2009 International Energy Conservation Code. They are not required to comply with 90.1-2010 until October 19, 2013.

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