BILL ANALYSIS Ó
AB 213
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Date of Hearing: March 23, 2015
ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
Anthony Rendon, Chair
AB 213
(Ridley-Thomas) - As Introduced February 2, 2015
SUBJECT: Energy efficiency: light emitting diode (LED)
lighting products
SUMMARY: This bill prohibits the California Energy Commission
(CEC) from adopting a color rendering index (CRI) value greater
than the CRI value set forth in the United States Environmental
Protection Agency (US EPA) ENERGY STAR program, as of January 1,
2015, as a part of energy efficiency standards for lighting
products, unless the commission makes certain findings.
Specifically, this bill:
a)Establishes a definition for Light Emitting Diode (LED)
products.
b)Prohibits the CEC from adopting a CRI value greater than the
CRI index established in the US EPA's ENERGY STAR Program
unless peer reviewed studies demonstrate all of the following:
1) A CRI value greater than that required by the ENERGY
STAR program will increase the rate of consumer adoption
and produce greater sales of LED lighting products.
2) Energy efficiency gains from consumer adoption of LED
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lighting products using a CRI value greater than that
required by the ENERGY STAR program will exceed the energy
efficiency gains that would result from consumer adoption
of LED lighting products meeting the standards set forth in
the ENERGY STAR program.
3) Consumers are willing to pay an increased purchase price
for LED lighting products with a CRI value greater than
that required by the ENERGY STAR program.
4) Consumers are willing to pay higher electricity bills to
use lower efficiency LED lighting products with a CRI value
greater than that required by the ENERGY STAR program.
a)Specifies that the prohibition on adopting a higher CRI value
applies to voluntary agreements, the CEC appliance efficiency
standards, and the CEC building efficiency standards.
EXISTING LAW:
1)Requires the CEC to continuously carry out studies, technical
assessments, research projects, and data collection directed
to reducing wasteful, inefficient, unnecessary, or uneconomic
uses of energy, including improved appliance efficiency.
(Public Resources Code 25401)
2)Requires the CEC to adopt cost-effective energy and water
efficiency standards for appliances. (Public Resources Code
25402)
3)Prohibits the sale of new appliances that do not meet the
energy and water efficiency standards adopted by the CEC.
(Public Resources Code 25402(c)(2))
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FISCAL EFFECT: Unknown
COMMENTS:
1)Author's Comment. California has long been a leader in energy
efficiency regulations, setting Title 20 standards for various
appliances years before the federal government. The state's
Title 24 energy efficiency building regulations specify
requirements relating to lighting, insulation, windows,
heating, ventilation, and air conditioning (HVAC) systems, and
other construction details designed to reduce energy
consumption and lower energy bills for consumers.
Many peer-reviewed studies have found that cost is the
greatest barrier to LED adoption and mandates for higher CRI
lamps will further retard consumer use of the technology. The
average CRI 80 LED costs $10, whereas the average CRI 90 LED
costs $20.
Numerous programs administered by the state and local
governments and electric utilities in California, and
elsewhere, offer consumers incentives or rebates to purchase
LED bulbs and lighting devices.
CRI 90 LEDs are as much as 42 percent less efficient than CRI
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80 lamps because more energy is required to maintain the same
light output. The result is consumers pay more over the
lamp's lifetime than they would if they used a CRI 80 lamp.
2)What's a CRI? Different light bulbs emit different colors of
light. Lighting color ranges from cool to warm tones, and this
is called color temperature. Color temperature is not an
indicator of lamp heat. Color rendering index (CRI) is a
measure of how accurately an artificial light source displays
colors. CRI is determined by comparing the appearance of a
colored object under an artificial light source to its
appearance under incandescent light. The higher the CRI, the
better the artificial light source is at rendering colors
accurately. An incandescent bulb is the reference light source
and, as such, has a CRI of 100. High (above 80) CRI is
preferred in the home. ENERGY STAR requires that qualified
fixtures have lamps with CRI above 80.
3)What is ENERGYSTAR? ENERGY STAR is a U.S. Environmental
Protection Agency (EPA) voluntary program that has several
elements, one of which is a voluntary certification of
products that meet specified energy performance standards.
Manufacturers who voluntarily meet the requirements can offer
those products with an ENERGY STAR label. In order to earn the
label, ENERGY STAR products must be third-party certified
based on testing in EPA-recognized laboratories. In addition
to up-front testing, a percentage of all ENERGY STAR products
are subject to "off-the-shelf" verification testing each year.
The goal of this testing is to ensure that changes or
variations in the manufacturing process do not undermine a
product's qualification with ENERGY STAR requirements.
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The EPA periodically updates the requirements for certifying
products for ENERGY STAR label.
4)Not all LEDs are alike . According to the ENERGY STAR
website,<1> "after less than a year of use, a poorly designed
LED product can flicker, shift in color, look dim, offer
uneven light, or continue to use power when turned off, among
other problems. They caution that bad design can lead to a
wide range of problems, some immediately observable and some
not and that some poorly designed products come with
exaggerated claims while failing to deliver on the quality
specifications.
In 2012, the California Public Utilities Commission (PUC)
adopted a decision<2> that directed IOUs to only propose
rebates for general service screw base LED products that are
consistent with quality standards developed by the CEC.
5)CEC Voluntary Standard. In 2012 the CEC adopted a voluntary
LED standard requiring a CRI of 90 or above. At that time
Philips (a major lighting manufacturer) commented that a
higher CRI could lead to increased cost and worsening color
consistency. They also pointed out that their market studies
are showing that customers prefer the product with the lower
(80) CRI and expressed concern that a 90 CRI requirement would
result in a lower customer adoption rate. Rebuttal to these
arguments were offered by a Professor Lorne Whitehead, who
also served on the Board of the International Commission on
---------------------------
<1> https://www.energystar.gov/index.cfm?c=ssl.pr_why_es_com
<2> http://docs.cpuc.ca.gov/word_pdf/FINAL_DECISION/166830.pdf
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Illumination (CIE), who argued that Philips was wrong in these
assertions and that higher CRI will lead to less color
distortion and save energy.
6)CEC Proposed Mandatory Regulation. In September 2014, the CEC
issued a staff proposal to establish mandatory regulations of
LED bulbs in three ways: the efficiency, the CRI, and Color
Correlated Temperature (Color Correlated Temperature is a
measure of a light's "warmth"). Staff's proposal allows for
tradeoffs between one another, and proposed implementation is
in two tiers, with more stringent requirements in Tier 2. Each
tier is composed of a minimum compliance equation and bounding
conditions on how low efficiency and CRI can be. The staff
proposes Tier I standards to take effect January 1, 2017 and
Tier II standards to take effect January 1, 2019. The staff
proposal documents the potential energy savings, cost of
manufacturing, and net benefits to California customers.
The CEC regulatory process allows stakeholders to make
comments on regulatory proposals and offer suggestions on
changes to the proposed regulations.
7)Can you get a rebate for an LED bulb that uses more
electricity than a similar LED bulb? The PUC explains that the
IOU rebates offered for various LED bulbs are not necessarily
based solely on energy consumption (wattage). The rebates may
be based on a variety of factors, for example, ensuring
rebates are available for a range of different products with
different CRI indices because some customers may make their
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product choice on something other than price. This is to help
ensure that customer satisfaction with the product will lead
to greater market adoption.
8)Support/Opposition
Supporters assert the ENERGY STAR rated products are not only
adequate but that CRI 80 is preferred by the vast majority of
customers, especially if the red content of a CRI 90 lamp is
too high. They state that a high CRI limits the ability of
manufacturers to innovate and develop new products that
increase customer preference for LED lamps with improved
vividness. This will further slow the adoption rate in
California compared to other markets.
Opponents state that this bill could limit the CEC's ability
to adopt forward thinking energy savings standards in the
future and could have a chilling effect on innovation. Other
opponents point out that this bill would solve a problem that
does not yet exist, focuses on only a single metric related to
lighting performance, and ties California to a 2015 ENERGY
STAR standard, even though ENERGY STAR rating requirements are
updated every two years.
9)Double Referred. This bill is double referred to the Assembly
Committee on Natural Resources.
REGISTERED SUPPORT / OPPOSITION:
Support
American Federation of State, County and Municipal Employees
(AFSCME)
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General Electric
Osram Sylvania
Philips Lighting
Opposition
Natural Resources Defense Council (NRDC)
Pacific Gas and Electric (PG&E)
Sierra Club California
Analysis Prepared by:Sue Kateley / U. & C. / (916) 319-2083
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