BILL ANALYSIS Ó
AB 213
Page A
Date of Hearing: April 13, 2015
ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
Anthony Rendon, Chair
AB 213
Ridley-Thomas - As Amended April 6, 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 a part of
energy efficiency standards for lighting products, unless the
commission makes certain findings. Specifically, this bill:
a)Establishes a definition for 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 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
lighting products using a CRI value greater than that
required by the ENERGY STAR program will exceed the energy
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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))
FISCAL EFFECT: Unknown.
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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
80 lamps because more energy is required to maintain the same
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light output. The result is consumers pay more over the
lamp's lifetime than they would if they used a CRI 80 lamp.
2)Amendments made to AB 213. The author amended the bill that
was originally heard in this Committee. The amended bill
eliminates the restriction that would have tied the LED
standard to the January 2015 Energy Star standards. The
author also eliminated the requirement that studies specified
in this bill be peer reviewed.
3)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. 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.
4)What is ENERGYSTAR? ENERGY STAR is a US 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
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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.
The EPA periodically updates the requirements for certifying
products for ENERGY STAR label.
5)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 investor owned utilities
to only propose rebates for general service screw base LED
products that are consistent with quality standards developed
by the CEC.
6)CEC Voluntary Standard. In 2012 the CEC adopted a voluntary
---------------------------
<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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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
Illumination (CIE), who argued that Philips was wrong in these
assertions and that higher CRI will lead to less color
distortion and save energy.
7)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.
According to the CEC, CRI "is an imperfect color metric,
mainly because of potential inaccuracies with red colors. The
voluntary LED quality specification adds a requirement for
performance with red colors. The lighting world has been
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working for years on alternative color metrics but has not yet
reached consensus on an improvement to CRI. The front-runner
alternative is Color Quality Scale (CQS), developed by the
National Institute of Standards and Technology (NIST). When
an improved color metric is agreed to by the lighting
industry, CEC would analyze and consider it for recognition
and incorporation." Importantly, the CEC points out that a
NIST study found that "CQS provides scores consistent with the
CRI for most recent phosphor type LED products and traditional
discharge lamps." The CEC regulatory process allows
stakeholders to make comments on regulatory proposals and
offer suggestions on changes to the proposed regulations.
8)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 product choice on something other than price. This
is to help ensure that customer satisfaction with the product
will lead to greater market adoption.
9)Double referred. AB 213 is double referred to Natural
Resources.
REGISTERED SUPPORT / OPPOSITION:
Support
Los Angeles County Economic Development Corporation
AB 213
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Phillips Lighting
Opposition
None on file
Analysis Prepared by:Sue Kateley / U. & C. / (916) 319-2083