minutes of the meeting -...
TRANSCRIPT
2nd Ad-Hoc Working Group (AHWG) meeting for the
revision of EU GPP criteria for the product group:
Road lighting and traffic signals.
Presentation and discussion of criteria proposals
relating to light pollution and product durability.
21 September 2017
Minutes of the meeting
Contents
Agenda ........................................................................................................................... 2
List of participants ......................................................................................................... 3
Light pollution criteria ................................................................................................... 4
RULO (Ratio of Upward Light Output) criteria (TS7) ................................................ 4
Ecological light pollution criteria (TS8) .................................................................... 6
Product durability criteria .............................................................................................. 8
Provision of instructions criteria (TS9) ...................................................................... 8
Waste recovery criteria (TS10 and CPC7) ................................................................. 8
Product lifetime criteria (TS11 and AC3) .................................................................. 9
Reparability criteria (TS12) ..................................................................................... 11
Ingress Protection criteria (TS13) ............................................................................ 12
Failure rate of control gear criteria (TS14) .............................................................. 12
Closing remarks and next steps.................................................................................... 12
Agenda
Time Agenda point
14:00 - 14:10 Connection and introductions.
14:10 – 14:20 RULO (Ratio of Upward Light Output) criteria.
14:20 – 14:35 Discussion about criteria proposal for RULO.
14:35 – 14:45 Ecological light pollution criteria.
14:45 – 15:05 Discussion about criteria proposal for ecological light pollution.
15:05 – 15:15 Provision of instructions criteria.
15:15 – 15:20 Discussion about criteria proposal for the provision of instructions.
15:20 – 15:30 Waste recovery criteria.
15:30 – 15:40 Discussion about criteria proposal for waste recovery.
15:50 – 16:00 Product lifetime criteria (e.g. warranty).
16:00 – 16:10 Discussion about criteria proposal for product lifetime criteria.
16:10 – 16:20 Reparability criteria. Upgradability?
16:20 – 16:30 Discussion about criteria proposal for reparability.
16:30 – 16:35 Ingress Protection criteria.
16:35 – 16:45 Discussion about criteria proposal for Ingress Protection.
16:45 – 16:50 Failure rate of control gear criteria.
16:50 – 16:55 Discussion about criteria proposal for control gear failure rate.
16:55 – 17:00 Closing remarks and next steps.
List of participants Surname Name Organisation Brunet Pierre ANPCEN
Donatello Shane DG JRC
Falchi Fabio ISTIL
Gama Caldas Miguel DG JRC
Giacomelli Andrea Loss of the Night Network
Hollan Jenik CzechGlobe, Global Change Research Institute
Horvath Christof Austrian Energy Agency
Kyba Christopher German Research Centre for Geosciences
Luth Richter Jessika International Institute for Industrial and
Environmental Economics
Mohar Andrej Dark Sky Slovenia
Pistochini Patrizia ENEA, ISPRA
Sanchez De Miguel Alejandro University of Exeter
Schappi Bernd Austrian Energy Agency
Scholand Michael EEB
Seraceni Matteo Gruppohera
Van Tichelen Paul VITO
Wachholz Carsten EEB
List of interested participants not able to attend
Surname Name Organisation Bara Salva Universidad de Santiago de Compostela
Bardenhagen Harald Licht und Natur e.V.
Baddiley Chris Retired astronomer
Degiorgis Enrico DG ENV
Lathuy Yanick Wegen en Veerker
Eelen Dirk
Diaz Castro Javier Instituto de Astrofisica de Canarias
Pagano Fabio Associazione nazionale produttori
illuminazione
Seraceni Matteo Gruppohera
Thorns Peter Thorn Lighting Ltd.
Horvath Christof Austrian Energy Agency
Light pollution criteria The JRC briefly introduced the importance of light pollution in terms of sky glow, glare,
annoyance and the potential adverse impact on nocturnal species.
RULO (Ratio of Upward Light Output) criteria (TS7)
The JRC presented the criteria proposal for a 0% RULO to be applied as a Technical
Specification in all cases except when there is a well-defined need for vertical
illumination in particular sub-areas of the road. The 0% should be verified by
laboratory testing of the luminaire and light source combination and the tilt angle of
the installed luminaire should match the tilt angle applied to generate the compliant
laboratory test data.
Stakeholder discussion:
It was asked if the 0% RULO criterion was intended to apply to ALL road lighting.
This point was raised because it was felt that, while 0% RULO is understandable for
M-class roads, it might not always be applicable to C and P class roads. This would
particularly be the case in areas where facial recognition for pedestrians is important.
Another possible distinction that could be used for RULO limits is that used by the
Italian authorities:
Road lighting.
Area lighting, roundabout, parking lot.
Pedestrian area, bike lane.
Green area lighting.
City centre with historic lantern.
One Italian stakeholder stated that they would of course prefer the EU GPP criteria to
distinguish roads in the same way as the Italian system but that a simple split between
M-class (0% RULO) and C/P-class roads (possibility for >0% RULO) would be fine
too.
It was asked if RULO was ever to be allowed to go >0%, how much should it be allowed
to go up to? It was claimed that it would be difficult to give any simple response because
the RULO is expressed as a percentage of light output. 1% of a 20W lamp is a lot less
than 1% of a 1000W lamp. Consequently it would be better to specify upward light
limits in terms of lumens instead of % light output in cases where RULO might be >0%.
The Italian GPP refers to limits for upward light in terms of lumens. The IESNA BUG
(Backlight-Uplight-Glare) rating system was mentioned. The IES TM-15-11 could be
used as a standard to look at upward light output either in terms of lumens or candelas.
It would be good to see the actual criteria set out in the Italian approach here for
reference.
Other stakeholders were against any allowance of RULO being >0% under any
circumstances. Already 0% is specified widely across Europe, why should GPP be less
ambitious? Put another way, why should a luminaire with upward light output be
accepted under GPP? The first few degrees of upward light are actually the worst in
terms of sky glow. It was added that upward light can often increase glare and in some
cases actually decrease facial recognition (which is one of the main arguments for
specifying vertical illumination in the first place). One suggestion was to have a
separate criterion dedicated to RULO and glare in cases where vertical lighting was
required.
It was claimed that dirt gathering on luminaires with upward light output can effectively
diffract even more light upwards – potentially increasing upward light by a factor of 10
(figures of 0.5% RULO when clean going to 5% RULO when dirty were quoted). It
was added that 0% RULO luminaires collect less dirt than those with >0% RULO.
However, when prompted for actual studies that would back up this claim, no suitable
references were mentioned. It was simply responded that this was such an obvious
phenomenon that it could be easily observed. Another stakeholder added that the
upward light diffraction by dirt on >0% RULO luminaires could be explained by basic
physics. The stakeholder was invited to provide these explanations in writing.
Other stakeholders against >0% RULO argued that reflectance off light poles would
increase actual RULO in the field. There is currently software available to measure
RULO in-situ but it is proprietary software and without knowing the ways it works in
detail, it is difficult to actually use it in a reliable way in order to allow researchers to
better understand the variables that actually control in-situ RULO. Not all upward light
is equal either. One stakeholder added that if there is any upward light, it should be
weighted based on its spectral distribution, with a higher weight given to lower
wavelength light (e.g. blue/violet) which creates more sky glow per unit light due to
greater scattering. Further written evidence to detail what exact weighting would be
proposed for spectral output in different defined wavelength ranges was requested. In-
situ measurements of 0% RULO can easily be made visually by simply observing the
luminaire from a point that is at least 1m above the luminaire.
One stakeholder wanted to go even further than 0% RULO by actually setting
requirements on flux code 3, at least for a comprehensive criterion [For information:
RULO refers to light at 90° to the horizontal while flux code 3 refers to light at 75.5°
to the horizontal]. The same stakeholder also proposed to replace RULO with RUL –adding that there is a significant difference between the two and that they should not be
confused with each other. RULO is the % of total light output of the lamp going
upwards whereas RUL is the % of light output of the luminaire going upwards. In any
given case, x% RULO will equate to more light that x% RUL because not all light from
the lamp exits the luminaire (indeed often 20-30% stays in the luminaire).
The stakeholder who proposed some allowance for upward light in certain cases re-
emphasised that they were not referring to M-class road lighting where luminaires may
be mounted on 8m high poles but instead in, for example, city centres where luminaires
may be mounted at 2m or 3m heights and where vertical illumination is desirable to
improve facial recognition. Basically, the lower the luminaire height, the harder it is to
get vertical illumination with 0% RULO. This could be easily demonstrated by basic
mathematical principles.
This prompted one stakeholder to claim that there were numerous examples of streets
in Paris with 0% RULO where facial recognition was not an issue. Other stakeholders
mentioned the problems with glare that had been observed when retrofitting LED into
2-3m high poles when the luminaire had >0% RULO. Apparently this issue has been
reported in a number of publications and the stakeholder was invited to share details of
these references. Another stakeholder added that they have taken many in-situ
measurements of glare using vehicle mounted Slovenian equipment that would support
these claims and is happy to share them. Many improvements in glare are still possible
simply by diffusing LED light better or using less power and aiming for lower light
levels. The main problem is that the only way to avoid the glare problems is to go to
0% RULO luminaires, but then in order to maintain the required vertical illumination,
it would be necessary to either install more poles at 2-3m height during the retrofitting
or to increase the height of the existing poles. Either way, it would increase the costs of
the retrofitting operation.
The discussion drifted towards the possible health effects of light entering people's
windows and affecting their sleep although such discussion was cut short by stating that
this is going beyond the intended scope of GPP criteria and entering into an area where
many subjective arguments exist and clear and consistent conclusions have not yet been
drawn.
It was proposed to have a sticker that states their RULO value. Overall, the majority of
stakeholders were against any allowance for luminaires being installed with >0%
RULO (or RUL).
Ecological light pollution criteria (TS8)
The JRC presented some key background research relating to the impact of different
wavelengths of light on different species, the energy efficiency penalty for shifting
towards lower CCT LED lighting and the apparent relationship between CCT and the
fraction of blue/violet light output in spectra. The final proposed criterion was a single
Technical Specification that should only be applied when the procurer thinks that road
lighting is a sensitive matter for nocturnal species or residents in the surrounding
areas. The core level criterion required mandatory dimming to 50% during curfew
hours and a CCT <3000K. The comprehensive level criterion required dimming to
30%, a CCT of <2700K and a proposed upper limit on the amount of blue light in the
spectral output (to be discussed).
Referring to the example spectral outputs of different light sources that was presented
at the webinar (and also in TR 2.0) one stakeholder added that he felt the spectra for the
HPS source was not as representative as it could be – he said he would send spectra that
reflect the full family of HPS, which can go up to 2500K for "white" HPS, to illustrate
his point.
When attempting to place restrictions on blue light output, there was a clear split in
opinions about how best to do this. Some stakeholders felt that CCT was a simple
measure, suitable for GPP, that showed a good enough correlation with blue light
spectral output (referring to graph published in the shared "Street Lighting and Blue
Light FAQ” document and also reproduced in TR 2.0). Others felt that it was not
scientifically valid enough and would not guarantee against, for example, any UV light
output. In terms of defining the light output to limit, one suggestion was to place a limit
on any light of wavelength <500nm.
The impact of upward blue light on sky glow is greater than other light due to its greater
scattering effect but stakeholders were asked if downward blue light was reflected more
or less than other wavelengths. One stakeholder referred to a study that demonstrated
that blue light reflected less from road surfaces than other wavelengths but that the
reduced reflection was not sufficient enough to compensate for the increased sky glow
caused by the higher scattering of blue light. Details of this study were requested.
One understudied impact was the potential effect of blue (and red) light on urban plants
exposed to road lighting. These wavelengths are sensitive to photosynthesis but any
criterion on CCT will not necessarily limit spectral output in these ranges.
The JRC asked if any criteria were to be taken forward for limiting blue light content
and how should this be specified? The options are as absolute output (e.g. W/lm) or as
a fraction of total light output (%). One response received was that % would be easier
to specify.
The discussion drifted towards the impact of blue light on human health, sleep patterns
and circadian rhythms although the JRC emphasised that this was not something that
the Commission was in a position to use as supporting rationale for any limitation of
blue light content in road lighting. It was a discussion that was much more relevant for
indoor lighting due to the much greater exposure there.
Stakeholders in support of CCT as a criterion added that the IDA (International Dark-
Sky Association) has a maximum 3000K limit. Phosphor Converted (PC) amber
lighting was promoted as the best way forward with LED because people are used to it
and will be less likely to complain and it is a proven way of reducing sky glow because
it has no blue light output. Support was expressed for an informative sticker to be placed
on the luminaire/light source stating the CCT.
One stakeholder added that anything >3000K would have an adverse impact on the
vision of elderly people due to glare because their visual receptors (1980 study) were
most sensitive to blue/violet light. Another aspect that had not been considered was that
amber light will tend to reduce the colour rendering index and that lowering the CCT
may also be an issue for colour blind people. It was responded that amber light can still
produce results of Ra of 60%.
One project in Italy was cited that apparently reduced light pollution by 70% by
replacing HPS lamps with 4000K and 3000K LED lamps in non-residential and
residential areas respectively. This prompted a number of doubts from other
stakeholders who claimed that the original HPS lamps and luminaires in place must
have been extremely poor in terms of light pollution. The same stakeholders claimed
that if amber-LED had been used instead of 4000K and 3000K LED then the light
pollution would have been reduced even further. One comment claimed that 1x 2700K
LED lamp would contribute the same light pollution as 2x amber-LED lamps with the
same lumen output. So there really is a motivation to go to lower CCT values. Another
optimised lighting solution was mentioned (reference made to a report by Baltic
Republics). The stakeholders were requested to provide further details of both the
original Italian case study and the claim about 2700K LED being two times more
polluting than amber. The following link was provided to support claims that 4000K
LED was contributed to light pollution a lot more than HPS.
While stakeholders were generally in favour of limiting the “blue light” output from
road lighting, there was no clear agreement about exactly how to do this. Some
stakeholders were for CCT, some were against CCT. Those against CCT were also
undecided about how exactly to define limits on “blue light” output although some
suggestions were made. Nonetheless, one valid point that should always be borne in
mind is that over-lighting is a much bigger issue than the colour of light.
Product durability criteria The JRC presented the general importance of product durability for road lighting
products, especially given the much longer lifetimes now possible with LED technology.
The importance of lifetime on LCA impacts and LCC as well as the direct relevance to
a circular economy philosophy were highlighted. A total of 6 criteria have been
proposed that aim to address product durability from different angles.
Provision of instructions criteria (TS9)
JRC presented a criterion proposal for instructions, emphasising that as more and
more electronics and controls are involved in lighting technology it is important to have
adequate instructions in place to troubleshoot, identify faults and be able to make
adequate repairs.
No stakeholder discussion directly related to the provision of instructions arose except
that one stakeholder felt that repair of LEDs was not a current reality and that
replacement of modules or drivers was the most that would perhaps be done and even
then, this would involve removing the entire luminaire and repairing it offsite and then
saving it by for use elsewhere. This same stakeholder opined that criteria directly
relating to product lifetime were far more important.
Waste recovery criteria (TS10 and CPC7)
The JRC presented a brief background to the issue of waste management in relation to
road lighting. A single Technical Specification (TS) was proposed where the tenderers
commit to taking any Waste Electrical and Electronic Equipment (WEEE) to
appropriate facilities for their further processing and potential recycling. The winning
tenderer would then be held to this commitment via a Contract Performance Clause
(CPC).
One stakeholder commented that appropriate collection of road lighting for WEEE
processing was already virtually 100% in Slovenia (shipped to Germany) and that
materials had been separated into Mercury-containing and Mercury-free streams.
Support was expressed for keeping the criterion as it may be useful in other Member
States where collection rates are lower. One key message given was that longer life
products produce less WEEE in the first place and that this is a greater environmental
benefit than simply collecting all the WEEE generated.
Some stakeholders questioned the WEEE statistics shown in the presentation (which
were from 2010). After the recast of the WEEE Directive, the ways targets are defined
can be one of two ways: either based on waste collection data or based on the quantity
of EEE sold during the last three years. In general collection rates for road lighting are
higher than for domestic lighting and indeed 100% should be the target for road lighting
since it is very much under the control of public authorities. Another stakeholder added
that the 2010 data presented for Spain (around 22%) are today more like 50%.
Stakeholders did not complain about the removal of the earlier (TR 1.0) proposal to
provide a Bill of Materials for critical raw materials. Even though technology is
available for recovering critical raw materials (CRMs) from WEEE, it is difficult to
recover consistently high volumes of CRMs and the market price is not consistently
high enough to make this economically viable.
When prompted about any possible EU GPP requirement to ban the procurement of
Mercury-containing lighting, stakeholders generally agreed that there was some
political momentum now with the recent entry into force of the Minimata Convention
(16 August 2017). Several governments are known to be considering maintaining the
RoHS exemption for Mercury in lighting and so the value of a specific ban in EU GPP
criteria would help highlight that Mercury should not be associated with the most
environmentally friendly lighting products on the market. It was confirmed that
Mercury is a particular challenge (and cost increase) when processing waste lighting
equipment and that today in Sweden all lighting equipment is processed together with
the assumption that it contains Mercury. With time it is anticipated that this will change
as HID lamps are gradually replaced by LEDs and those LEDs come to the end of their
lives. However, at the present moment, due to the real difficulty in distinguishing
Mercury-containing lamps from Mercury-free ones, better labelling of bulbs should be
implemented, for example via the symbol Hg inside a circle.
When asked about the hazardous metals and materials that may be present in LEDs
(which are Mercury-free) it was added that the main concerns were related to Arsenic
in Gallium arsenide semi-conductors and Lead in solders used in electronics. However,
it was emphasised that much was still not clear about the impacts of LED manufacture
in terms of releases of hazardous substances since most manufacturing is carried out in
Asia and LCA literature on this aspect of LEDs was scarce, especially relating to the
pre-industrial processing of these components. Any concerns with hazardous
substances in LED simply reinforce the importance of having longer life lighting
products in order to reduce the quantities of these materials entering the waste stream.
Product lifetime criteria (TS11 and AC3)
The JRC presented the criteria proposals for product lifetime criteria which were split
into a minimum LxBy requirement and a minimum warranty to cover repair,
replacement and the provision of spare parts. An additional Award Criterion (AC) was
provided to encourage extended warranties (up to a realistic point).
Extensive discussion took place regarding this criterion in particular with relation to
product durability. One stakeholder emphasised that when considering LED lighting,
durability has to be considered from 3 perspectives:
i. The electronics.
ii. The LED chips.
iii. The combination of i and ii in an actual road lighting luminaire.
With regards to the electronics, it is apparently easy to find good quality electronics
that will operate for 100000 hours (i.e. 25 years of road lighting). The lifetime of
electronics can be reduced by the use of cheaper (1-5 Euro savings) and lower quality
capacitors. The use of surge protectors (at a cost of 15-20 Euros) can effectively protect
and prolong the lifetime of electronics to 100000 hours. This stakeholder suggested that
separate specifications should be made for electronics and for LED modules.
With regards to LEDs, in addition to lower quality control in chip manufacture,
overheating in the luminaire can seriously shorten the expected lifetime. The potential
for overheating is directly related to the luminaire design and the adequacy of any heat
sinks and ventilation. One way to reduce the risk of overheating is simply to use
dimming or to use lower power light sources in a given luminaire. It was claimed that
a very low power LED could in theory last 100 years. It was also claimed that dimming
can prolong the lifetime of LED lighting by 2-3 times. Any evidence to support these
claims would be most welcome. The ambient temperature can also be an issue, the same
LED and luminaire in Sweden would last a lot longer than if it was in southern Italy.
This was strongly disputed by another stakeholder, who added that road lighting
operates at night-time, when ambient temperatures are cooler and differences not
significant enough to have a major effect on overheating. However, the actual influence
of overheating in the luminaire, when it does happen, was not disputed. There is a need
to ask the industry, for example Osram, Phillips etc. about 100000 hour LxBy
predictions for LED lighting (presumably in order to match it to the lifetime of
electronics). Some procurers are currently requesting 100000 hour LxBy performances
and 10 year warranties.
The proposed LxBy criteria were as follows:
Core: L92B50 @16000 hours and L80B10 @60000 hours
Comp.: L92B50 @16000 hours and L90B10 @60000hours
Several stakeholders had comments about the specific LxBy requirements. One
stakeholder pointed out the B requirements should be the other way around that the B
number (% of individual modules failing) should get higher as time passes instead of
lower. Another stated that any warranty should be linked to the Lx factor and not
necessarily the By factor because it is not practical to check that part and that the most
important point is Lx, which is the actual lumen output. Another stakeholder wanted to
go a step further and not make any minimum requirement for By at all in the EU GPP
criteria. However, this was countered by comments saying that the By factor is a
measure of quality control and will also have an influence on what Lx is actually
realistically achievable.
It was asked why the EU GPP criteria do not try to follow industry convention which
defines the end of useful LED lifetime as when it reaches L70 (i.e. lumen output
depreciates by 30%). Another stakeholder added that they would have no problem
letting the lumen output depreciate to L50 if it means significantly extending the life of
the lighting product.
One comment was that the warranty and the LxBy were seen as double requirements
of the same thing. JRC responded by saying that while the LxBy requirement relates to
some sort of quality and performance check on the lighting to be procured if the tenderer
is successful – there was no actual guarantee that the lighting which will be purchased
in the end will actually meet that performance. The warranty is providing the procurer
with some sort of guarantee of performance.
Regarding test methods, LM80 and TM 21 were mentioned as a suitable combination
and it was clarified that the LM80 procedure does not involve testing for 16000 or
60000 hours but is instead for 6000 hours (maximum 10000) and then the TM21
method takes the LM80 data and applies pre-determined depreciation curves that were
developed based on steady state temperature measurements taken on lots of different
LED modules when in operation under controlled laboratory conditions.
One stakeholder wished to bring up the example of Madrid, which was procuring LED
lighting and running it at 60% of maximum light output - then increasing power to
account for lumen depreciation when needed. The same stakeholder then added that
road lighting was being replaced every 5 years in Madrid. JRC responded by saying
that this was potentially a huge waste of money (either in capital costs, operating costs
or both) and leading to the generation of large amounts of unnecessary WEEE. One of
the purposes of EU GPP criteria is to precisely avoid this type of practice. It seemed
contradictory that over-specified LED lighting in Madrid would be dimmed (which
would prolong its lifetime) only for the lighting to be replaced 5 years later regardless
of performance.
One issue that was raised, and which is a particular concern, is that there is a perceived
intention of the lighting industry to shift away from the most durable LED lighting
products and towards products with a planned obsolescence in order to ensure more
frequent sales. This would simply increase the importance of any minimum
requirements on LxBy and product warranty in EU GPP criteria. A 10 year warranty
was suggested as a minimum to guard against the possible procurement of less durable
lighting products.
Reparability criteria (TS12)
JRC briefly presented the arguments for a criterion relating to reparability and
especially relating to the drivers, which were due to some 73% of all LED failures and
caused by irregularities with the power supply (e.g. power surges, capacitor failure
etc.).
One stakeholder mentioned that LED repair was not common practice today. At the
most the driver could be replaced but that any attempts to repair and replace LED
modules in-situ was simply too complex to do onsite.
Another issue raised was the reparability of faults that were due to software failure or
incompatibility that could render hardware in a good condition as useless. JRC
responded that this was a good point and that stakeholders should try to gather real
examples of concerns and possible issues that are related to software. Could EU GPP
set some requirements on freely available software or software functionality that is
directly or indirectly linked to a warranty?
When prompted about possible requirements relating to upgradeability, no feedback
was received except that traditional luminaire lifetimes are very long (up to 50 years)
and that traditional light sources were well standardised to fit into those luminaires on
a like for like basis every 4-8 years. Now with the rapid evolution in LED-lighting
technology and optics of the housing, it is much more difficult to predict if it is
worthwhile to have luminaires that are capable of being upgraded or if a bespoke
luminaire is required after a 20 year old LED light source reaches the end of its life.
Upgradeability was considered as unrealistic and impractical with LED road lighting.
First the LED-lighting market will need to become more standardised. Of relevance
today, the retrofitting of LEDs into HID luminaires was not considered such a good
idea – largely due to the same reasons mentioned above.
Ingress Protection criteria (TS13)
JRC very briefly presented the proposal for IP rating requirements for EU GPP road
lighting. The proposal allowed for IP55, IP65 or IP66 depending on local
circumstances.
The only stakeholder feedback received relating to this criterion was that a minimum
IP rating of 66 could easily be specified and would help ensure product durability. No
information on possible cost premiums for improving the IP rating was provided, but it
would be very useful to have this if anyone can find cost data.
Failure rate of control gear criteria (TS14)
JRC very briefly presented the proposal for control gear failure rate requirements for
EU GPP road lighting.
One stakeholder felt that a more appropriate approach would be to have a 10 year
warranty on all control gear and a lifetime expectancy of 100000 hours for at least 80%
of the control gear equipment supplied. JRC asks if there is any standard methodology
that could be applied to demonstrate such claims and how meaningful the 100000 hour
life expectancy rate is if the warranty is only for 10 years.
Another stakeholder highlighted the need to make sure that poor performance due to
poor installation is also covered by EU GPP criteria. An example of a 4% failure rate
of a lighting contract was specified (obviously due to installation issues). The JRC
pointed out that there are a number of CPCs that may be relevant to this matter and that
stakeholders should check the TR 2.0 and add any relevant comments there.
Closing remarks and next steps JRC thanked the participants for their input and urged them to submit their comments
in writing using the html version of the TR 2.0 that is available on BATIS. Any
stakeholders not registered on BATIS will be invited to do so. Comments need to be
submitted by the 21st October 2017.
The comments will then be taken into account a new TR published by the end of
January. Following publication, there will be a 6 week written consultation during
which stakeholders can submit their written comments.
The European Commission’s science and knowledge service
Joint Research Centre
EU GPP criteria for road
lighting and traffic signals
2nd Ad-Hoc Working Group meeting to present
and discuss latest criteria proposals
September 2017
Shane Donatello
2
The Joint Research Centre
at a glance
3000 staff Almost 75% are scientists and researchers. Headquarters in Brussels and research facilities located in 5 Member States.
3
Sustainable Product Policy at the JRC
No.
of pro
ducts
Product "environmental performance" (e.g. emissions, energy consumption,
hazardous substances, recycled content etc.).
worst best
4
Sustainable Product Policy at the JRC
No.
of pro
ducts
Product "environmental performance" (e.g. emissions, energy consumption,
hazardous substances, recycled content etc.).
worst best
Eco-design
BREF / BAT
EU Ecolabel
EU GPP
Energy labelling
20+ EU GPP Criteria
Sanitary tapware
EEE Health care sector
Combined Heat & Power
Flushing Toilets & Urinals
Wall panels
Imaging Equipment
Waste water infrastructures
Street lighting and traffic signals
Indoor lighting
Water based heaters
Roads
See all here: http://ec.europa.eu/environment/gpp/eu_gpp_criteria_en.htm
6
Project stages and progress
We are here
7
Structure of presentation
1. Light pollution (2 criteria).
• RULO
• Ecological light pollution
2. Product lifetime (6 criteria).
• Instructions
• Waste recovery
• Product lifetime (warranty)
• Reparability
• Ingress Protection
• Control gear failure rate
• Discussion session after each criteria.
• Please keep discussion concise and on topic.
• Follow up with written comments on html file on BATIS.
8
Why is light pollution important?-1
• Not natural.
• Disrupts observation of night sky.
• Adversely affects nocturnal species.
https://www.pinterest.com/pin/90212798757716447/
http://www.warrenphotographic.co.uk/03421-geese-flying-past-the-moon
https://www.pinterest.com/pin/276408495857029812/
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Why is light pollution important?-2
• A European wide issue.
• But, can be quickly remedied!!
• Light pollution from space
• Parts of UK, PT, ES, FR, IT
• Most of BE, NL and SL
• Why such differences?
• Link to population density..
• Link to road density…
10
Why is light pollution important?-3
• Impacts on humans.
• Upward light sky glow.
• Upward light = wasted energy!
• Upward reflected light sky
glow.
• Glare discomfort
• Light trespass annoyance.
• Discomfort/annoyance are quite
subjective and vary frequently.
• How to appropriately handle
with EU GPP criteria?
11
Ratio of Upward Light Output (RULO)-1
• 0% RULO easily achievable.
• Especially with LED.
• Light source and luminaire tested
together in laboratory.
• Then simply a case of installing
correctly.
• Green parts are where GPP comes in.
• Fits well with any PDI and AECI indicator. http://cescos.fau.edu/observatory/lightpol-prevent.html
12
Ratio of Upward Light Output (RULO)-2
• Is 0% RULO good enough alone?
• Should we consider flux codes?
• E.g. (FCL) CIE 30 40 50 100 65
• Or are installation specs better?
• E.g. tilting and boom angles?
65 is the light out as a % of total light produced
30 is the % light out falling within 41.4°
40 is the % light out falling within 60°
50 is the % light out falling within 75.5°
100 is the % light out falling within 90° (i.e. 0% RULO)
13
Ratio of Upward Light Output (RULO)-criteria
Key points:
• A single TS specifies 0%
• Test standards mentioned.
Discussion points:
• CPC needed?
• Flux codes useful?
• Need for different approaches
in different situations?
• Minimum utilance approach?
14
Ecological light pollution-1
• All about adverse effects on species (incl. humans…?).
• Some clear effects shown in specific situations.
• Lot more research still needed…
• FR conclusion:
• i.e. amber light please…
Melatonin suppression etc. out of
scope due to exposure rates –
much more of an indoor issue
15
Ecological light pollution-2
• 1st webinar
complaints about
luminous efficacy req.
• Perceived discrimination
against amber LED
• Not strictly true
(although maybe goes
against low power LED).
• Graph shows 3lm/W decrease as CCT drops 1000K for LED • i.e. pretty modest decrease.
• Covers the range 6000K 3000K
16
Ecological light pollution-3
• LED is good for energy efficiency, durability, light direction…
• Most complaints have been with “white” light…(i.e. blue light).
• HPS lamps little blue light
• LPS lamps no blue light
• MH lamps lot of blue light
• LED lamps depends……
17
Ecological light pollution-4
• Blue light from LEDs depends on spectral output.
• Correlated Colour Temperature (CCT) correlation with blue light?
• Seems reasonable.
• Seems procurer friendly.
• But some objections.
• So why not call a spade a
spade and specify light sources that are low in blue light spectral output?
Source??
18
Ecological light pollution-criteria proposal
Key points:
• Nuanced for areas of concern i.e. procurer decides.
• When relevant, go for a “belt and braces approach”. • i.e. core: dimming + CCT <3000K
• i.e. comp.: dimming + CCT <2700K + blue light max. output.
Discussion points:
• Test methods for CCT and spectral output?
• Ease of assessing and verifying spectral output? How to do exactly?
• How to best define a limit on spectral output? • i.e. absolute (µW/lm) or % of total output
• Blue light or violet/blue light? • Need fixed wavelength ranges for consistency.
19
Product lifetime criteria-1
Why is product lifetime important?
• LCA impacts: • Use phase is dominant from LCA perspective.
• But LED higher manufacturing impact.
• As efficiency increases…
• ….manufacturing becomes more significant
• Costs: • Save on capital costs for lamp replacement
• Save on labour costs for lamp replacement
6% 28%
20
Product lifetime criteria-2
Why is product lifetime important?
• Circular economy principles:
i.e. reduce this
By reducing this
21
Product lifetime criteria-3
Why is product lifetime important?
• Direct link to circular economy
• Traditional road lighting scenario
• Probable future lighting scenario
• Can avoid the need for 4 lamps in 20 years…
+
https://www.shutterstock.com/image-vector/led-light-bulbs-e27-base-vector-572630305?src=5hSKSvrvYAlw_Kjjm2LzDw-1-43
+ +
+ clean
+
+ clean
+
+ clean
+
+ clean
+
+ clean
0yrs 4yrs 8yrs 12yrs 16yrs 20yrs
+ +
+ clean
+ clean
+ clean
+ clean
+
+ clean
22
Product lifetime criteria-4
Why is product lifetime important?
• Commission is strongly promoting circular economy principles: • Durable products
• Ease of disassembly
• Repair
• Remanufacturing
• Upgradeability?
• Link to waste management and recycling rates.
• Link to non-toxic material cycles.
• GPP expected to play a BIG ROLE.
Locked in at product design stage
23
Provision of instructions-1
Why important?
• Never been more important! • Rapidly evolving LED technologies.
• Dimming controls, CLO drivers, traffic sensors, remote data…
• More complex electronics.
• More things that can go wrong!
• Greater need for clear instructions for maintenance workers.
• Need for instructions only exacerbated by longer life LED lamps.
• But depends on nature of contract (product/works/service)?
24
Provision of instructions criteria proposal
Key points:
• A single TS.
• Tries to cover the most important aspects: • Disassembly instructions.
• Replacement of light sources and lamps.
• O+M of lighting controls, including calibration where relevant.
Discussion points:
• Opinions?
• Any important aspects for instructions missing?
25
Waste recovery-1
Why important?
• In 2010:
• Need to improve in general, road lamps should be 100% collected!
• Traditional HID lamps may contain Mercury hazardous waste…. • LED may contain Arsenic….others?
26
Waste recovery criteria proposal
Key points:
• A single TS to commit to taking any waste WEEE to designated sites.
• Requirement for BoM removed negative stakeholder reaction.
• A CPC to ensure that this commitment is honoured.
Discussion points:
• What is current normal/best practice?
• Are LEDs considered hazardous waste?
• Potential for recycling materials in lamps and luminaires?
• What do you think about criteria to exclude Hg containing lamps? • Unique challenge of handling Hg (volatility)
• Political momentum (recent Minimata convention)
http://www.mercuryconvention.org/
27
Product lifetime-1
Why important?
• LED lasts longer than HID…..?
• Not all LEDs are born equal…. • Quality control on chips:
• "Reject batches" still too good to throw away.
• End up in lower end (and cheaper) LED lighting products.
• How to ensure good quality product? • ENEC+ mark?
• Warranty claims!
• What are the pass/fail boundaries to set with a warranty?
28
Product lifetime-2
Lumen maintenance • The core job of any light
source….
• Big advantage of LEDs is the
tendency to avoid abrupt failure.
• Ignoring failures in control gear
abrupt failure…
• Where is end of life for LED
considered then?
• Generally at 70% of maximum
lumen output.
• Example shows L70 at 54000h
http://www.ledsmagazine.com/articles/2012/11/the-elusive-life-of-leds-how-tm-21-contributes-to-the-solution-magazine.html
29
Product lifetime-3
Lumen maintenance
• How to predict performance so long into future?
• Need to extrapolate data.
• Recent changes in standards • US: IESNA LM80TM21
• EU: IEC 62722 / IEC 63013
• Difference in L70, L80 and L90:
• Warranty should cover abrupt failures of light source (and control gear?)
• What should the relationship be between warranty and LxBy (if any)?
30
Product lifetime criteria proposal
Key points: • A single TS for minimum LxBy and warranty to cover "faulty" equipment.
• Core: L92B50 @16000 hrs + L80B10 @60000 hrs.
• Comp.: L92B50 @16000 hrs + L90B10 @60000 hrs.
• An AC to encourage extended warranties (up to a point).
Discussion points: • Opinions about LxBy approach? For x, for y and for operational hours.
• Does it make sense to specifically mention FLLM for cases of HID lamps? • If so, what ambition level?
• For the warranty that the procurer gets, who is it against? The contractor or the
manufacturer?
31
Reparability-1
A central tenet of circular economy philosophy! • Lots of individual things can go wrong…
• Should be able to fix that individual thing instead of buying a whole new set of
things throwing away lots of perfectly fine parts too…
LSRSC, 2014. LED luminaire lifetime: recommendations for testing and reporting. Solid-state lighting product quality initiative, 3rd edition, September 2014, Next generation lighting industry alliance LED systems reliability consortium.
32
Reparability-2
Basic requirements
• LED and auxiliaries have to be accessible. • 4 classes of luminaires in BE.
• Only class 1 is considered suitable for GPP.
• LED and auxiliaries have to be easy to disassemble.
• Ease of disassembly will depend on: • Product design.
• Quality of instructions provided.
• Tools needed.
33
Reparability criteria proposal
Key points:
• A single TS that: • Aligns with class 1 type accessibility in the BE system
• Defines basic tools that should be able to do any access/disassembly.
Discussion points: • LED a fast-moving technology upgradeability is important?
• Any experience with "design for upgradeability"?
• Is the lifetime of LED and the luminaire lifetime going to merge?
34
Ingress Protection-1
Why important?
• Strongly related to product durability.
• Also related to assumed maintenance factors…?
• Ingress protection clearly decreases the potential for lumen depreciation
caused by interior fouling. Not sure about exterior fouling.
Cleaning interval (months)
Luminaire maintenance factor (FLM) IP2X IP5X IP6X
High pollution Medium pollution
Low pollution
High pollution
Medium pollution
Low pollution
High pollution
Medium pollution
Low pollution
12 0.53 0.62 0.82 0.89 0.90 0.92 0.91 0.92 0.93
24 0.48 0.58 0.80 0.87 0.88 0.91 0.90 0.91 0.92
36 0.45 0.56 0.79 0.84 0.86 0.90 0.88 0.89 0.91
48 0.42 0.53 0.78 0.76 0.82 0.88 0.83 0.87 0.90
35
Ingress Protection-2
What does it mean exactly:
http://www.standardpro.com/ip-code-what-it-means/
We are looking at:
• IP55
• IP65 and
• IP66
For EU GPP road
lighting
36
Reparability criteria proposal
Key points:
• A single TS that: • Nuances the IP rating as IP55, IP65 or IP66
• Depends on local conditions – i.e. procurer decides.
Discussion points:
• If higher IP rating (e.g. IP55 IP65) leads to higher MF (1-7%)….. • We end up with less over-design of lighting….
• Sufficient argument to justify minimum IP65 across the board?
• Then higher only if local conditions require it?
• What is cost premium on IP ratings?
37
Control gear failure rate-1
Why important?
• Even the best light source will fail if the control gear/driver fails.
• Can lead to premature disposal of perfectly functional light source.
• Provides a specific quality assurance on the control gear.
• Relating to IP rating..?
• Relating to control gear/driver..?
http://www.standardpro.com/ip-code-what-it-means/
38
Control gear failure rate criteria proposal
Key points:
• A single TS that sets minimum requirements: • Core: 0.2% per 1000h + an 8 year control gear warranty.
• Comp.: 0.1% per 1000h + a 10 year control gear warranty.
• Warranty matches ambition of light source warranty.
Discussion points:
• Any experience with this?
• What are the main test methods used? No international standards?
• What are reputable manufacturers offering?
39
Closing remarks and next steps
• Draft minutes of the meeting to be sent out ASAP. • Then a 1 week period for any requested corrections to minutes.
• Then minutes uploaded on BATIS and JRC website.
• Written comments to be submitted on the html document on BATIS. • Deadline for written comments: 21st October 2017.
• Discussion amongst stakeholders also encouraged on BATIS forum.
• Comments will be taken into account and a new version of the TR
published by end of January 2018.
• Feb/March 2018: 6 week stakeholder written consultation period.
40
Any questions? You can write to me at [email protected]
Project website: http://susproc.jrc.ec.europa.eu/Street_lighting_and_Traffic_signs/documents.html
Stakeholder platform: http://eippcb.jrc.ec.europa.eu/batis/