More Thoughts on T24 for Lighting

My latest overly lengthy post on California's Title 24 changes received some comments from my excellent colleague Jay Shuler, CEO of Cool Lumens, a Santa Cruz LED startup. His comments are in blue, and my responses below.

1. Dictate results, not technologies or technological implementation. This is the Prime Directive of standards. Do not squelch innovation by limiting how people achieve your goals. 

I agree totally on technology neutrality. In my mind there are some problems with the current proposals in this regard. Tech neutrality should also be seen in the context of what's between the lines. It's always the stated intent in regulation, but very often things are wired so that only one technology can fit the regulatory goal. In the case of LEDs, this is true to some extent. But there is no real viable replacement on the horizon, and LED as a general class of technology is incredibly broad and has much potential. Where I see issues are in provisions that require integrated fixtures vs simple lamp retrofits. As I explained in my last blog, some of these issues speak to the tradeoffs necessary in achieving a balance between private profit and public good. 

I'm not worried about squelching innovation as a bad thing- I think we should squelch it and slow it down so that we can understand what we're doing better before find ourselves in RobotLand and the IOT is the oppressive global government, like in Brave New World.

2. Dictate results that matter, and be application aware. For example, color quality is important to a much different degree in different applications. Where visibility is the primary concern, CRI matters only to provide color contrast in addition to luminance contrast. It is obviously much more important in retail and hospitality, including home. A reasonable metric would provide minimum CRI standards for different applications. But don't get too strict... CRI is a matter of opinion, not science.

"Results that matter" should always be the goal of regulation and standards, it's just that we don't really have agreement on how CRI matters. There's a lot of science behind it, and once again, we don't have agreement on how the science matters. The relevance of color varies greatly in different applications, this is true. Most of the proposed T24 changes seem to recognize this and have been carefully considered according to different applications. The reasonable metric with minimum CRI is pretty much exactly what needs to be worked out, it's complicated.

3. Efficiency is incredibly important to global warming and other things that one could easily argue are more important than being able to see red a little better. However, given the need for color in many apps, a sliding metric that computes efficacy and CRi together might make sense... something like setting a minimum value for LPW x CRI. (low LPW x high CRI = high LPW x low CRI). 

Yes, efficiency is crucial and often overlooked and taken for granted in lighting today. The connection between quality and adoption however remains very clear to me, but unfortunately not to everyone. I appreciate Jay's being willing to take a look at different metrics or combinations of metrics. LPW and CRI are of course both important. I'm not sure if multiplying them will give the result, and there is a danger in using a single metric for everything, it simply can't tell the whole story no matter how accurate it is, especially with CRI. I like the idea of a "sliding" metric- more like a scale. I hope the CEC sees enough creative thinking here to develop a good approach- it's not obvious now what that might be, but that shouldn't keep us from trying.

4. Watch out for efforts to save the industry from itself... trust the market to some extent. In other words, crappy products will fail in the market; you don't have to disallow them. This has been the mission of the DOE for a long time, and it is laudable to establish voluntary standards of quality... a Good Housekeeping stamp of approval, if you will... but hesitate to be heavy handed. EnergyStar and DLC are great and laudable efforts, and good enough.

I really don't always trust the market alone. For one thing, it's moving too fast now for regulation to keep up. And this rapid movement results in dramatically increased inequalities- everyone's aware of these issues. The key thing is a healthy stable balance between markets and government- this kind of thing is simply too difficult for most Americans to envision. I'm workin' on that.

I would beg to differ about Energy Star and would argue that their efforts have come across as somewhat heavy handed. Heavy handedness is very much to be avoided, as it carries a serious risk of backlash. When overly zealous energy regulations are put in place at the expense of quality and other practical considerations, people start to hate the entire idea of regulation at all and the whole house of cards starts to fall. This is happening in Europe and all over the globe, I'm disturbed by it. As I see it, the biggest problem is the lack of coordination between industry, consumers, and government. Our interests can all align, it just takes more work, and in a society that often seems to be rapidly disintegrating and losing social cohesiveness, it's a lot more work.

5. Under "It's About R9" I have a few additional comments. The blue pump is usually but not always 450-460nm. The traditional LED phosphor is yellow, not green or red, although different formulations are emerging. Blue+Yellow = White (perceived). Blue + Green + Red = white (perceived) but with a better chance at high CRI and efficacy together. Blue leaks through not by accident but on purpose, to balance the Yellow (or Red + Green) to make the perception of white. LED spectrum is actually pretty smooth compared to other phosphor-converted sources, only lacking (or more accurately, weak in) Cyan and Red in traditional YAG phosphor products, and presumably smaller slices in RGB formulas.

Good comments. It is important to realize that most (certainly not all) LED spectra are smoother- this is good in general, although the spike that occurs in most is at the 450nm range in general, the wavelength to which circadian processes are most sensitive, quite an unfortunate accident. Personally I feel that LEDs have and will continue to advance rapidly enough that we can have basically any spectrum we want, from low candelight to noonday summer sun in Marrakech and anything in between. Cyan gaps have closed and R9 is up on many "blue pump" sources these days. Phosphor engineering is a fascinating field these days- I'm always impressed by what Intematix is up to, for instance. 

California's T24 - Weigh In on Residential Quality of Light

Revisions to California’s Title 24 2016 code now being considered. I know- you’d probably rather have a root canal than think about regulatory issues. And even if you are engaged in them, it’s basically impossible to learn everything you need to know in the time you have available. But…you do have an impact on this process, and it’s important that you know how to exercise this right.

I’ve appointed myself an independent advisor to any and all who will listen, well…read that is, to present my summary analysis of the main points of this pending legislation that will affect your professional and personal lives, and to give you guidelines on how to comment effectively. Disclaimer: although I am active in the Illuminating Engineering Society (IES), and the International Association of Lighting Designers (IALD), my opinions and recommendations are presented completely independently of these groups. I am also greatly indebted to Jim Benya for his excellent comments and help. He's very actively involved in this effort, probably knows more about it than anyone on the planet, and has been at it for far longer than most of us, especially me. I’ve drawn heavily on his recommendations in making my own. I apologize for the length of this, but there's a lot to consider without serious oversimplification.

Regulation, Why Bother?
There’s much debate about the role of regulatory actions in the market- should they drive technology or follow it? This is a particularly pertinent question today with lighting, as technology is advancing so quickly that it’s impossible for regulations to keep pace. Maybe for now, regulations are following technology. Either way, regulations must allow for healthy innovation, energy efficiency, market development, health and wellness, and environmental justice without destroying the balance between private profit and public good. “Disruption” may be good for innovation (or not, that’s now quite debatable) but it’s not conducive to stable, participatory government. Poorly crafted regulation, despite the best of intentions, can do more harm than good.

I’ve limited myself to commenting only on parts of the Residential Lighting part of the code that I know enough about to form an opinion. As part of my effort here I attended the June 24 hearing at the California Energy Commission (CEC) in Sacramento.

But if you’re so inclined, I encourage you to comment on any part of the proposed changes to the code. Anyone from anywhere can comment, even people from other states or countries. Since California has traditionally been a leader in energy efficiency regulation, I think that looking towards how other regions and countries can apply our successes is important. By the same token, we in California don’t come up with all the great ideas and legislative practices - incorporating comments from outside our regional framework is healthy.

Public Comments Close July 23
The process of developing and revising codes, including Title 24, takes a long time and there are many stages during which different levels of comments, revisions, and review are incorporated. The comment period in question is for proposed changes to the 2016 code, and for now, the most important date is July 23, which is the deadline to send public comments to the CEC. After that, there will be more workshops and increasingly tight code language to review by the CEC, who will ultimately adopt it into the 2016 code.

Quality, Adoption, and Complexity
One of the many complex dimensions of T24 is that its primary purpose is to legislate energy efficiency, not “quality” per se- quality of life, indoor quality, or quality of light specifically. But the reason to include “quality” based measures, such as CRI, into the standard is that they dramatically impact the broad adoption of energy efficiency measures, especially in lighting. Efforts to improve CFL adoption, especially in residential application, failed- not because of poor regulation specifically, but because of poor product quality (actual and perceived). CRI is a key metric used to judge light quality, and it’s not necessarily a perfect metric, but in lighting we have few of those anyway, and legislation is not about perfection, it’s about results. I’ll talk more about CRI below.

A consistent refrain from those within my network who are inside the regulatory process is that there is not enough industry and user feedback. In regulatory affairs today, legislation is usually dominated by the few key players who choose to (or more importantly, in the case of well funded entrenched interests, can afford to) show up and mouth off. Participation in this process, as complicated and inconvenient as it may be for Ma and Pa Public and small businesses, is a “use it or lose it” right.

In any proposed legislation, especially that which deals with energy efficiency or environmental issues, the incumbent players’ first reaction is typically to proclaim in stentorian tones that tightening standards will be economically ruinous, imperil jobs, and hasten the demise of Western Civilization. And very often, well crafted legislation that is done with appropriate support and input from all stakeholders, including end users, overcomes these initial objections and achieves its purpose. In the current proposed changes, there is much that still needs to be worked out, and entrenched industry interests have some legitimate concerns, as do homeowners, manufacturers, industry groups, and practitioners.

Why Color Quality is Important
Residential lighting regulations are so important because in our homes, color quality in lighting is generally perceived to be more important than in public spaces. So even though residential lighting does not represent the largest percentage of overall energy use, it has a large influence on how the public perceives and supports LED technology in non-residential uses. The last breakthrough lighting technology (CFLs) failed in residential applications because quality was not a priority for manufacturers, and because incandescent light sources were not being banned. Now incandescents are being banned, and CFLs, while improved in quality, are no longer viable. LED is widely understood to be the technology of the future- fortunately it’s incredibly flexible scalable, and efficient. We will eventually enjoy much better quality of light at much higher energy efficiency.

It’s About R9
Not to be overly reductionist, but the biggest quality issue with LEDs so far has been color performance- both in temperature (CCT) and rendering (CRI). People perceive that LEDs are too blue. This is largely because most LEDs are made with a blue “fundamental emitter” or "pump"- the LED die itself emits blue light at approximately 450-460 nm, which excites the red and green (or yellow) phosphors in the LED package to create white light. Because the blue fundamental emission is used in combination with red and green to create white, a blue phosphor isn’t required – this makes the LED cheaper to produce. First generation LEDs settled for “broken” spectra, that don’t include all colors in light in balanced proportions, so the blue leaks through and shows up disproportionately (many newer LEDs, including Soraa’s especially, have improved spectral design and color rendering). This is similar to the color problem in fluorescent lamps, which also work by exciting phosphors. Because of their large surface area, a lot of phosphors are required, and manufacturers realized they could produce light cheaply by taking spectral “shortcuts”- leaving out large bands of the spectrum of white light. Both fluorescents and first generation LEDs suffer from low R9 values- the deep red part of the spectrum. This plus the high blue component of their spectra makes them look greenish or blue.

Most of the problems with LED color performance center on poorly balanced spectra and low R9- not enough red or deep red- not necessarily low CRI per se. It’s possible to achieve a high CRI value and still have low R9, as CRI is an average of all the R values. In order to look right to most people, electric light, including LEDs, especially in lower color temperatures (below 3500K), needs a full balanced spectrum and high R9 value. Even in higher color temperatures (above 3500K), full spectrum light is better, although we’re not used to it and don’t expect it because we don’t see it very often- few manufacturers make sources like this anymore.

CRI may not be the ideal metric for color, but it’s adequate for our purposes now, where it matters most, in lower color temperature residential lighting. It also has the advantage of being widely accepted and understood, at least by lighting professionals. It’s a standard that can appear on lighting product packaging- even though most of the public doesn’t understand it now, they will eventually.

Flicker, the Persistent Irritant
Manufacturers hate the flicker problem because it’s evidently so difficult to deal with. People hate flicker in LEDs because it looks unnatural, and there are health concerns. In my opinion we don’t know enough about how harmful flicker may be to have health concerns drive regulation, I’m sure many will disagree with me here. But like light quality, it’s something that will slow adoption, so must be dealt with in T24 for that reason.

Compatibility, Another Persistent Irritant
Compatibility issues with LEDs represent a widespread case of unexpected consequences –no one foresaw or wanted these problems. The entire electrical infrastructure of the US and most industrialized countries was built primarily for incandescent light sources first, in fact lighting was the primary driver for electrification in the US. And since LEDs are a technology fundamentally different from incandescent or fluorescent, they deal with power very differently and are much more sensitive to the inevitable variations in power that occur in any system like the electrical grid- it’s even more complicated than that, I’m only scratching the surface here.

In many cases, LEDs can be simply plug-and-play, changed out in existing sockets with no performance problems. In other cases, they won’t dim, they flicker, or worse, they just won’t work. Being fundamentally unidirectional, LED lamps are also necessarily configured differently than omni-directional ones- this contributes greatly to both their lamp and fixture efficiency. Unfortunately they often won’t fit in fixtures designed for incandescent or fluorescent sources. And dimmers, drivers, and other components designed for incandescent and fluorescent sources don’t always work with LEDs. This has slowed adoption, as people are used to simply switching out lamps, as was the case with CFLs, instead of having to retrofit the entire electrical system for a building just to get the benefits of LEDs.

The wide extent of compatibility problems is greatly exacerbated by the need to simultaneously embark on a replacement strategy, where many lamps are switched out for high efficiency sources, and to develop completely new components, controls, and infrastructure that are compatible with LEDs. To make things even harder to deal with, the pace of technology change means that something that works now will probably be completely outmoded in 2-3 years, when the building project you specify LEDs for today will be completed. In my opinion, the only way we can deal with these issues is to incentivize manufacturers to plan for flexibility, maintenance, and eventual obsolescence of any lighting components or system, a very difficult thing to envision, let alone execute. Still, compatibility problems will eventually be ironed out. Now the goal is to craft regulations that encourage both rapid, balanced replacement as well as innovation at the system level.

My Recommendations:

1. Revisit California Quality Lighting Initiative (CQLI)
Many of the proposed changes to T24 are the result of the CQLI, most of which I like. I recommend we take another look at the 90 CRI requirement, perhaps considering lowering it very slightly to 87, even 85, if this also includes the R9>50 (or greater) requirement. However, this may not be necessary. The EPA last year failed to include a >80 CRI requirement in the Energy star standard, claiming that the market would find a way to develop higher CRI light sources without being motivated by regulations. In fact this is what happened- most of the top LED manufacturers now offer high CRI products. I like to think that this happened because the market demanded it, and that some manufacturers foresaw eventual regulation toward this direction. In any case, the CRI requirement is one of, if not the most, important parts of the suggested changes, and regulation should be consistent with what the market is already doing, as well as make it easier for all manufacturers to offer high quality products.

2. Address Lower CCTs and Color Changing
In the 2013 standard JA8, LED lighting is required to have at least 90 CRI and a color temperature between 2700K and 4000K for indoor lighting. Because there is so much demand today for very low CCT sources, I recommend we lower this to at least 2400K. I also recommend we address color changing sources and systems, as they’re already in the market and will be a part of how we use lighting in the future.

3. Get a Handle on Flicker
Flicker mitigation is important in efforts to improve LED quality. One of the problems now is that there is no widely accepted testing and certification procedure for flicker. It’s also poorly understood, if at all, by consumers. I recommend not regulating it until we have a testing procedure in place that will support rating, certification, and labeling to consumers. By the time manufacturers begin to deal with this issue, a process should be in place. More about flicker here:

http://www.ledsmagazine.com/articles/print/volume-11/issue-4/features/developer-forum/proper-driver-design-eliminates-led-light-strobe-flicker.html

http://www.e3tnw.org/Documents/2011%20IES%20flicker%20paper%20poplawski-miller-FINAL.pdf

4. Ensure Dimmers & Transformers Are All LED Capable
Manufacturers are already making many new LED compatible transformers and dimmers. Regulations should require them, and allow for certification and labeling.

5. Support the Screw Base Proposal
Bans on conventional incandescent lamps are expected to mature by 2017, and everyone will need to begin replacing them long before that. Indeed, when LEDs become an obviously superior choice to consumers, as they surely will very soon, we need to not impede adoption by making it difficult to install LEDS in existing fixtures. The proposal to allow screw base (Edison) lamps to comply with T24 has wide acceptance, and should be supported. I’m in favor of things that make lighting consumer friendly, and Edison lamps are easy to use, as opposed to many types of connections. Connection standards in lighting should be more like the successful ones in consumer electronics, like USB, that are well designed, consumer friendly, and gain wide acceptance.

6. Review the Recessed and Enclosed Provisions
One of the proposals on the table is to require that all enclosed and recessed lighting be high efficacy and “hardwired”, meaning a dedicated fixture without removable lamp. I’m of two opinions on this. I wouldn’t support it because it does not in practice pass the “technology neutral” test, as “hardwired” fixtures, or integrated LEDs, have traditionally been expensive, and they’re a perfect example of something that will be outmoded soon after installation. With the appropriate fixture and lamp combination, you can do the same thing as an integrated luminaire for a lot less money, and you can swap out the lamp when you get a better one. However, the real reason for this proposed requirement is that there are widespread thermal performance issues with LEDs- even though they run cooler than incandescents, they can generate a lot of heat in enclosed fixtures and much more sensitive to higher temperatures. In recessed and enclosed fixtures they can pose a fire hazard. Also, integrated fixtures are becoming much more affordable, so until thermal performance issues are resolved with LED lamps, the rationale is that it doesn’t make sense to allow them as high efficacy sources in enclosed and recessed fixtures. Maybe we have to wait on this one.

7. Rethink Lifetime Expectations
This is a problem that I’m not sure I have a regulatory answer for. LED lifetimes claimed by manufacturers are largely irrelevant and don’t bear much relation to real-world conditions, for several reasons: 1.) Actual lifetimes depend on other components like drivers, which are not necessarily as long-lived as lamps, 2.) Actual lifetimes are difficult to predict, as the testing system depends on extrapolation- 50,000 hours of over 6 years of 24/7 use, 3.) LEDs don’t fail noticeably, they slowly degrade, so it’s difficult to tell when to replace them, 4.) Manufacturers often claim long lifetimes because they don’t often have much that differentiates their products, the initial high price of LEDs needs to be justified with long life, and consumers simply think that longer is always better, and 5.) LEDs will certainly improve dramatically, with lower cost, higher quality, and increased efficiency well within five years, and installations of current products will most likely be replaced anyway. The bottom line for manufacturers is that lowering lifetime thresholds will make LEDs cheaper, speeding up adoption, bringing down price, and saving more energy sooner. It seems counterintuitive, but maybe we could argue for lowering lifetime requirements.

8. Convene More Roundtables
In my opinion, ( and Mr. Benya’s) more industry roundtables on LED lamps, fixtures, and controls should be convened ASAP. Manufacturers should be invited and consensus should be reached on all proposed changed to the Standard. If you're a manufacturer, make sure you're represented at these meetings.

A Brilliant Future, If We Get it Right
Despite the formidable technical, economic, environmental, regulatory, and political challenges involved in the current transition in lighting, I believe that the future holds the very real possibility of better electric lighting everywhere- higher quality, cheaper, more flexible, and significantly more energy efficient. The new technology is too compellingly better in almost every way, but technology alone is not enough, nor is any single part of the process. Industry, government, consumers, and NGOs all need to work together to get the regulations right. If we don’t, we run the risk of delaying crucially needed energy use reductions and improvements in light and indoor environmental quality. You can play a part in this by making informed comments to the CEC.

How to Comment
The best contact method is email at docket@energy.ca.gov. Please include the docket number #2014-BSTD-01 and indicate 2016 Building Standards Update in the subject line. Please include your name and any organization name. Comments should be in a downloadable, searchable format such as Microsoft Word (.doc) or Adobe Acrobat (.pdf)

Light...By the People and For the People

Kickin' it the Merkan way with my boy U-Sam in Troy, NY.
Snap by George Gruel.

In a recent LI discussion group post about the role of government regulation in lighting, one ornery contributor took issue with my use of the term “environmental justice,” referring to it as a “silly term” coined by meddlesome “statists.” This made me realize that perhaps some people out there may not see eye-to-eye with me about shaping the regulatory environment around lighting, could it be? So I thought I’d better explain myself on this idea in a forum where the shouting is somewhat more filtered out.

I love it when I’m deeply ruminating on something (in this case it was the entire idea of government and how we believe it’s generally irrelevant) and I read a piece that neatly sums up a position and conclusions I’m already coming to on my own and points to a path of action. In this case it was Nathan Heller’s brilliant piece on the current clash of real people and the invading technocracy in my hometown San Francisco, California Screaming in the July 7 New Yorker. Here he points out that government is pretty much the opposite of innovation (kissin’ cousin of the recently mortally wounded meme whose name is Disruption) and the exquisitely efficient transfer of information that has come to define our culture today. Government is slow, participatory, painful, endlessly iterative, analog, and frustrating, but it still works. (It does, OK? Who builds the roads and delivers the water?) The really radical thing for Silicon Valley companies and people to do would be to embrace and enhance government as it is rather than constantly trying to reinvent it, or turn it into software-driven private enterprise. Of course information technology has made many functions of government infinitely better, like paying parking tickets. That doesn’t mean that the idea of government is over, or dead. That’s basically what Ted Cruz and the Tea Party want you to believe.

EPA (an agency I’m not always in agreement with) defines environmental justice as “…the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.” Also, “EPA has this goal for all communities and persons across this Nation. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment in which to live, learn, and work.” That works for me: equal distribution of income, equal protection, equal opportunity. If that’s silly to you, call me a communist, or worse, a liberal. But if you’re not participating, step aside. I’ve got work to do.

My radical idea is to consider the built environment, especially indoors, where we spend almost all of our time, as probably the most important part of the “environment,” especially when it comes to lighting. This is something we’ve never really done before as far as I can tell. I mean, sure, jungles and spotted owls and rivers are worth saving for future generations, but let’s also focus on buildings, cities, all the built environment in the public domain, and apply ideas of environmental justice to its financing, regulation, design, construction, maintenance, and use of materials, energy, and water.

We’re still at a global tipping point with lighting. We have suffered far too long from crappy lighting in most of the global built environment. Incandescent lights have acceptable quality, in fact they’re mostly what we still recognize as lighting when we’re not at Walmart or in general commercial office wasteland, but now we know they use way too much energy. Fluorescent lights have to go- we hate the way they make things look, and they don’t save enough energy. LEDs will provide wonderful light in the future, save a lot of energy, and solve most lighting problems, but only if we get the regulations right. With incandescents being phased out globally, manufacturers will continue to just make the cheapest LED lighting they can and consumers and businesses won’t have much choice unless we get involved. We won’t revert to incandescents and we won’t suddenly adopt more CFLs- that’s a dead technology. LEDS superior in all ways than incandescents are already on the market, it’s just a matter of how quickly they’ll be adopted. Rapid adoption of LEDs is good for reducing global energy use sooner, but their quality has to be as good as incandescents. It already is, most people just don’t know it yet. Regulation will play a catalytic role in making better LED lighting widespread. We all have to get much more involved in order to make this happen, and we have to believe that getting involved matters and that government works- they do, trust me. You can help, more on this below.

I started a Facebook page on July 4th last year: People Against Bad Lighting. It was tongue-in-cheek and part of a product marketing effort, but there was some real political purpose there beyond selling LED lights. In the process of doing this I got to riff on the Declaration of Independence, which involved actually reading it, something I highly recommend. Lately I’m realizing that on some level, I’m still proud of being an American and of the basic blueprint of our government, flawed and tenuous and constantly embattled as it is. In my mind the best thing about it is that it contains instructions for ongoing reinvention, retrofitting, and renovation. If that makes me a “statist,” one who believes in the idea of “states,” with participatory government, then I’m guilty as charged. I’m not exactly sure what the viable alternative to being a “statist” is today, unless it’s reverting to tribal nomadic social structure. Ghengis Khan did the nomadic thing pretty well actually, but he evolved into a statist, and one with startlingly modern notions about religious freedom and equal distribution of rights and resources. Besides, he’s been gone kind of a long time and there are a few more people on the planet now than there were in his time.

Environmental justice in lighting means that all people have the right to high quality lighting indoors and out, just as we have the right to high quality water and air indoors and out. Egregious violations of our basic environmental rights as humans with lighting may not seem as life threatening or heinous as water and air pollution and carcinogenic pesticides, but they’re still important- more so because they’re largely unrecognized.

There is global awareness of the problems of light pollution, overlighting, and encroachment in outdoor lighting- all exacerbated by the recent rapid adoption of high blue spectrum LED light, harmful to humans and other living species. Public outdoor lighting has historically often been highly contentious and politicized, as it should be. We’re trying to figure out the extent of negative health effects from poor quality indoor fluorescent and LED lighting, but it will be quite some time before we can draw enough conclusions to effect real legislation around this issue. In the meantime, the fact that bad indoor lighting is ugly and demoralizing as well as too energy intensive is enough to consider it a serious environmental problem.

There are other important benefits to encompassing lighting within the concept of environmental justice. From my experience in green building, I know that lighting retrofits are responsible for “jump starting” a huge number of energy efficiency projects, as lighting is the single most visible use of electricity. Projects that start with the “low hanging fruit” of lighting replacement very often go beyond that as people start to look at buildings more holistically. And while LEDs now may still seem to many to be too expensive and only for richer people and fancier buildings, the technology will soon become prevalent and widely available to everyone, in high quality. In fact it will also provide electric light for the first time to many who have not yet adopted incandescents or fluorescents, just as many people in developing countries who never had landlines now use cell phones.

For those in the lighting world, and for that matter anyone concerned with energy use, “resilience, “sustainability” and global warming, now is the time to weigh in on proposed changes to California’s Title 24 energy code around lighting. Here’s where to start participating http://www.energy.ca.gov/title24/participation.html. In addition, I and some of my colleagues will be providing summaries of the proposed changes and recommendations about how to comment. Do this even if you don't live or work in California, or the U.S. as the quality provisions being considered here will affect lighting far beyond the state.

The best example I’ve seen so far of true participatory “redesign” of government was the UK’s Government Digital Service’s revamping of government websites. This is inspiring to me as a designer, a writer, a marketing person, a web developer, a researcher, and a citizen. If we could have this level of effort and results in lighting regulation and the subsequent transition to a new lighting and energy infrastructure, there would really be justice in the world.