3November 28, 2
November 21, 2014
Mr. Hughes Nappert
Manager, Regulatory Standards
Engineering, Planning and Standards Branch
Spectrum, Information Technologies and Telecommunications Sector
Industry Canada
365 Laurier Avenue West
Ottawa ON
K1A 0C8
Submitted via email: Hughes.Nappert@ic.gc.ca
NEMA Comments on Industry Canada Proposal on Lighting Regulation - Request for
Comment
Dear Monsieur Nappert,
The National Electrical Manufacturers Association (NEMA) appreciates the opportunity to
provide the attached comments on Industry Canada’s Proposal on Lighting Regulation. These
comments are submitted on behalf of NEMA Lighting Systems Division member companies.
As you may know, NEMA is the association of electrical equipment and medical imaging
manufacturers, founded in 1926 and headquartered in Arlington, Virginia. Its nearly 400 member
companies manufacture a diverse set of products including power transmission and distribution
equipment, lighting systems, factory automation and control systems, and medical diagnostic
imaging systems. The U.S. electroindustry accounts for more than 7,000 manufacturing
facilities, nearly 400,000 workers, and over $100 billion in total U.S. shipments.
Please find our detailed comments below. We look forward to working with you further on this
important project. If you have any questions on these comments, please contact Alex
Boesenberg of NEMA at 703-841-3268 or alex.boesenberg@nema.org.
Sincerely,
Kyle Pitsor
Vice President, Government Relations
National Electrical Manufacturers Association
1300 North 17th Street, Suite 900 - Rosslyn, VA 22209
NEMA Comments on Industry Canada Proposal on Lighting Regulation
NEMA and its members appreciate the opportunity to comment to Industry Canada’s proposal
and considerations to adopt CISPR 15 requirements for Lighting Products in the Canadian
market. We have several concerns and questions regarding this proposal, which we detail
below.
1. Regarding the presented background from Industry Canada:
“Earlier this year, Industry Canada became aware of interference cases involving very noisy
LED lighting equipment. As a consequence, Industry Canada performed a measurement
study on LED lighting devices and has confirmed the need for clear rules for LED lighting
equipment along with other lighting equipment to be included in the Interference-Causing
Equipment Standard 005 (ICES-005), Radio Frequency Lighting Devices (RFLDs). Industry
Canada is seeking feedback with regard to the following proposal as part of its consultation
process. The feedback received would be considered in the development of the upcoming
issue of ICES-005.”
NEMA Comment: We note from NEMA members in attendance at several subsequent
meetings also attended by Industry Canada staff that testing results from three products
were shared for discussion. Of those three, one was distinctly not in compliance with any
recognized emissions requirements, while the other two exhibited little or no emissions at
levels consistent with issues in the field. We submit that the field enforcement process is
appropriate (as was conducted) to address the non-compliant first lamp. No new regulation
is needed to address this situation. See also our comment under No. 11 below.
2. Regarding the Industry Canada proposal:
“We, Industry Canada, are proposing the following: The adoption of the current IEC CISPR
15 standard, Edition 8, published in May 2013, entitled: Limits and methods of measurement
of radio disturbance characteristics of electrical lighting and similar equipment. Additionally,
we are proposing to extend the frequency range of the radiated emission limits of this
CISPR 15, Edition 8 up to 1 GHz. Specifically, the current radiated emission limit applicable
at 300 MHz in CISPR 15 would also apply in the 300 MHz – 1GHz frequency range. In
adopting CISPR 15, the scope of Industry Canada’s ICES-005 would be updated to reflect
the scope of the CISPR 15 standard. Hence, a wider range of lighting equipment such as
dimmers which are currently not encompassed by ICES-005 (i.e. RFLDs) would be included
in the upcoming version of ICES-005.”
NEMA Comment: We would appreciate further clarification on the following.
a. How was it determined that switching from ICES 005 to CISPR 15 will mitigate the
reported case(s)? Some NEMA members who have global presence in their markets
have already tested U.S. and Canadian product designs to CISPR, in their efforts to
use one design in multiple regions as often as possible. In most cases we have
examined, devices built to FCC Part 15/18 requirements have not exceeded the
thresholds of CISPR standards, causing us to doubt that Industry Canada’s proposal
to adopt CISPR will adequately address the claimed interference issues in the field
any more effectively than existing ICES regulations.
b. The CISPR F Committee is discussing to extend the range from 300 MHz to 1 GHz
in the future CISPR edition 9. A document for comments is anticipated soon. This
complex matter will take some time to analyze scientifically and reach consensus. It
is therefore not possible to tell if Industry Canada’s proposed direct expansion of the
same limit at 300 MHz to include 1 GHz is technically justified at this point.
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3. We wish to bring to Industry Canada’s attention several unintended consequences of
adopting CISPR 15 at this time:
a. Mains voltage range differences between Canada and Europe and the proposal’s
inadequate scientific evidence to predict the impact of lowering the bottom of the
voltage range from 220VAC (CISPR) to 120VAC (CAN) and raising the upper
voltage range from 240VAC (CISPR) to 347VAC (CAN).
b. Additional product testing costs will be incurred that will likely impact Canadian
consumers, and given the energy efficient nature of these products, this additional
cost could only be justified by a real corresponding benefit that we do not see at this
time.
c. Potential mismatch between Canadian and European regulations following
conclusion of ongoing CISPR F committee discussions.
d. CISPR 15 establishes immunity requirements for spectrum license holders and
users, whereas Industry Canada and FCC currently do not. A move to adopt CISPR
15 for Lighting products, and any others, should logically also include consideration
of and establishment of immunity requirements for spectrum users. Their
representatives should be consulted.
4. We wish to know if lighting dimmer controls were involved with any of Canada’s interference
studies or reported products.
5. We appreciate sharing study results onscreen at a few meetings, but it would be even more
useful to industry in considering this proposal if Industry Canada could provide for deeper
review of the study that it conducted and also details of specific products involved in field
incidents. It is nearly impossible to answer Industry Canada’s concerns without better
scientific and factual information.
6. With respect to technologies besides LED (since those are in scope of this proposal): The
installed base of lighting technologies and its performance will not be noticeably affected by
a new EMI regulation for many years because of the millions of products installed and the
predicted life of these installations. NEMA’s internal market data for the past five year’s U.S.
sales for Fluorescent Lamp Ballasts and High Intensity Discharge Ballasts (ex. office
lighting, street lighting and high-bay lighting) is 472 million units. This number is staggering
compared to the extremely low number of reported interference incidents in the field, both in
the U.S. and Canada. As these installations age and fail, it is probable that most of them
will be replaced by LED-based products.
7. LED based products may be better covered under ICES 003, although further scientific
study is needed to be certain. This standard is efficiently addressing emissions from other
powers supplies in Canada already. It includes considerations up to 1 GHz already.
8. An additional fundamental consideration follows; most 120V to 277V lighting products today
do not meet CISPR requirements at 150 KHz. This is a regional consideration; most CE
products are not designed to operate in such range. Adopting CISPR in Canada without
due consideration to regional differences may lead to separate lighting products for 120V
and 277V, increasing cost and reducing new energy saving technologies accessibility to the
Canadian society. We respect that Industry Canada asked for a list of potential regional
differences, but as noted above we cannot adequately address this issue without further
study, data, and discussion.
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9. It is our understanding that FCC Part 18 and ICES 005 are harmonized standards, with
regard to discharge lighting products. In the spirit of cooperation, we suggest the same
approach be used in harmonizing regulations for LED lighting products, rather than
undertake new requirements for all lighting products. This is reasonable, even necessary,
given the likelihood of product migration over the border between our two countries.
10. We believe Canadian society will be better served by a harmonized regional regulation.
Industry Canada and FCC are cooperating in various areas of the spectrum; such as the
800 MHz reallocation. ICES 003 and FCC part 15 have specific limits and considerations
that cover emissions up to 1 GHz already. Furthermore, the U.S. and Canada just a few
weeks ago announced the start of efforts for the Regulatory Cooperation Council (RCC
http://www.trade.gov/rcc/), whose specific purpose is to harmonize and deconflict U.S. and
Canadian regulations. It makes sense to strongly consider moving this effort into the RCC
process.
11. The discussions to date strongly suggest to NEMA that a large part of Industry Canada’s
perceived need to specify new/changed regulations stems from a lack of clear authority to
address interference issues in the field involving LED lighting products. We submit that it is
possible to add authority without adding new or expanded emissions requirements simply by
extending the scope of ICES 003 to specifically include LED Lighting products and that
change would clarify authority.
12. Finally, we propose that further consideration of expanded or changed Canadian and U.S.
regulations for lighting products be undertaken in a cooperative process between our two
countries, given our common border, common concerns, common market and common
goals. One possible avenue of approach would be the RCC effort we note above. Another
method would be a joint effort to develop harmonized requirements in a setting involving
Industry Canada, FCC and representatives of affected industries, including spectrum license
holders.
In Summary:
• ICES 005 and FCC part 18 should continue to mirror their requirements between both
countries.
• The existing ICES 005 (mirrored with FCC part 18) should continue to be applicable to
traditional discharge lighting products in Canada.
• ICES 003 and FCC part 15 should continue to mirror their requirements between both
countries.
• ICES 003 (mirrored with FCC part 15) scope should be extended to include LED lighting
products in Canada, thus clearly granting authority to Industry Canada to enforce
requirements against interference and address incidents in the field involving these
products.
• It appears that some of the reported incidents of LED lighting interference in Canada
resulted from LED lamps not in compliance with emissions limits of either ICES 003 or
CISPR 15. Changing or expanding existing requirements cannot mitigate noncompliance with existing requirements. In these cases, the existing process of
identifying and resolving field interference incidents will remain the best path to
resolution.
• Because of the similarity of the radiated requirements in the 50 MHz frequency band for
ICES 003 and CISPR 15, the proposal from Industry Canada to adopt CISPR 15 equally
supports the theory that ICES 003 compliance enforcement can address interference
prevention just as effectively. However, the added cost of testing products for sale in
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Canada that would follow adoption of CISPR 15 will logically result in an increased cost
for the Canadian consumer, with a potentially reduced product offering and with no clear
benefits.
Industry Canada’s suggestion to expand the existing CISPR radiated limits from 300
MHz to 1 GHz is not part of the existing CISPR 15 Ed 8 published standard and should
not be considered.
Finally; CISPR 15 should not be adopted in Canada at this time.
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