Residential Lighting Solution Pipeline Plan December 2012 CALIFORNIA STATEWIDE LIGHTING MARKET TRANSFORMATION PROGRAM 2013‐2014 RESIDENTIAL LIGHTING SOLUTIONS PIPELINE PLAN Prepared for Southern California Edison by The Cadmus Group, Inc. 1 Residential Lighting Solution Pipeline Plan December 2012 TABLE OF CONTENTS Acknowledgements ....................................................................................................................................................... 3 Purpose of Residential Lighting Solutions Pipeline Plan ................................................................................................ 4 Updates to Pipeline Plans .......................................................................................................................................... 4 Residential Lighting Market Sector Overview ............................................................................................................... 5 California’s Lighting Market ....................................................................................................................................... 5 Energy‐Efficient Lighting Trends in the U.S. Residential Market ............................................................................... 5 Market Transformation Process .................................................................................................................................... 8 Push ........................................................................................................................................................................... 8 Trim ............................................................................................................................................................................ 8 Lighting Solution Push: LED Downlight .......................................................................................................................... 8 Description of LED Downlights and Applications ....................................................................................................... 8 Rationale for pushing ............................................................................................................................................... 10 Energy and Demand Benefits .............................................................................................................................. 10 Non‐Energy Benefits ............................................................................................................................................ 11 Overview of Current Efforts ..................................................................................................................................... 12 Overview of California Programmatic Efforts ...................................................................................................... 12 Non‐Programmatic Efforts ................................................................................................................................... 14 Overview of Major Market Barriers ......................................................................................................................... 17 Market Barrier: Product Quality and Performance ................................................................................................. 18 Market Barrier: Cost ................................................................................................................................................ 21 Market Barrier: Customer Awareness and Perceptions .......................................................................................... 22 Summary of Partners and Implementation Actions ................................................................................................ 24 Lighting Solution Trim: SPecific Compact Fluorescent Lamp Applications .................................................................. 26 Description of CFL and Applications ........................................................................................................................ 26 RationalE for Trimming ............................................................................................................................................ 28 Approaches for Trimming ........................................................................................................................................ 29 Summary of LMT Program Actions .............................................................................................................................. 31 2 Residential Lighting Solution Pipeline Plan December 2012 ACKNOWLEDGEMENTS The Cadmus Group, Inc. worked with SCE staff to develop this pipeline plan and reviewed multiple sources of information, including reports such as the California Long‐Term Energy Efficiency Strategic Plan1 and other documents characterizing the residential lighting market and its needs. We also relied on input from several SCE, PG&E, and SDG&E Lighting Market Transformation (LMT) program managers, lighting policy experts, lighting designers, lighting manufacturers, and lighting procurement professionals. We thank the following individuals for their time and valuable input. Name
Role
Organization
PurposeofInterview
Vireak Ly LMT Program Manger SCE LMT Activities and Pipeline Plans Marissa Barrera Offer Manager, Customized Solutions SCE Energy‐Efficiency Programs Randall Higa C&S Manager SCE Codes and Standards Process for LED Downlights Richard Greenburg Product Manager SCE Experiences with LED Downlights for SCE Residential Programs Teren Abear ET Field Placement Manager SCE Experience with LED Downlight in SCE’s Emerging Technology Programs David Bend LMT Program Manager PG&E PG&E’s Efforts in Residential Lighting Mike Nguyen LMT Program Manager SDG&E SDG&E Efforts in Residential Lighting Jim Benya Principal Benya Lighting Design perspective on LED downlights Rick Bain Director of Business Development Cree Inc. Manufacturer LED Downlight Perspective Gus Lanese LED Replacement Lamp, Engineer General Electric Manufacturer LED Downlight Perspective Eileen Eaton Lighting Program Manager Consortium for Energy Efficiency Konstantinos Papamichael Co‐Director of CLTC California Lighting Technology Center Karl Johnson Research Coordinator California Institute for Energy and Environment Eric Richman Senior Research Engineer Pacific Northwest National Laboratory Caroline Chen Evaluation Project Manager SCE Feedback on Pipeline Plans Nancy Clanton President Clanton Associates Designer Perspective Lara Cordell Account Executive Widenbach‐Brown Provider Perspective (works closely with clients from large companies) Energy‐Efficiency Advocate/Industry Perspective on LED Downlights Academic Perspective on LEDs and Exterior Bi‐Level Lighting for the California Market Academic Perspective on LEDs and Exterior Bi‐Level Lighting for the California Market National Laboratory Perspective on Emerging Technologies and Codes Development 1
California Public Utilities Commission. California Long‐Term Energy Efficiency Strategic Plan. September 2008.
3 Residential Lighting Solution Pipeline Plan December 2012 PURPOSE OF RESIDENTIAL LIGHTING SOLUTIONS PIPELINE PLAN This Residential Lighting Solutions Pipeline Plan is a guiding document for implementing the LMT program in 2013‐2014. Its purpose is to:  Characterize the current residential lighting market and relevant trends.  Describe the market transformation process for pushing the market towards more efficient lighting solutions and trimming transformed solutions from investor‐owned utilities’ (IOUs) energy‐efficiency portfolios.  Help IOUs meet the lighting needs of customers within the residential market sector and help meet the IOUs’ and California’s energy‐efficiency goals by identifying strategic lighting solutions to push and to trim. o Lighting Solution Push: Present the rationale for pushing a lighting solution, recent programmatic and non‐programmatic efforts, and a strategy for overcoming market barriers that coordinates actions among IOUs and other market actors. This pipeline plan pushes LED downlights. o Lighting Solution Trim: Help the IOUs determine when a lighting solution has been transformed and how to best phase out support. This pipeline plan trims compact fluorescent lamps (CFLs). UPDATES TO PIPELINE PLANS This plan is a living document that will be updated annually to incorporate relevant findings from newly completed studies. The next update will incorporate findings from the following studies:  KEMA. California Lighting Retail Store Shelf Survey Report. Fall 2011.  KEMA. California LED Lamp Market Characterization Report. 2012.  Southern California Edison. LED Market Trial. In progress. Currently, this residential pipeline plan outlines steps to push and trim a limited number of lighting solutions. The LMT program staff worked collaboratively with various other energy‐efficiency program staff to identify these solutions. In the future, LMT program staff will select additional lighting solutions to push or trim based on information derived from the LMT Lighting Solution Workbook, the LMT Lighting Activity Workbook, and past versions of the LMT Lighting Solution Pipeline Plans. A description of the Lighting Solutions Workbook and the Lighting Activity Workbook follow.  The LMT Lighting Solution Workbook is a utility program planning tool. The workbook contains market data that allow for prioritizing lighting solutions (such as products, systems, and design strategies) by sector (residential and non‐residential), technology, savings potential, and market barriers. The prioritization variables depend on the specific aspect in consideration for program planning, but will result in a set of Key Lighting Solutions that balance the availability of stakeholder resources, existing interest and momentum, and the level of effort required to affect the market.  The LMT Lighting Activity Workbook contains information about the various completed, ongoing, and planned IOU lighting activities (such as technology assessments, demonstrations, program trial studies, and measurement & evaluation market studies). The Lighting Activity Workbook allows analysis of lighting activity gaps and needs to prioritize, align, and streamline lighting activities for efficiently overcoming the Key Lighting Solutions’ market barriers. 4 Residential Lighting Solution Pipeline Plan December 2012 RESIDENTIAL LIGHTING MARKET SECTOR OVERVIEW CALIFORNIA’S LIGHTING MARKET Lighting represents 22% of the electricity used in the average California home (California Public Utilities Commission, 2008), which is approximately 16,000 GWh/year across residences in the IOU service areas. Based on data contained in the Lighting Solutions Workbook and KEMA’s socket inventory data from 2008‐2009,2 residential energy consumption by product type is as shown in Table 1. Table 1. California Residential Lighting End‐Use Consumption by Product Type Product Type Percent of Interior Lighting End‐Use Consumption Incandescent Medium Screw Base (MSB) 62% Linear Fluorescent 10% CFL MSB 8% Incandescent Small Screw Base 8% Halogen Pin Base 6% Halogen MSB 3% LED MSB 0% Product Type Percent of Exterior Lighting End‐Use Consumption Incandescent Flood MSB 72% Halogen Flood MSB 28% * Does not sum to 100% due to rounding. This table shows there is significant potential for energy savings in California residential lighting applications, primarily by replacing incandescent lamps. Incandescent lamps are ubiquitous in the residential market and are found in a variety of fixture types (wall, ceiling, recessed, ceiling fan, etc.) and locations (bathroom, bedroom, living room, kitchen, office, etc.). Most lamps in the home are connected to a simple on/off switch; dimmers and three‐way switches are much less prevalent. ENERGY‐EFFICIENT LIGHTING TRENDS IN THE U.S. RESIDENTIAL MARKET The United States residential lighting market still has substantial potential for energy savings. Of the 51.4 average lamps installed in a U.S. residence, approximately 23% are CFLs, equivalent to roughly 12 2
Unpublished data. 5 Residential Lighting Solution Pipeline Plan December 2012 CFLs per home.3 Although CFLs have a 23% overall socket saturation, they represent only 8% of the interior lighting energy usage, as shown in Table 1. Thus, there is still room for significant increases in CFL saturation/penetration. According to the U.S. Department of Energy (DOE), the U.S. residential sector accounts for approximately 175 Terra Watt hours (TWh) of electric consumption annually, a decrease from 208 TWh in 2001 (DOE, January 2012). This reduction of 33 TWh could be correlated to the increase in residential CFL saturation over the past decade. The residential lighting market has come a long way in adopting energy‐efficient technology. Prior to CFLs, dimmable incandescent lamps and luminaires, linear fluorescents, and other fluorescent luminaires were the primary sources of energy‐efficient lighting, which offered consumers limited functionality and aesthetics. In the early 1990s, CFLs first entered the residential lighting market with major performance limitations, which ranged from flickering and humming during operation, to poor light quality, to incompatibilities with dimming. Although an energy‐efficient light source was developed, there were issues that went unaddressed and ended up hampering adoption. CFLs experienced similar market barriers to those currently experienced by LED recessed downlights, such as performance, cost, and awareness. Therefore, CFLs serve as a good benchmark technology for LED recessed downlights. CFL saturation increased because of utility market coordination with manufacturers and retailers, a shift in consumer behavior toward energy‐efficient and environmentally friendly products, and federal and state government policies. Utility sponsored energy‐efficiency programs nationwide, mandated by regulators to save energy, have relied on CFL programs for large portions of their total portfolios’ energy savings. Early CFL promotional programs, implemented in the early 1990s, targeted the downstream market. Utilities provided a mail‐in or instant rebate for the purchase of ENERGY STAR®‐qualified CFLs. Over time, programs became both more sophisticated and better aligned with natural market forces by transforming incentives from the downstream to upstream market. This transformation allowed CFL manufacturers to lower product cost to retailers while maintaining profit margins for both the manufacturer and retailer. As a result, CFLs that were incentivized by utility programs could be sold at a lower retail price and often in premium shelf spaces, such as end caps and aisle displays. When lower costs were combined with marketing efforts by the utility, retailer, and manufacturer, consumers were motivated to purchase CFLs because they understood the benefits and were willing to pay a marginal increase over the cost of an incandescent. This upstream CFL program model is still used by many utilities, including the California IOUs, to help spur CFL market transformation. 2007 was a banner year for energy‐efficiency and residential lighting. Wal‐Mart announced its intention in late 2006 to sell over 100 million CFLs at its Wal‐Mart and Sam’s Clubs locations in the U.S. during 2007. The company met its goal by the end of September 2007, ahead of schedule.4 Other retailers responded to Wal‐Mart’s CFL campaign by increasing their own stock of CFLs and changing lighting planograms.5 As CFLs became more mainstream, they began to be featured in car and consumer goods 3
U.S. Department of Energy. 2010 U.S. Lighting Market Characterization, Building Technology Program. January 2012. 4
Wal‐Mart Stores, Inc. Press Room. “Wal‐Mart Surpasses Goal To sell 100 million compact fluorescent light bulbs Three Months Early.” Bentonville, Ark., Oct. 2, 2007. http://www.walmartstores.com/pressroom/news/6756.aspx. 5
Planograms are diagrams or models that indicate the placement of retail products on shelves in order to maximize sales. 6 Residential Lighting Solution Pipeline Plan December 2012 commercials that encouraged consumers to be more environmentally conscious and make smarter purchase decisions. During this rapid increase in CFL sales, California mandated increased efficacy for general service incandescent lamps that was to be effective on January 1, 2011. This mandate was a precursor to the passage of the Energy Information and Security Act (EISA) that began in 2012 with the phase out of standard 100‐watt incandescent light bulbs. Over a two‐year period, all medium screw‐base general service lamps manufactured in and imported to the U.S. will be required to comply with specific efficacy mandates. The complete timeline and associated performance metrics are provided below in Table 2. The U.S. is not alone in its mandate for efficiency improvements for general service lamps. Effective in 2009, Australia, the European Union, and Switzerland banned incandescent light bulbs.6 Canada phased out incandescent light bulbs starting in 2012.7 Table 2. EISA Chart8 EISA Effective Dates Incandescent Replaced EISA Replacement EISA Lumen Ranges EISA Minimum Efficacy Ranges 1/1/2012 100 W 72 W 1,490 – 2,600 21 – 36 lm/W 1/1/2013 75 W 53 W 1,050 – 1,489 20 – 28 lm/W 1/1/2014 60 W 43 W 750 – 1,049 17 – 24 lm/W 1/1/2014 40 W 29 W 310 – 749 11 – 26 lm/W While the impact of EISA is still being measured, since 2007 an influx of new, more energy‐efficient lighting technologies have entered the retail market, such as LED and hybrid halogen‐incandescent bulbs. LEDs have been under development for much of the past decade. With advances in technology, LEDs are becoming more feasible for use in general illumination and specific niche applications in the residential market. Performance, quality, lack of awareness, cost, and other types of barriers exist for LED applications (to be explored further for LED recessed downlights in this pipeline plan), but LED technology is improving from early prototypes and is beginning to be introduced to market through the same utility programs that impacted the market for CFLs. The federal government, academia, manufacturers, retailers, utilities and energy‐efficiency program administrators, and energy‐efficiency advocates are very optimistic about LEDs’ market entrance; however, the optimism is also cautious. Many in the residential lighting industry recognize that CFLs were likely made available in the retail marketplace prematurely, before some of their serious flaws had been adequately addressed. These flaws adversely affected, and continue to affect, consumers’ willingness to use CFLs, even now that newer CFL models have overcome many of the early flaws and CFL prices are becoming comparable to incandescent prices. LED proponents do not want to repeat the mistake of prematurely promoting the product, nor do they want the introduction of LEDs to adversely 6
Kanter, James. "Europe's Ban on Old‐Style Bulbs Begins". The New York Times (2009‐09‐01). Retrieved May 2012. 7
Reuters. “Canada to ban incandescent light bulbs by 2012.” Retrieved May 2012. http://www.reuters.com/article/2007/04/25/us‐lightbulbs‐env‐idUSN2529253520070425.
8
Source: Energy Information and Security Act of 2007. 7 Residential Lighting Solution Pipeline Plan December 2012 affect the lighting market as a whole. While barriers to energy‐efficient lighting still exist, such as lack of consumer awareness, consumer preferences, high bulb cost, poor performance, and poor reliability, they are being addressed more holistically by a coordinated market effort that has learned from the experience of bringing CFLs to market. The residential lighting market has clearly made significant advances in energy efficiency over the past decade. It is a considerable achievement that the U.S. has saved 33 TWh while the number of lamps in a home has increased during the same period. Although the future of residential lighting is unknown, two things are certain: CFLs will continue to play a role, and the saturation of LEDs will increase as the 77% of sockets in U.S. homes (DOE, January 2012) with standard incandescent lighting are retrofitted with more efficient lamps. MARKET TRANSFORMATION PROCESS The LMT program works to transform the market through pushing, or “interventions that bring advanced lighting technologies and best practices to the marketplace and support rapid adoption by end users” (California Public Utilities Commission, 2008), while trimming back those substantially adopted by the market or adding them into codes and standards. PUSH In the following Lighting Solution Push section, this document presents:  The lighting technology intended to push into the market, its applications, and the rationale for its inclusion (including energy and non‐energy benefits);  An overview of current programmatic and non‐programmatic efforts;  A discussion of major market barriers, how each of these can be overcome; and  A strategy for the LMT team to implement with key partners, such as manufacturers and industry advocates. TRIM This document’s Lighting Solution Trim section discusses criteria for determine when a lighting technology has been adopted by the market. This includes providing an overview of proposed technologies that may be ready for trimming and the rationale for trimming the technologies. The section concludes by suggesting strategic approaches for trimming. LIGHTING SOLUTION PUSH: LED DOWNLIGHT DESCRIPTION OF LED DOWNLIGHTS AND APPLICATIONS The recessed downlight category encompasses a broad range of luminaires, which share the attribute of being installed above the ceiling and emitting light through an aperture. The market‐wide portfolio of downlights includes products with either round or rectangular apertures that range in width from 8 Residential Lighting Solution Pipeline Plan December 2012 approximately two inches to 12 inches. Common in both residential and commercial applications, they are primarily used to provide ambient illumination; in some cases, they may also be used for accent illumination.9 Recessed downlights are most often installed in kitchens, hallways, bathrooms, and other areas such as media rooms and dining rooms. Figure 1 shows a few example products listed in the ENERGY STAR‐qualified LED lighting list.10 Figure 1. ENERGY STAR Residential LED Recessed LED Downlights11 Conventional residential and light‐commercial downlights—the intended market for LED retrofit downlight units—typically use CFL, incandescent, or halogen lamps. Depending on the specific application, the source may be either an omnidirectional lamp (e.g., A‐lamp, ED17 triple tube) or a directional lamp, such as a reflector (R, BR, ER) or parabolic aluminized reflector (PAR) lamp (DOE, March 2012). Examples of these replacement lamps are shown in Figure 2. Figure 2. Examples of Replacement Lamps for Recessed Downlights12 The light output of a traditional recessed downlight is a function of the lumens produced by the lamp and the luminaire efficiency. Reflector‐style lamps are specially shaped and coated to emit light in a defined cone, while A style incandescent lamps (or A‐lamps) and CFLs emit light in all directions, leading to significant light loss unless the luminaire is designed with internal reflectors. Downlights using non‐
reflector lamps are typically 50% to 60% efficient, which means that approximately half the light produced by the lamp is wasted inside the fixture.13 Figure 3 provides an overview of light dispersion and light loss that is experienced when using omnidirectional light sources. A‐lamps and CFLs suffer from light loss, whereas the covered reflector and recessed downlight maximizes light dispersion. Figure 3 does not include replacement PAR and reflector LED bulbs, which were some of the first LED replacement bulbs to gain market acceptance. 9
U.S. Department of Energy CALiPER Application Summary Report 14: LED Downlight Retrofit Units, Solid‐State Lighting Program. March 2012.
10
ENERGY STAR. ENERGY STAR‐qualified LED Lighting. Revised October 22, 2010.
11
Products from left to right: HALO ML706835, Cree CR6‐575L, and WAC HR‐LED418.
12
Products from left to right: Sylvania Ultra LED PAR30, Greenlite R30, and Sylvania BR30 Reflector Flood. 13
Pacific Northwest National Laboratory. LED Application Series: Recessed Downlights. 2008.
9 Residential Lighting Solution Pipeline Plan December 2012 Figure 3. Downlight Light Dispersion and Light Loss14 LED recessed downlights can either be used as a retrofit product or for new construction, where they are currently becoming more common with builders. With advances in design, LED downlights can retrofit existing line‐voltage recessed downlight fixtures or they can be screwed into Edison‐based sockets. Not every existing recessed downlight application may be retrofitted with LED downlights, but there are currently LED recessed downlights available in the market that meet the needs of existing recessed downlight applications. Recent studies have shown that ENERGY STAR‐qualified LED recessed downlights provide desired color temperature and color rendering with better efficacy than incumbent technologies, including CFLs (DOE, March 2012). RATIONALE FOR PUSHING At this point in the technology commercialization process, LED recessed downlight solutions have been primarily targeted for nonresidential installations at nonresidential price points. Many activities, such as an increasing number of incentives, have focused on overcoming barriers in the nonresidential market sector and most have been successful. The residential market sector has tremendous potential for energy savings in recessed downlights applications and, if its market barriers can be overcome, the long‐
term energy savings potential of LEDs in recessed downlight applications will be very large. ENERGY AND DEMAND BENEFITS LED technology is ready for the residential market sector. When compared to incandescent lighting, the predominant technology used in residential downlight applications, ENERGY STAR‐qualified LED recessed downlights, can decrease energy use by 75% or more.15 With over 800 million downlights installed in the U.S.,16 the annual realized savings if all residential downlights were switched from 65‐watt incandescent to 10‐watt LED exceeds 48,180 GWh,17 which is 14
Ibid.
15
http://www.energystar.gov/index.cfm?c=ssl.pr_why_es_res Accessed October 2012 16
Navigant Consulting. Energy Savings Estimates of Light Emitting Diodes in Niche Lighting Applications. Prepared for Building Technologies Program, Office of Energy Efficiency and Renewable Energy, U.S. Department of Energy. October 2008. 17
Assumes three hours of daily use. 10 Residential Lighting Solution Pipeline Plan December 2012 enough to power 6.8 million homes, or 6% of the nation’s residential housing stock,18 annually. In comparison, the State of California could save over 4,950 GWhs by completing this same retrofit.19 Compared to halogens and incandescents, downlight technology LEDs have better efficacy. Efficacy measures a lighting product’s efficiency by dividing its lumen output by its wattage. The higher a product’s efficacy, the more energy efficient it is. Currently, LED and fluorescent downlights are equal in efficacy, but LED downlights may surpass fluorescents after more extensive research and the development of an improved manufacturing processes that increase lumen output while lowering wattage. Since they can be integrated with controls, LED downlights could be used as a demand‐response tool to lower peak demand. LEDs are manufactured with components that make control feasible and easy, through convenient applications such as tablets, mobile phones, and home control systems. Utilities could consider controlling LEDs in a home through Smart Grid technologies that respond to peak demand reduction needs. As manufacturers, lighting designers, and utilities continue to learn about the potential of LED technology, this use may be pursued more aggressively. NON‐ENERGY BENEFITS In addition to robust energy savings, LED downlights provide many non‐energy benefits over incumbent technologies. These are:  Product Performance: Several experts we interviewed to develop these pipeline plans agreed with one who said, “the first success of LED lighting was LED downlights.” LED downlights are instant‐on and come to full brilliancy immediately, unlike fluorescent technology. LEDs are rated for a long life that often surpasses 25,000 hours‐of‐use, whereas halogen and incandescent downlights are typically rated for 1,000 hours. LED downlights are designed with heat sinks that allow for better management of heat generation, which is often the cause for early burnouts in incandescent, halogen, and fluorescent technology. Like halogen and incandescent technology, many LED downlights are fully dimmable to light levels less than 5% of total lumen output. LED light output (and efficacy) increases as operating temperatures drop (DOE, January 2012), in contrast to fluorescent technology.  Light Quality: LEDs downlights provide better quality light and light dispersion than incumbent technologies. The beam angle20 of LED downlights varies from product to product, but generally is wide enough to provide equal light distribution for ambient lighting. LED downlights emit a light similar in appearance to the correlated color temperature (CCT) commonly associated with incandescent technology that consumers desire (2,700 K). The light quality, or color rendering index (CRI), for a sampling of LED downlights measured recently through Commercially Available LED Product Evaluation and Reporting (CALiPER) testing was greater than or equal to 80 CRI (DOE, March 2012), which is the benchmark used by ENERGY STAR for qualifying eligible replacement lamps.  Functionality: In contrast to incandescent, halogen, and fluorescent technologies, which have reached the limit of further development, LED downlights have not yet realized their full 18
U.S. Census. Total Housing Inventory for the United States: 1990 to 2010, Table 982. 2012. 19
Assumes 11,502,870 households replacing an average of seven incandescent recessed cans to LED and three hours of daily use: ((Total California households/Average recessed downlights in U.S. home)* 55 watts * 1,095 hours)/(109 watt hours/Gwh) 20
The degree of width that light emits from a light source. 11 Residential Lighting Solution Pipeline Plan December 2012 
potential when it comes to control, custom light appearance, and design. LED recessed downlights are still too new to assess how the market will adapt to its various options; however, there are several implications on how they may transform. According to experts we interviewed for this pipeline plan, in the future LED downlights will be integrated into controls used by consumers, building operators, and utilities. Further market research for LEDs may determine a custom CCT, or light appearance, for specific applications; this appeal to customer satisfaction could increase the adoption of LED technology. LED technology is malleable and can be adapted for virtually any market need. As a result, lighting manufacturers are producing LED downlights that meet the demands of the new construction and retrofit markets. Manufacturers offer integrated replacement fixture trim kits and replacement lamps for retrofitting existing downlight applications, and they offer integrated hardwired trim kits for new construction. Health and Safety: LED downlights do not contain mercury or other toxic materials. Mercury is a component of fluorescents, which has prohibited some consumers from supporting that technology. Since LEDs manage heat generation better, there is less risk of fire compared to incandescent or halogen technology, which both waste large amounts of energy as heat. OVERVIEW OF CURRENT EFFORTS This section is organized by programmatic (utility program) and non‐programmatic (non‐utility program) efforts. OVERVIEW OF CALIFORNIA PROGRAMMATIC EFFORTS In 2007, IOUs learned about LED recessed downlights as a potential energy‐efficiency opportunity through various conferences, tradeshows, and journals. At that time, the market barriers for LED technology were a lack of information, high cost, and performance uncertainty. SCE project managers and engineers gathered technical information through meetings and demonstrations with product manufacturers. Some manufacturers allowed SCE to conduct one‐off tests of products at the Southern California Lighting Technology Center (SCLTC). Concurrently, the SCLTC was evaluating LED recessed downlights. Over time, product performance improved to the point it merited an Emerging Technology (ET) assessment project. SEC initiated this project, SCE ET 07.15 Residential LED Downlighting, in 2007 to fully evaluate the performance of the hardwired and screw‐based replacement lamp technology in a laboratory setting and provide additional data on residential kitchen lighting use. During the assessment, SCE shared the performance information with ENERGY STAR to support its development of criteria for LED technologies. SCE published the performance data from the ET assessment, completed in 2009, that same year in an Interior LED Downlight Fixtures work paper. The assessment concluded that many lamps did not emit sufficient lumens for consideration as a replacement lamp. In addition, several products that were tested failed prematurely. LED downlight quality has improved substantially since this ET assessment was completed; LEDs are now similar in efficacy to CFL applications and have a decreased failure rate. To validate these improvements in LED downlight technology, scaled field placement pilots have been scoped in 2012 for recessed downlights, specifically targeting residential and commercial applications. The California Energy Commission (CEC) and its partners conducted other LED downlight demonstration projects during the implementation of the ET assessment project. The ET project, work paper, CEC 12 Residential Lighting Solution Pipeline Plan December 2012 demonstration projects, and ENERGY STAR criteria have helped establish information and performance certainty for SCE’s incentive programs. Following the completion of the work paper, SCE added LED recessed downlights to its Commercial, Industrial, and Agricultural Calculated Incentives Program to help overcome the market barrier of LED’s high initial cost. However, the structure of the Calculated Incentive Program limited LED measure adoption because it required many steps to receive incentives. In 2010, to overcome this program transaction cost barrier and to help increase the measure adoption rate, SCE incorporated LED technology into the IOU Commercial, Industrial, and Agricultural Deemed Incentives Program. The Express Solutions Program, a deemed program that provides an incentive for the installation of qualified LED downlights, currently has the best participation among contractors and other trade allies because of the ease of receiving incentives. These contractors and trade allies, who work with the many businesses that retrofit lighting and make other efficiency upgrades, benefit from SCE’s continuing outreach and training opportunities. Early in 2012, the Resource Conservation District of Greater San Diego County and SDG&E’s ET subprogram conducted an assessment project to evaluate downlight LED technology. This assessment project will assist offices to determine the applicability of LED recessed downlights for general illumination. The project’s goal is to determine the energy savings potential of downlight LEDs as the source for general illumination lighting compared to the standard Title 24‐2008 base‐case fluorescent in a small office setting. Quantitative light and electric power measurements recorded a 16% reduction in energy usage and demand with LED luminaires compared to the lighting power density (LPD) requirement for office space illumination per Title 24‐2008. Table 3 below compares the product performance using manufacturer data, the project’s measured data, and the CALiPER testing data, which shows variance in energy consumption and color appearance. These variances show why in situ testing is important for LEDs in comparison to lab testing. In situ testing provides a more realistic forecast of performance attributes. Table 3. LED Downlight Performance Data* Manufacturer Measured CALiPER 07‐47 Power (W) 10.5 11.8 10.8 CCT (K) 3,500 3,377 3,402 Power Factor >0.90 0.98 0.97 *LMT Program Staff. LMT Pipeline Plan updates, DRAFT version. May 2012. Any decision to select LEDs must consider design, functionality, and occupant behavior; acceptance and tolerance of an emerging light source technology; luminaire quality; and the economy. Because each situation is unique, project managers must exercise due diligence in determining the appropriateness of LEDs for general illumination, luminaire selection, lighting design, and layout. This assessment demonstrated that LED recessed downlights deliver lighting power densities that meet or exceed Title 24 requirements. The results of this project attest to the leaps in technological enhancements of LED luminaires. However, the main barrier to significant market adoption is the high initial cost when choosing LEDs as the general illumination ambient lighting in new construction. Incentives offered by 13 Residential Lighting Solution Pipeline Plan December 2012 utilities in the short‐term could help to reduce the initial costs for customers to be early adopters of this new LED technology. The IOUs have provided a $30‐per‐unit incentive for ENERGY STAR‐qualified recessed downlights in their core commercial programs since the beginning of the 2010‐2012 program cycle. Since the 2011 LMT report submission, the IOUs have evaluated LED technology for possible inclusion in the Upstream Lighting Program, which benefits the residential market. Currently, SCE and PG&E are both conducting an incentive‐level pilot test with mass market retailers in their service territories to determine seasonal product price elasticity and to establish the most impactful incentive level. Both pilots track weekly sales data for six different price points for LED applications in geo‐clusters that represent different demographics. A report on the effectiveness of the incentives will be available in late 2012. Because high price is often cited as the largest barrier to market adoption of LED downlights, this pilot will help inform future residential LED upstream incentive programs. The next largest barrier after high price is lack of awareness of LEDs and how they work, according to preliminary results from consumer focus groups. Cadmus conducted more complete surveys in spring 2012 with consumers who were divided into two groups: (1) those not educated about LEDs and (2) those educated about LEDs. Those who were not educated about LEDs attended a focus group to answer questions about their experiences with LED products. Those who were educated about LEDs received eight types of LEDs to test at home; then we surveyed them on their preferences. A final report of these results will be available late 2012. In addition to market research, the utilities throughout California are collaborating on a joint education campaign to educate their customers on changes in the lighting industry. In the past, educational efforts for lighting have been too general for energy‐efficient lighting. This campaign will be more focused on the types of lamps available, differences between lumens and watts, the best application for a specific lamp or technology, how to read the Lighting Facts Label, and many other lighting‐related questions. NON‐PROGRAMMATIC EFFORTS Both the lighting and energy‐efficiency industry have been heavily involved in shaping the landscape for LED downlights by implementing programs that emphasize quality and performance expectations and deliver training and education. The DOE, ENERGY STAR, and North American Electrical Manufacturers Association (NEMA) have helped advance the quality and adoption of LED downlights through such programs as those detailed below:  CALiPER Program: The DOE CALiPER program uses industry‐approved procedures to test a wide array of solid‐state lighting (SSL) products available for general illumination. CALiPER test results (1) guide DOE planning for SSL research, development, and market introduction activities, including ENERGY STAR program planning; (2) support DOE GATEWAY demonstrations and technology procurement activities; (3) provide objective product performance information to the public in the early years, which helps buyers and specifiers have confidence that new SSL products will perform as claimed; and (4) guide the development, refinement, and adoption of credible, standardized test procedures and measurements for SSL products.21  LED Lighting Facts®: The DOE LED Lighting Facts is a program that showcases LED products for general illumination from manufacturers who commit to testing products and reporting 21
U.S. Department of Energy. “Solid State Lighting: CALiPER Program.” Last Updated May 16, 2012. http://www1.eere.energy.gov/buildings/ssl/caliper.html. 14 Residential Lighting Solution Pipeline Plan December 2012 performance results according to industry standards. For lighting buyers, designers, and energy‐
efficiency programs, the LED Lighting Facts Label provides information essential to evaluating products and identifying the best options.22 The biggest success of the LED Lighting Facts program was the creation of the Lighting Facts Label, which resembles a food nutrition label and describes such features as lumens, efficacy, and CRI. A sample label is shown below in Figure 4. Figure 4. LED Lighting Facts Label23 The Federal Trade Commission (FTC) modified this Lighting Facts Label that, effective January 2012, is mandated for use on general service replacement lamps. A sample of the FTC’s Lighting Facts Label is shown below in Figure 5.24 Figure 5. FTC Lighting Facts Label 22
U.S. Department of Energy: LED Lighting Facts. “Success with solid‐state lighting.” http://www.lightingfacts.com/. 23
U.S. Department of Energy: LED Lighting Facts. “Anatomy of the Label.” http://www.lightingfacts.com/default.aspx?cp=label.
24
Bureau of Consumer Protection Business Center. “The FTC ‘Lighting Facts’ Label: Questions and Answers for Manufacturers.” Last modified April 2011. http://business.ftc.gov/documents/bus26‐labeling‐your‐light‐bulbs‐
lighting‐facts‐questions‐and‐answers‐manufacturers. 15 Residential Lighting Solution Pipeline Plan December 2012 
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The difference between the FTC and DOE versions of the Lighting Facts Label is that the DOE’s version was developed primarily for LED applications, whereas the FTC’s version was developed for all general service replacement lamps. Regardless, both Lighting Fact Labels provide consumers with necessary information about the lighting products, which aides them in making an informed purchasing decision. Other DOE Efforts: The DOE conducted other programs and initiatives to support the development of LED technology; these include offering frequent workshops, seminars, and a Technical Information Network for Solid‐State Lighting (TINSSL) program;25 and spurring research and development efforts through the L‐Prize competition and GATEWAY demonstration programs.26,27 While all of these efforts may not have directly impacted the growth of LED downlights, they are important due to the DOE’s strong influence, and success, in bringing quality SSL products to market in the U.S. ENERGY STAR: ENERGY STAR introduced its specification for LED recessed downlights in 2008, through version 4.2 of the residential lighting fixture specification. Currently, there are 311 ENERGY STAR‐qualified LED recessed downlight fixtures on the qualified products list.28 ENERGY STAR is working on a new specification for lamps, which will cover LED replacement PAR and BR lamps used in downlight fixtures. In addition to its work on specifications, ENERGY STAR oversees a rigorous third‐party testing program for all of its products. CEC: The CEC is currently working with technical experts, utilities, and lighting industry representatives on a voluntary quality standard for LEDs. The IOUs support the concept of the LED quality specification to improve LED quality in the market. NEMA: In an effort to tackle the dimming issues associated with LED downlights installed on incompatible circuits, NEMA is working with its members to set a standard to ensure that LED downlights will work on any dimmer when installed regardless of the dimming circuit. Lighting for Tomorrow Program: Similar in approach to the L‐Prize program in encouraging innovation for new LED product design, the Consortium for Energy Efficiency (CEE), in partnership with the American Lighting Association, administers an annual design competition—
the Lighting for Tomorrow Program.29 In 2010, a category for LED downlights was added to the program as a specific fixture design category to help spur the development of LED downlights. Several of the past winners are having success at retail and are included in utility incentive programs. Manufacturer Education Efforts: LED manufacturers such as Cree, Philips, General Electric, and Sylvania have invested heavily in educating their customers and training contractors on the advantages of LED technology. One example of a manufacturer’s commitment is Cree’s LED Revolution campaign. This campaign is dedicated to educating Cree’s current and potential customers about its LED technology and to marketing current installations and major projects 25
U.S. Department of Energy. “Solid‐State Lighting: Technical Information Network.” Last Modified February 27, 2012. http://www1.eere.energy.gov/buildings/ssl/technetwork.html. 26
U.S. Department of Energy. “Transforming the Lighting Landscape.” Last Modified March 20, 2012. http://www.lightingprize.org/. 27
U.S. Department of Energy. “Solid‐State Lighting: Solid‐State Lighting GATEWAY Demonstrations.” Last Modified May 20, 2011. http://www1.eere.energy.gov/buildings/ssl/gatewaydemos.html. 28
ENERGY STAR. “Light Fixtures for Consumers.” http://www.energystar.gov/index.cfm?fuseaction=find_a_product.showProductGroup&pgw_code=LU. 29
Lighting for Tomorrow. “Lighting for Tomorrow Competition Celebrates 10th Year.” Last Modified September 12, 2012. http://www.lightingfortomorrow.com/.
16 Residential Lighting Solution Pipeline Plan December 2012 throughout the U.S.30 Through efforts by manufacturers, information and trainings on LED downlights are becoming more readily available and help to ensure a higher percentage of quality installations. The non‐programmatic efforts listed above are a small portion of the ongoing effort by the government, manufacturers, retailers, designers, and advocates to ensure that quality LED downlights are in the market and that appropriate education and training exists so consumers understand the benefits of the technology. In order to fully accept LED downlights, members of the supply chain need to continue to coordinate and support one another. OVERVIEW OF MAJOR MARKET BARRIERS LED recessed downlights provide many energy and non‐energy benefits, but many market barriers limit their mass adoption. The following are considered to be the major market barriers and are presented with some of the major questions that need to be answered to assist in market adoption:  Product Performance and Quality: How can manufacturers improve performance and ensure the quality of each LED downlight sold and installed? How does one manufacturer with a high‐
quality product separate itself from a manufacturer with a low‐quality product at retail?  Cost: Will consumers make a trade‐off between low price/short life to high price/long life when lighting has traditionally been a low‐involvement purchase decision?31 How will consumers adapt to a comparatively high price for LED downlights?  Customer Awareness and Perceptions: What is the impetus for a consumer to move away from incandescent lighting when this technology has been accepted for so long? Why should a consumer care enough about LEDs, or any lighting, to be educated about its technology and benefits? If these market barriers and associated questions that encapsulate the issues deterring market adoption of LED recessed downlights can be addressed successfully, the likelihood of transforming the recessed downlight market with LED technology increases substantially. Figure 6 presents the market barriers and some associated activities that can help to overcome them. 30
Cree Inc. “Lighting the LED Revolution.” http://www.creeledrevolution.com/. 31
Low‐involvement purchase decisions involve a low expenditure or personal risk, and are habitual (e.g., soft drinks, toilet paper).
17 Residential Lighting Solution Pipeline Plan December 2012 Figure 6. Associated Activities to Overcome LED Recessed Downlight Market Barriers SCE and the California IOUs have already been involved in many of these activities in an effort to introduce LED recessed downlights to market. A more comprehensive approach will be detailed in the summary section. MARKET BARRIER: PRODUCT QUALITY AND PERFORMANCE Advances in technology have solved some of the early problems LED recessed downlights experienced when they first entered the market in 2008 and started competing against incumbent technologies. Although there have been many subsequent technological advances, there are still quality and performance issues that need to be addressed, as listed below:  Lumen Depreciation: LED recessed downlights differ from incumbent technologies because they do not burn out; instead their brightness depreciates over time and eventually passes the point of producing useful light output. A testing procedure was developed to test LEDs for lumen depreciation by the Illuminating Engineering Society of North America (IESNA), titled IES LM‐80 Measuring Lumen Maintenance of LED Light Sources (LM‐80). LM‐80 also addresses harmonic distortion, the output of voltage that could impair the LED applications driver.32 One drawback of LM‐80 testing is that it provides no determination or estimation of expected life or lumen output beyond test data (DOE, May 2009), making it challenging to determine the actual lifetime of the LED application tested. A separate test, also developed by IESNA, titled TM‐21, addresses the estimation of actual lifetime for tested LED products. TM‐21 specifies lumen maintenance behavior for LED products intended for illumination applications;33 these include LED recessed 32
U.S. Department of Energy. “Understanding IES LM‐79 & IES LM‐80.” PowerPoint Presentation at LightFair Exhibit, May 5‐7, 2009. Presented by Eric Richman, Pacific Northwest National Laboratory. Available online: http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/lightfair8_richman‐ies.pdf. Retrieved May 2012. 33
Philips Lumileds (Mark Hodapp). “IESNA LM‐80 and TM‐21.” PowerPoint Presentation at the Municipal State Street Lighting Consortium, Tampa, Florida. 2011. Available online: http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/msslc‐se2011_hodapp.pdf. Retrieved May 2012. 18 Residential Lighting Solution Pipeline Plan December 2012 
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downlights. LM‐80 and TM‐21 testing were made a part of the ENERGY STAR specification requirement to ensure that only quality LED products are qualified. While many manufacturers test their products using LM‐80 and TM‐21, not all do, which could result in premature lumen depreciation and lead to consumer dissatisfaction. Components: LED recessed downlights are made of several components that, if assembled incorrectly, can adversely impact product performance. Components in LED recessed downlights include LED chips or diodes, a circuit board, lens, fixture housing, heat sink, driver, and power supply. In addition to poor assembly, poor quality components will lessen the overall bulb quality and lifetime. There is no guarantee that manufacturers will continue to use all of these components in recessed downlights in the future. There could be a shift to consumers demanding a fixture that is compatible with replacement lamps or other alternatives, which could benefit LED technology, but negatively impact the market for LED recessed downlights. Binning: The binning34 of LEDs is a practice used by LED manufacturers to manage the variation of LED performance in mass production processes. The inefficiencies of binning may create vulnerability in the supply chain for the market. To reduce the risk, LED manufacturers often choose binning schemes in accordance with their specific or unique mass production process. As a result, the LED components or packages produced by the manufacturers maintain structured variations for their performance characteristics. Because of the uniqueness of the mass production and quality control process used by each LED manufacturer, the LED products supplied to LED system integrators or assemblers (module makers, luminaire makers, etc.) with similar performance characteristics produced by different manufacturers are binned and labeled differently. The binning structures and labeling (marking) varies from manufacturer to manufacturer. This inconsistency in binning structure requires more effort by LED system integrators and assemblers. More unnecessary testing, verifications, qualification, and validations processes have to take place, which hampers productivity35 and can increase the price of an LED application. Heat: To provide the light output typically expected for downlights, multiple LEDs must be grouped together. This clustering generates heat, which requires good thermal management in the fixture. If the fixture temperature rises too high, the LEDs’ light output will fall and their life will be shortened. Thermal management is especially critical in insulated ceiling applications, where fixture temperatures can be much higher than in other applications.36 While advanced technology has allowed manufacturers to produce LED recessed downlights that do not fail from overheating, there are still commercially available products with inadequate heat management. Dimming: LEDs provide much smoother and more consistent dimming than dimmable CFLs; however, it is important to identify standards for dimming to ensure compatibility between the LED driver and a dimmer switch. This issue is being addressed, but according to experts we interviewed for this paper, consumers do not understand the differences in dimming switches and that they are not compatible with all technologies and various brands. In addition, there are consistency issues with dimmer switches that need to be addressed. A wide variety of dimmer switches are capable of dimming LEDs down to 15% of full light output; select others are capable 34
Binning is a process designed to maximize effective utilization in the production of LEDs that has implications on product performance, cost, and lead‐time. 35
PennWell Corporation. “NEMA publishes white LED binning standard (SSL 3‐2010).” LEDs Magazine. April 15, 2010. http://www.ledsmagazine.com/news/7/4/17. 36
Broderick, James. Are LEDs ready for recessed downlight applications? May 2007. 19 Residential Lighting Solution Pipeline Plan December 2012 of dimming LEDs down to 5%.37 Manufacturers of both LED and lighting controls need to ensure that they are developing LED recessed downlights that are capable of dimming to 5% to meet the needs of consumers.  Market Availability: As noted above, there are 311 ENERGY STAR‐qualified LED recessed downlights on the qualified product list. While that is a significant number of testing and third‐
party verified products, many poor quality products are still in the market. Imitators develop LED recessed downlights using cheap components to lower the price and take advantage of consumers who are not knowledgeable on LED technology. Consumers, contractors, builders, and designers need to be aware that not all LED recessed downlights are quality or perform well. This is an education need, but important to note when discussing quality. Although these issues are being addressed through enhanced testing protocols and market intervention, there is no guarantee that quality can be ensured for every LED recessed downlight manufactured. SOLUTION The short‐term solution to product and quality issues is simple: utility and lighting efficiency programs need to continue their concerted support of the efforts of ENERGY STAR, NEMA, and DOE in addressing performance and quality issues for LED recessed downlights. Incentive programs depend on quality, market‐ready products in order to be successful and claim energy savings. To date, these efforts have resulted in an energy‐efficient product standard for LED recessed downlights, testing protocols for ensuring product quality and performance, third‐party testing programs to verify that protocols are met and exceeded, and a listing of qualified LED recessed downlights that utility and efficiency programs use as a basis of eligibility for program participation. While the groundwork in verifying quality and performance for the LED recessed downlight market has been laid, there is still more that needs to be addressed. 1. Continue to improve on the actions taken to address lumen depreciation, binning, heat maintenance, and dimming. More stringent testing protocols and further industry coordination is needed for continued improvement in addressing the quality and performance issues hindering the further growth of LED recessed downlights. Participation in DOE SSL roundtable meetings is a way to be aware of improvements in the industry and also to advocate for specific efforts concerning quality and performance issues that are not being addressed properly. 2. Use best practices to control quality at retail. While SCE and other IOUs can control which products they incentivize through their programs, they cannot control which products are stocked in a retail location. Marketing and education campaigns help inform consumers of the differences in quality between ENERGY STAR LED recessed downlights and imitator products and, specifically, how purchasing an imitator LED recessed downlight, or even incumbent technology, can reduce the return on their investment. Coordination with builders and contractors who purchase in bulk is necessary as well. If possible, pursue ways to creatively offset, or at least close the gap, between the price of LED recessed downlights and poor quality LED or incumbent recessed downlights. One method could be offering a bulk purchasing program for large orders. The frequency of these transactions would be easy to track since they typically occur at lighting distributors and contractor showrooms. It should be noted that the industry can do everything right and the product can still fail because consumers could opt for a lower‐cost alternative. 37
Pacific Northwest National Laboratory. Demonstration of Recessed Downlight Technologies: Power and Illumination Assessment. November 2009.
20 Residential Lighting Solution Pipeline Plan December 2012 3.
Determine a holistic approach to address controls. There is a great opportunity for designing compatible, cost‐effective controls for LED lighting. With the advent of apps and the ease of networked systems, it will be only a matter of time before an app is developed that can control light sources from a smart phone, tablet, and television that is cost‐effective enough to gain market traction. LEDs are the perfect technology for controls since its electronic components are sufficiently malleable to change for various consumer needs. Lighting controls manufacturers have solutions for LED recessed downlights, but at present they are too expensive for most consumers. Dimming controls, which are already available for LED recessed downlights, need to be consistent from one dimmer to the next and compatible with the fixture components. MARKET BARRIER: COST The greatest barrier to increasing market adoption is the cost of LED recessed downlights, which average between $50 and $80 per unit, without any utility incentives. In comparison, incandescent recessed can lights cost up to $35 per unit, with many available for $20 or less. Although the IOUs offer a $30 incentive on LED recessed cans through their commercial programs and are currently piloting different price points for their residential programs, it is hard for a consumer to justify purchasing a product that costs twice as much. The issue of high cost has been addressed before for energy‐efficient residential lighting. When CFL programs began, cost was one of the major barriers. Over time, prices decreased as CFL saturation increased. The same assumption can be made for LED recessed downlights: as saturation increases, price will decrease. The major difference, however, is that CFLs are priced at a level considered to be a low‐involvement purchase decision. The opposite is true for LED recessed downlights: their comparatively high cost makes them a high‐interest purchase, which means the purchase is planned and not habitual. Consumers are not used to perceiving lighting as a high‐interest purchase category. SOLUTION IOUs are aware of the cost issue with LED downlights and are already testing upstream incentive strategies to address the high price through pilot studies at retail. Results of the pilot studies will help the IOUs develop a comprehensive pricing strategy and new tactics to address the high cost. Although IOUs have been proactive in addressing high cost for LED recessed downlights, there is still more that should be considered. 1. Continue to increase the affordability of quality LED recessed downlights in the retail market by providing reasonable upstream incentives to offset the initial high price. To put it simply, utility program incentives help ease market adoption. Utility and efficiency programs nationwide that support LED recessed downlights have reported success when they can offer a reasonable incentive, perhaps no more than 50% of the regular retail price, on a quality product to offset upfront cost. According to the CPUC proposed decision (12‐07‐001), the IOUs are encouraged to incentivize LED products that are in the “top half of the products available on the market” to make them a more appealing choice for consumers and builders. The CPUC guidance indicates the most important indicators of quality are light output and color rendering. Once the CEC’s Quality Standard for LEDs is developed, then the utilities may only offer incentives for screw base LED products that conform to the standard, as stated in D.12‐05‐015. 2. Avoid short‐term deep incentives to spur market adoption. Pricing is important for many reasons. If incentives are applied that lower the retail price to an unreasonable cost (e.g., IOUs 21 Residential Lighting Solution Pipeline Plan December 2012 provide a $50 incentive to make the retail price less than $10), the integrity of the product may be questioned and cause long‐term negative effects, not to mention that the incentive program will be unsustainable given the incentive per unit. If consumers become used to low prices for LED recessed downlights and then prices rise once incentives are decreased or lifted, they may no longer support the technology and instead purchase incumbent technologies. 3. Shift the consumers’ purchasing interest from low to high by encouraging long‐term thinking about lighting. It is important for consumers to understand the benefit of long‐term thinking when it comes to LED recessed downlights. Like all new products, price will decrease over time as the market stabilizes, competition increases, manufacturers achieve economies of scale, and consumers become educated about LED recessed downlights benefits and how the product fits their needs. For LED recessed downlights to succeed, consumers must change from their habitual low‐involvement purchase behavior. Unlike the purchase of CFLs, when consumers decide to design with LED recessed downlights, they need to think the same way they would when purchasing an appliance. Changing consumers’ purchasing perspective from low to high interest will require extensive marketing and educational campaigns on the benefits of LEDs, training on LEDs return on investment, and a realistic price reduction through incentives. Focus groups and other research methodologies can help determine what messages and tactics will appeal to the IOUs’ diverse customer base. MARKET BARRIER: CUSTOMER AWARENESS AND PERCEPTIONS Lighting has been such a low interest product category void of change for so long that, although there is buzz about LEDs, consumers are still comfortable with incandescent technology. CFL programs have revealed that consumers want the same color appearance, functionality, and cost as incandescent light bulbs. These features are also being addressed for LED recessed downlights. As with CFL programs, there are likely to be the same challenges to converting consumers to LED recessed downlights. Additionally, IOU customer research suggests that residential customers’ views of new lighting technologies, such as LEDs, have been tainted by prior experiences with poor quality CFLs. Below are several more barriers regarding customer awareness and perceptions:  Lack of consumer awareness of LED recessed downlights and their benefits: Consumers are aware of LEDs, but not in general illumination applications such as LED recessed downlights. What consumers do hear about LEDs differs from one source to the next. A fundamental need is quality education about lighting in terms that consumers can understand, avoiding jargon and unnecessary words and concepts.  Lifetime and warranty: According to experts we interviewed for this pipeline plan, IOU customers do not care about the long lifetime and warranty provided by LED recessed downlights. Currently, long life is the greatest benefit for LEDs since their energy savings is comparable with fluorescent technology, and their light quality is still comparable with halogens. Finding other benefits outside of long life and warranty that do not appeal strongly to consumers may be challenging until the technology has been improved to substantiate other messages.  No information on proper installation: LED recessed downlights are made easy enough for a consumer to install, more so in comparison to incumbent technologies, but many consumers may have never installed a recessed downlight. Consumers are used to replacing lamps for their halogen or incandescent recessed downlights, but the fixture housing of LEDs may be more complicated for consumers who want to retrofit their existing recessed downlights. Retrofitting 22 Residential Lighting Solution Pipeline Plan December 2012 LED recessed downlights that are not an integrated fixture and replacement lamp may be an easier task for a consumer to complete.  Lack of relevant market data: Market data help consumers make informed purchasing decisions. Since the cost of LED recessed downlights is much greater than the competing incumbent technology, consumers may conduct their own research to determine which product they will purchase, the products’ benefits and attributes, the best pricing, etc. For a consumer, any lack of information on performance and installation for a new product may make it difficult for them to justify purchasing LED recessed downlights. Market data will also help IOU staff determine penetration rates for LED recessed downlights and serve as a benchmark for future programming efforts. SOLUTION Education is paramount in raising consumer awareness and acceptance for LED recessed downlights. Customers need assurance that LEDs are a good choice and will perform well. The entire supply chain, from the manufacturer to the consumer and installer, needs to convey appropriate information about LED recessed downlights, without hype, so consumers will have reasonable expectations for the technology that can be met. 1. Increase the visibility of the benefits of LED recessed downlights through many information channels. Consumers need to be educated on the benefits and potential for LED recessed downlights using every available consumer touch point. They also need assurance that these benefits are real and that they can depend on LED products. Existing resources, such as Energy Education Centers should incorporate information on LED recessed downlights into their training curricula. Online lighting catalogs should list the energy and non‐energy benefits of LED recessed downlights to educate about and entice consumers to purchase them. Targeted marketing efforts to home builders and contractors should be leveraged to promote the benefits, as well as the available incentives for LED recessed downlights; builders and contractors may see the financial benefit and incorporate LED recessed downlights into their home lighting packs. A coordinated effort that reaches each market segment using the most appropriate tactics needs to be devised and implemented strategically. 2. Conduct additional market research to understand what consumers want for lighting so it can be provided. IOUs are already conducting focus groups that cover consumer preferences for LEDs, but more research, such as additional focus groups, conjoint studies, and customer satisfaction surveys, are needed to determine how consumer preferences change after the benefits and options of LED recessed downlights are realized. The energy savings potential for LED technology is substantial, but to help direct the development of this technology, consumers need to be asked how they would use lighting in the future. LED recessed downlights can be networked and controlled through smart phones and tablets, and there are many other potential opportunities for new applications. 3. Leverage the supply chain to determine market needs. Continuous and comprehensive feedback and communication are needed from all aspects of the supply chain, such as manufacturers, retailers, installers, builders, and consumers, so that programs for LED recessed downlights can be constructed and revised to ensure that products are meeting consumer expectations with no disruption in the supply chain. Creating partnerships in the supply chain can introduce consumers to LED technology in places where they feel comfortable, such as retail and grocery stores that currently use LEDs in many of their displays. Open houses, home shows, building expositions, and other demonstration opportunities are also places to introduce consumers to LED recessed downlights, especially given their popularity in the new construction 23 Residential Lighting Solution Pipeline Plan December 2012 market. The more the IOUs can leverage their supply chain partners to educate consumers on the benefits of LED recessed downlights and collect feedback on aspects such as performance, consumer preferences, stocking and sales, and ease of installation, the easier it will be to make changes to program strategies and advocate for changes with the product to meet the needs of the end user. SUMMARY OF PARTNERS AND IMPLEMENTATION ACTIONS Industry‐wide collaboration is needed to address the barriers that exist for LED recessed downlights. Every market actor has a role, as detailed below.  Manufacturer: Manufacturers play a pivotal role in producing high quality products. ENERGY STAR certification can make it easier for consumers, builders, and contractors to identify high quality products. Competitive manufacturers will continue identifying and implementing new methods for producing high‐quality LED recessed downlights while lowering the cost of goods sold. Fixture manufacturers can also work with lighting controls manufacturers to ensure LED recessed downlights are compatible with dimming circuits. Continued manufacturer and industry coordination with NEMA is necessary to overcome this issue. Manufacturers also play an important role in educating customers on how to pick the right product and properly install it.  Retailer: Retailers play a key role in market transformation through offering a selection of high quality LED products to customers at competitive prices. Retailers should receive information on which LED recessed downlights are the best for their customers so they can factor this into stocking decisions. Ideally, this information comes from a third party, such as ENERGY STAR, DOE, or IOUs, that has no financial interest in providing this information. Retailers can help educate customers by: displaying LED products in readily accessible areas of their store with point‐of‐sale signage; providing recessed downlight demonstration displays that compare the quality between incumbent technology and LEDs, and videos or other interactive tools; and training their sales staff on the benefits of LED recessed downlights.  Installer: Installers, such as contractors, electricians, and builders, should receive information on how to select the best quality LED recessed downlights, and then communicate this information to their customers when advising them on product selection and options for dimming and controls. Furthermore, installers should learn about incentives available to customers in their region, and the utility incentives should reinforce installer recommendations by requiring the highest quality products. If additional market research indicates installers’ limited experience with LED downlights is a barrier, then installation training could increase their confidence and quality of installations. Installers have an important role in providing feedback to their distributors as well as manufacturers, if applicable, on experiences with LED recessed downlights, both good and bad, so they can be addressed throughout the supply chain.  Lighting Designers: Lighting designers who understand the benefits of LED recessed downlights, both their performance and aesthetics, are more apt to include them in their design plans and will be better prepared to explain their recommendations to customers. Designers can go a step further by incorporating applicable utility incentives into their cost proposal. Lighting designers, who specify work for both the residential and commercial markets, are in a strong position to provide helpful feedback to manufacturers on improving product specifications and design, influencing the next generation of products and their applicability in specific building applications. 24 Residential Lighting Solution Pipeline Plan December 2012 
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Efficiency Advocates: Efficiency advocates, such as California Institute for Energy and Environment, California Lighting Technology Center (CLTC), CEE, Natural Resources Defense Council, and even some industry groups (such as NEMA), support market transformation efforts for LED downlights through conducting studies, advocating for policies encouraging efficiency and industry standards, and disseminating best practices. Utility, efficiency, and government programs can leverage advocates’ knowledge and resources to support the transition to LEDs, specifically LED recessed downlights. For example, lighting advocates are in a position to help develop educational materials that resonate with different market actors. Messaging that will effectively appeal to consumers may be different from what is currently used. PG&E conducted focus groups with consumers and learned that long life and warranty are not strong selling points for LEDs; this contrasts with the current practice of using these properties as a key message for the majority of marketing and communication materials for LED recessed downlights. Government Programs: Government programs, such as ENERGY STAR and DOE’s Building Technologies Program, have made LED technology a commercial reality by coordinating with lighting advocates, manufacturers, retailers, utilities, and other members of the supply chain. Not only have government programs built a strong foundation for LED recessed downlights, they continue to push for better quality products through more stringent manufacturing specifications. Another important role for government programs is that of watchdog. Through third‐party verification testing programs, LED recessed downlights are rigorously tested to determine if they perform as advertised. Without these programs, there is no quality assurance for LED recessed downlights outside of in‐house testing by manufacturers, which may not be sufficiently comprehensive. Furthermore, government programs can be an ideal vehicle to provide messaging on the benefits of LED downlights. Information should come from one credible source instead of many to minimize market confusion, and the message should be clear and consistent in order to resonate with consumers, as was discussed above. IOU Energy‐Efficiency Programs: Energy‐efficiency programs are influential in many stages of the technology development cycle. For instance, the emerging technologies program tests new products to determine if any should be considered in the energy‐efficiency incentive programs, while the codes and standards program establishes minimum efficiency requirements. o For commercially available products, such as LED downlights, that are still relatively new to the market, incentive programs encourage the demand for commercially available LED products by reducing the total cost, which is vital to early market traction. Without a reduction in price, consumers and installers may have little interest in the product and will continue to use incumbent technology. Utility energy‐efficiency programs should consider feedback from lighting advocates, retailers, and manufacturers to ensure that the incentives offered are an appropriate quantity and offered in a way that is convenient for customers (e.g. upstream). The IOUs should coordinate with the CEC to ensure programs are supporting products considered high quality, and also consider lighting industry concerns that the standards could result in higher costs and reduced availability. IOU concerns that the standards will lead to reduced cost‐effectiveness, due to potentially higher costs, should be discussed with the CEC and CPUC. Financing programs can also help customers pay for retrofit projects involving lighting upgrades to LED technology. o In addition to incentives and financing, the IOUs can work with trade allies in relevant distribution channels to ensure that products are available, and that installers are properly trained to install LED recessed downlights. The utility marketing, education, 25 Residential Lighting Solution Pipeline Plan December 2012 and outreach program can coordinate activities with market actors to educate customers. While government programs should provide credible messaging and information for dissemination, utility programs are well positioned for getting that message directly in front of their customers through a variety of ways. LIGHTING SOLUTION TRIM: SPECIFIC COMPACT FLUORESCENT LAMP APPLICATIONS DESCRIPTION OF CFL AND APPLICATIONS CFLs were designed to be an alternative light source to incandescent light bulbs. CFLs produce light when an electric current is driven through a tube containing argon and a small amount of mercury vapor. This generates invisible ultraviolet light that excites a fluorescent coating (called phosphor) on the inside of the tube, which then emits visible light.38 CFLs have a spiral appearance, where the fluorescent tubing is twisted like a corkscrew. The lighting industry refers to CFLs that have a spiral appearance, while providing light for basic or general applications such as table lamps, as bare spirals. Figure 7 depicts an example of a bare spiral CFL. Figure 7. Example of Bare Spiral CFL39 CFLs have evolved over the past 10 years to provide special functionality, such as three‐way and dimming, for unique applications, such as outdoor reflectors and vanity‐bar globe lighting. For CFL technology to be able to replace all lamps in a home, adding this functionality was necessary. CFLs that consist of functionality beyond general illumination are known as specialty CFLs. Figure 8 provides a few examples of specialty CFLs. 38
ENERGY STAR. “Learn About CFLs.” http://www.energystar.gov/index.cfm?c=cfls.pr_cfls_about. Retrieved October 15, 2012. 39
This shows a TCP Eco$aveTM SpringlightTM. 26 Residential Lighting Solution Pipeline Plan December 2012 Figure 8. Examples of Specialty CFLs40 In addition to the two designations of replacement light bulbs, bare spiral and specialty, CFLs are also designed for specific fixtures. These CFLs consist of a pin base instead of a screw base. In 2006, the ENERGY STAR program made the diameter between the two pins standard for all ENERGY STAR‐qualified light fixtures. As a result, many manufacturers produce pin‐based fixtures that are compliant with the GU24 pin base specification for ease of replacement. Before GU24 pin‐based bulbs existed, there was no uniformity for CFL pin‐based replacement bulbs. Figure 9 below depicts an example of a GU24 pin base CFL. Figure 9. Example of a GU24 Pin Base CFL41 As mentioned above, CFLs have evolved over the last 10 years to meet the needs of virtually every socket in a home. CFLs, screw‐based and pin‐based, are used in a variety of fixture applications ranging from outdoor flood lighting, to recessed cans, to table lamps. Figure 10 provides an overview of CFL fixtures that include screw‐based and pin‐based CFLs. Figure 10. Examples of CFL Screw‐Based and Pin‐Based Fixtures42 40
Products left to right: Feit 3‐way Ecobulb® Twist, GE Energy Smart A19, and Philips Prisma CFL.
41
This shows a Maxlite 13 Watt GU24 Base CFL. 42
Products from left to right: Juno Lighting Group ICPL632E 6‐inch CFL Housing Recessed Can Light, Good Earth Lighting 1‐Light Nickel Pocket Wall Sconce G3155‐NK‐I, and Maxlite CFL Executive Desk Lamp.
27 Residential Lighting Solution Pipeline Plan December 2012 Due to limitations in fluorescent technology, CFLs are not the best lighting application for every socket. For example, fluorescent technology does not perform optimally in temperatures lower than 40 degrees Fahrenheit. These limitations are a by‐product of performance expectations consumers have from their familiarity in using incandescent light bulbs. RATIONALE FOR TRIMMING The criteria suggested to determine which CFL lighting applications should be trimmed from IOU programs are detailed below. To assess trimming specific CFL applications, it might be necessary to conduct research and obtain additional data on some of the criteria related to claims for the technology.  Regulatory requirements. o Codes and Standards. Once a measure has been adopted into codes or standards, it becomes legally required, and should no longer be incentivized (unless a case can be made for its use to support compliance). Additional incentives have yet to be proposed specifically for lighting code compliance in the 2013–2014 program cycle.43 o Legislation. For example, AB1109 calls for regulations and programs to reduce, from 2007 levels, average statewide lighting electrical energy consumption for indoor residential lighting by 50%, and for indoor commercial and outdoor lighting by 25%.44 o CPUC Guidance. The CPUC may determine programmatic support (for a measure) no longer serves ratepayers’ interests, and mandate its phase out.  Price premium. Sales price data showing a price premium no longer exists for an efficient option indicate market transformation.  Shelf space allocation. When shelf space allocation of an energy‐efficient option reaches and stabilizes at a significant share (30% or greater for a particular application), it indicates to sellers (typically based on sales data) that the market accepts the energy‐efficient solution. For example, retailers stocking their dishwasher inventory with mostly ENERGY STAR®‐qualified models reflects their high market share.  Consumer behavior. When consumer research (such as consumer surveys or observation) shows consumers choose efficient alternatives, this indicates transformations in consumers’ behaviors—a fundamental key to market transformation. For example, high socket saturation of a particular lighting technology and socket persistence indicate consumer transformation. Although not a market transformation indicator, performance is also an important consideration when assessing technologies to trim from programmatic support. Trimming should not be considered before a superior product becomes available for the same application. Superiority is defined as higher efficacy, longer lifetime, or additional functionality, such as dimmability. Based on the criteria above, CFL recessed downlights and bare spiral CFLs are suggested for trimming. The reasons are discussed below. CFL recessed downlights lack performance characteristics that make them comparable to new LED recessed downlights, or even to baseline halogen recessed downlights. CFLs were not designed to be used in enclosed fixtures, and this has led to increased burnout rates for this product category. Although 43
CPUC. Decision Approving 2013‐2014 Energy Efficiency Programs and Budgets. Mailed October 9, 2012. p. 70.
44
Assembly Bill 1109. Chapter 534. 2007. Accessed October 23, 2012: http://www.leginfo.ca.gov/pub/0708/bill/asm/ab_1101-1150/ab_1109_bill_20071012_chaptered.html
28 Residential Lighting Solution Pipeline Plan December 2012 manufacturers have addressed the issue through product advances, consumers are unwilling to adopt CFL recessed downlights in great numbers, often stating past experiences with burnouts or bad light quality as the main reasons. CFLs offer little or no price advantage since the pricing of CFL recessed downlights is comparable to, if not more expensive than, LED recessed downlights.45 According to an interview with manufacturer Cree, there has been a shift in stocking practices across major home improvement stores over the past three years, as the benefits of LED recessed cans have become widely recognized. Since IOUs began supporting bare spiral CFLs in the early 2000s, prices have dropped, shelf space and consumer acceptance have increased, and performance has improved. The IOUs, in collaboration with the CPUC, retailers, manufacturers, builders, installers, advocates, and government entities, have helped to accomplish these feats. The 2011 California Long‐Term Energy Efficiency Strategic Plan lists the phase out of utility incentives for CFLs as a near term policy strategy for market transformation. In addition, the CPUC passed the following guidance regarding the 2013‐2014 program portfolios: “We expect the IOUs to take decisive steps, as directed herein, to phase out Compact Fluorescent Lamps, scale‐up advanced lighting technologies and controls, revamp emerging technologies programs, and continuously improve their lighting portfolios to meet these aggressive targets.”46 This decision will preclude the IOUs from supporting bare spiral CFLs with rebates and other incentive models that have been used in past program efforts. Upon trimming bare spiral CFLs from programs, the IOUs should confirm if the baseline criteria put forth for trimming will be applicable to specialty CFLs, which are the next plausible lighting application to be trimmed due to the rapid advancement of comparable LED applications. APPROACHES FOR TRIMMING Transitioning away from supporting CFL recessed downlights and bare spiral CFLs needs to be conducted strategically in order not to (1) alienate market actors who are currently satisfied and supporting these technologies or (2) confuse residential customers who are unaware of available LED technology that will supersede CFLs in these applications. To accomplish this, the IOUs need to invest in educating their customers on the benefits of the next generation of high‐efficiency lighting. In addition, any approach decided upon for trimming should seek to impact the supply side as well. Consumers can be educated to transition to a new product or service, but without it being readily available they will be forced to purchase the incumbent product or service, or a substitute product or service, which could stall the IOUs efforts toward market transformation. IOUs that focus on increasing both supply and demand for LEDs will enable a smoother transition away from CFLs. The following recommended approaches are segmented by whether or not they will increase supply or demand for LED technologies. Possible approaches to increase supply of LEDs: 45
Based on preliminary website review; unpublished 46
California Public Utilities Commission. Decision Providing Guidance on 2013‐2014 Energy Efficiency Portfolios and 2012 Marketing, Education, and Outreach. May 10, 2012. 29 Residential Lighting Solution Pipeline Plan December 2012 1. Transition upstream lighting programs to support LEDs: In comparison to the promotion of CFLs, current upstream lighting programs promote a small selection of LED omni‐directional47 replacement bulbs and LED recessed downlights. IOUs could begin to remove incentives for bare spiral CFLs and allocate those funds toward buying down the price of these two LED technologies. IOUs could consider working in close collaboration with manufacturers and retailers on positioning strategies that target early adopters and consumer segments that are more likely to pay a premium to purchase LEDs (at least while their price is still relatively high).48 Over time, as prices decrease and possible additional funding becomes available to support LED incentives at retail, sales of LED recessed downlights and replacement bulbs will increase. In addition, the IOUs could prepare retailers for the phase out of CFL programs and ensure they will continue to stock competitively priced CFLs. 2. Consider adopting new program models to promote shelf space allocation and increases in stocking: The IOUs could consider new program models for promoting LEDs given how costly it is to reduce the incremental cost with incentives. IOUs may want to consider working with retailers, who account for a large percentage of LED sales, to provide them with a buying and stocking incentive motivating them to change the product mix of available recessed cans and replacement bulbs at retail. Instead of providing incentives to manufacturers, IOUs could incentivize retailers who have control in store and can invest the resources necessary to pave the way for this transition. 3. Begin to provide incentives on LED specialty bulbs: LED specialty bulbs will eventually become a better alternative than CFL specialty bulbs. The IOUs could work with retailers and manufacturers to develop a transition plan for LED specialty bulbs. A transition plan could consist of developing a timeline and hierarchy for when LED specialty bulbs are ready for full scale promotion at retail. Having a plan on how to promote LED specialty bulbs in advance will allow the IOUs to implement a seamless transition when it is determined that CFL specialty bulbs need to be trimmed from their programs. Possible approaches to increase demand for LEDs: 1. Invest in LED education: Consumers will not purchase what they do not understand. The IOUs, in collaboration with their network of retailers and manufacturers, need to educate consumers on the benefits of LED recessed downlights and replacement bulbs. Education could be delivered using multimedia such as TV, radio, online advertisements, point‐of‐purchase displays, and through IOU communication devices, such as bill stuffers, web sites, and other educational materials. The IOUs need to invest in educating their customers about this new LED technology to raise awareness and drive them to purchase. 2. Continue to invest in CFL education: Although it is recommended that the IOUs no longer support CFL recessed cans and bare spiral CFLs through incentives, they should continue to educate their customers that CFLs save energy. Customers need to be reassured that the CFLs they recently purchased with the support of the IOU are still fine to be used. Communicating the differences between CFLs and LEDs and the utility’s support of the technologies will be challenging to do with customers. The IOUs need to begin to address these two markets separately, but cannot transition away from supporting CFLs completely through their educational efforts. Since many customers experiences with IOUs stem from purchasing 47
Omni‐directional is defined as a bulb that will emit 360‐degrees of light dispersion, similar to CFLs and incandescent light bulbs. 48
Note that programs targeting likely purchasers could raise issues about free ridership.
30 Residential Lighting Solution Pipeline Plan December 2012 discounted CFLs at retail, IOUs need to continue to be supportive of this technology until it is no longer a viable energy‐efficient lighting solution to promote outright. 3. Target market actors: Market actors, such as builders, contractors, and building managers, need to understand the benefits of LED recessed downlights in comparison to CFL or halogen recessed downlights. Mass trainings to educate market actors could be utilized to continue to grow awareness of LED technology. SUMMARY OF LMT PROGRAM ACTIONS The LMT Program Team should consider actions that address the following questions: 1) What is the LED product positioning relative to CFLs? a. Develop marketing collateral that articulates why consumers should consider using LEDs, including benefits (quality and performance) of LEDs b. Collaborate with the statewide program team to create a transition plan that winds down CFLs by 2014. 2) What is the rebate strategy to influence pricing? a. SCE’s LED market trial has revealed product pricing and rebate levels influence the level of market adoption. The LMT team should coordinate with the statewide program team to develop a LED rebate or buy‐down strategy using lessons learned from the SCE LED market trial study. 3) What is the distribution channel strategy for this intervention (i.e., upstream, downstream or midstream)? a. Design and support an upstream buy‐down program that will have extra incentive for retailers to allocate shelf space for LEDs 4) What is the marketing, education and training strategy to influence awareness/knowledge? a. Engage Marketing Education & Outreach program to develop mass marketing message and ad placement b.
Offer training classes to retailers that educate sales staff how to sell LED products and differentiate them from CFLs. c. Design and sponsor a LED information workshop for the local government partnership program and regional energy network partners to learn about the benefits of LED products. d. Engage WET Connections (K‐12) and WET Centergies to educate and promote LEDs; offer manufacturer sponsored LED installation and maintenance training to lighting contractors e. Engage Home Buyer Guide, Home Energy Advisor and Business Energy Advisor programs (i.e., information and audit programs) to include all appropriate LED information in their offerings f. Engage advocacy entities to encourage information dissemination and support efforts g. Engage manufacturers, lighting contractors and lighting designers to participate in education and training efforts 5) What information is needed to support LED downlight market transformation? a.
b.
The IOUs and CPUC Energy Division will conduct a LED product quality test starting in the 2013‐2014 program cycle. The LMT team can assist this effort by collecting data on product quality to serve as a benchmark. The LMT team should ensure the LED associated workpapers and DEER inputs are correct and appropriate. Much of the LED cost‐effectiveness data are modeled using CFL data and need to be updated. 31