Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
Victorian Energy Upgrades: effect on lighting for safety and functionality
Dr John F. Culvenor
40 Wilfred Road, East Ivanhoe, Victoria 3079, AUSTRALIA
+613 9441 0590 / john@culvenor.com
Affiliations:
Research Fellow (honorary), Federation University, Australia.
Visiting International Scholar (honorary), East Carolina University, USA.
1
Introduction
The government of Victoria provides initiatives to reduce energy consumption. These programs are
enabled by the Victorian Energy Efficiency Target Act 2007.
Lighting, and particularly building lighting, is reported to account for a significant proportion of the
energy efficiency certificates issued in Victoria1. For the year 2021-22 it accounted for 4.8 million of
the 7.6 million certificates. Of these 3.2 million were for building-based lighting.
The business promotions emphasise energy cost savings and saving the environment as per the
residential promotions. An example is as follows:
Figure 1 Promotional material2
1
2
An energy certificate represents the reduction of one tone of carbon dioxide or equivalent greenhouse gases.
www.energy.vic.gov.au/for-industry/victorian-energy-upgrades-for-industry/veu-promotional-resources
1
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
2
Does the light get upgraded or at least stay the same?
The word upgrade could be misleading. A property owner or occupier could have the impression that
the intent of the programs is to improve or at least replicate existing lighting output but with less
energy being required. That is to say the outcome expected could be to upgrade or at least maintain
the actual light as well as upgrading energy efficiency. But it is not necessarily that at all.
Confirming the absence of something is conceptually difficult. But by looking at the material there is
no requirement specified that I can find that the new lighting will produce as much light as the old or
that it will be better (upgraded).
It is specified that a standard for lighting should be met. This is discussed later. Even if it is achieved,
it is not necessarily the same as upgrading what was present or even achieving a parallel with what
was present. The new light outcome is not benchmarked to what was present. It is referenced, at
least in theory, to an independent standard rather than what was already in place. If it is done,
achieving compliance with a standard could involve more or less lighting than the existing setup.
Consumers should know that less light could be an outcome.
3
Code of conduct for providers
There are a range of code of conduct materials available including guides for industry behaviour and
materials for consumers3:

The code of conduct guideline4;

Industry guide - generating leads and marketing under the VEU program5;

Industry guide - contracting with consumers6;

Industry guide - undertaking activities under the VEU program7;

Statement of rights8; and

Consumer information resource9.
Among these materials there is not a lot of attention on lighting functionality. The Victorian Energy
Efficiency Target Amendment (Code of Conduct) Regulations 2022 requires that consumers receive
clear and accurate information on a range of things. Among those things is the “performance of the
product” (reg. 14 (b)).
What performance means is not clear; energy performance, lighting performance, both or something
else? The Code, the Industry guide on leads, and the Statement of rights mention this requirement.
But it is not prominently explained what performance means. Given that AS/NZS 1680 compliance is
a requirement it should form part of the explanation of performance.
3
www.esc.vic.gov.au/victorian-energy-upgrades/participating-veu-program/meeting-your-obligations-under-veu-code-conduct
www.esc.vic.gov.au/sites/default/files/documents/VEU%20code%20of%20conduct%20-%20guideline%20-%20v1.1.pdf
5
www.esc.vic.gov.au/sites/default/files/documents/VEU%20code%20of%20conduct%20-%20industry%20guide%20%20generating%20leads%20and%20marketing%20under%20the%20VEU%20program_0.pdf
6
www.esc.vic.gov.au/sites/default/files/documents/VEU%20code%20of%20conduct%20-%20industry%20guide%20%20contracting%20with%20consumers_0.pdf
7
www.esc.vic.gov.au/sites/default/files/documents/VEU%20code%20of%20conduct%20-%20industry%20guide%20%20undertaking%20activities%20under%20the%20VEU%20program_0.pdf
8
www.esc.vic.gov.au/sites/default/files/documents/VEU%20code%20of%20conduct%20-%20statement%20of%20rights.pdf
9
www.energy.vic.gov.au/__data/assets/pdf_file/0028/585154/Victorian-Energy-Efficiency-Target-scheme-consumerfactsheet.pdf
4
2
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
4
AS/NZS1680
According to the Building Based Lighting Upgrade Activity Guide10 the replacements should comply
with the AS1680 standards series11.
“Each building based lighting upgrade is required to:

achieve the minimum illuminance specified in the relevant part or parts of AS/NZS 1680

achieve the recommended level of maintained illuminance specified in the relevant part or parts of
AS/NZS 1680.”
The provision has been in place for about ten years. It is enabled now by the Victorian Energy
Efficiency Target Regulations 2018 (reg. 19 for buildings)12. It was absent from the Victorian Energy
Efficiency Target Regulations 2008 when they were first made. The reference to the standard was
introduced in Version 009B dated 17 May 2012.
Compliance with AS/NZS 1680 is not about taking values from a document and comparing them to
what the lamps provide. There are many different lux values for a wide variety of tasks. Compliance
will involve consultation with the building occupier about what tasks are done in the building. It could
readily involve different requirements in different parts of the same workplace depending on the tasks.
Various parts of the series will be relevant depending on the setting. Compliance could mean that
lighting upgrade levels could be required to be less than existing, match existing, or be greater than
the existing, perhaps to the point where the energy usage would be greater13.
AS/NZS 1680.2.2 provides figures for office tasks. Examples are as follows:
-
600lux, drawing, fine detail reading;
-
320, General reading and writing; and
-
240, Training rooms, filing rooms.
AS/NZS 1680.2.4 provides the benchmark for industrial tasks. It is a more complicated consideration
than the office environment owing to more variety of tasks. A general scale relating lux to the difficulty
of the visual tasks is below. Many examples of work tasks are provided (in my case I can achieve 600
lux which I find it suitable for a range of experimental work, etc).
1600lux, Exceptionally difficult visual task;
320, Moderate;
1200, Extremely difficult;
240, Ordinary or moderately easy;
800, Very difficult;
160, Ordinary or moderately easy;
600, Difficult;
80, Rough intermittent visual tasks;
400, Difficult to moderate;
40, Movement and orientation.
10
www.esc.vic.gov.au/sites/default/files/documents/C%2018%2024696%20FINAL%20PBL%20%20Building%20Based%20Lighting%20Upgrade%20Activity%20Guide%20-%20V%202.4%20-%2020220919.pdf
11
AS/NZS 1680 Interior and workplace lighting, series.
12
The requirement is the default. There is provision to apply for a determination to provide for an exception.
13
Presumably in that situation the activity could not proceed under the program.
3
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
5
Number of premises certified against the standard
Large numbers of homes and workplaces in Victoria that participated have at least in theory been
determined to comply.
The report for 2021 describes 633,000 upgrades in 394,000 households and 24,000 upgrades in
19,000 business premises over one year14. The proportion that were lighting was 80% (down from
90% the year prior). Since the program began it has impacted on 2 million households and 128,000
businesses. Compliance with AS/NZS 1680 has applied for most of this time being 10 years out of 13.
There are about 727,000 businesses in Victoria15. The number of business that has engaged with the
energy program (128,000) is not a majority but a sizeable proportion has been involved.
It is not unusual for me and presumably others in similar fields of work to refer to the AS/NZS 1680
series. But I cannot recall many examples where a business had already tested or designed lighting
to the standards.
I doubt it is among favourite reading material of many property owners and
occupiers. The standards would obviously have been employed in the design and analysis of lighting
in some premises. But my impression is that use of the standards prior to this program would have
been modest. I expect this program has lifted the application of AS/NZS 1680 dramatically.
6
Liability and risk issues of Victorian Energy Upgrades related to AS/NZS1680
The certification of lighting against AS/NZS 1680 series if it actually has been done over the last ten
years would be a very significant compliance initiative against these standards. The claiming of the
energy certificate involves also a certificate indicating compliance with the lighting standard.
Many health and safety issues relate to lighting. They could be ill health or accidents. Office work
such as postural issues or eye strain owing to poor light is an example. Accidents such as falls on
stairs and paths often involve consideration of lighting. Accidents involving use of machinery, mobile
plant collisions are other examples.
It seems to me that any problems later on relating to lighting where a non compliance with the
standard is shown to be present could be connected to the providers. Consider that an accident or
other health and safety issue arises where lighting could be a cause and the lighting is found to not
meet the standard. The first question will be whether the place was the subject of a Victorian Energy
Upgrade. If so, it was meant to be in compliance according to the terms of the program.
14
https://www.esc.vic.gov.au/sites/default/files/documents/VEU-performance-report-2021-20220623.pdf
www.abs.gov.au/statistics/economy/business-indicators/counts-australian-businesses-including-entries-and-exits/latestrelease#states-and-territories
15
4
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
7
Equivalent swaps
The principle of the upgrades is not to achieve equivalent exchanges. That might be a surprise to
many property owners and occupiers.
But if equivalence was sought, two things need to be
considered; the nominal output and the typical output in practice over the lifespan.
Lighting output generally depreciates over time. The maintenance lumens are what can be expected
over a period of time as against new. The depreciation curve varies from one system to another.
An example depreciation curve for LED is shown in an appendix16 along with the Philips depreciation
curve for metal halide. The LED is expected to last longer and depreciate slower. Once it fails or the
light is unsuitable the entire LED fitting needs to be replaced not just the lamp as in conventional
lighting. That is part of the cost comparison not considered here.
Consider a 30,000 hour installation period. The LED is used once and metal halide changed five
times at 6,000 hours. Consider that there is a staggered approach so that at any one time some of the
LED are new and others are mid life and the same for metal halide. The LED typical output could be
about 85% of the nominal. The metal halide output is a sawtooth shape as shown on the figure where
the metal halide sawtooth depreciation is superimposed on the LED curve. The overall metal halide
maintenance lumens could be about 75% of nominal.
When considering a replacement of metal halide with LED an exact like for like nominal lumen output
is not needed. There is some margin. A nominal output of LED at 10-15% less than what it replaces
could be realistic.
Another way to think about it is that the ‘Wattage equivalent’ = Old wattage x (Old nominal output x
Old depreciation) / (New nominal output x New nominal depreciation).
To take some examples in the case of replacing the 400W metal halide in the case study elsewhere
described it would mean adopting about 200W LED at 155lm/W or about 300W LED at 95lm/W17.
16
www.esc.vic.gov.au/sites/default/files/documents/PBL%20%20Building%20Based%20Lighting%20Upgrade%20Activity%20Guide%20-%20V%201.6%20-%2020200421.pdf
17
400x83.5x0.75/155x0.85=190W
400x83.5x0.75/95x0.85=310W
5
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
8
LED v metal halide: government example that doesn’t provide the same light
The Australian Government guidance on LED output is 80lm/W18. The New South Wales government
guide uses various figures for different LED types19. The figure nominated for a high bay LED is 90100lm/W. It nominates a 400W metal halide as outputting nominally 36,000lm being 90lm/W. There
is the energy use of the ballast of the metal halide system to consider (nominated as 8% by the NSW
documentation). For a comparable light performance, it should be obvious that an energy saving of
any note cannot be achieved if the technologies provide similar output per unit of power input.
The power saving of the nominated alternative in the NSW government example is not accompanied
by the same light output. The document suggests a 210W LED as way to save 54% of energy
compared to 400W metal halide. The nominal output of the LED is reported as 18,000lm. Like all
lighting metal halide has a depreciation curve as above20.
It is generally claimed that LED
performance over time depreciates less but this will not overcome the difference. A realistic allowance
would be say 75% for the metal halide making the benchmark, the “before” 27,000lm maintained. A
realistic figure for the LED is 85% reducing it to 15,300lm. The comparison is favourable in terms of
energy but may be unfavourable in terms of function and safety. By and large the favourable energy
promotion is achieved by providing less light.
9
Measured case example, LED v metal halide that doesn’t provide the same light
Over recent years various people have proposed changing lights in an industrial building that I occupy.
The existing setup is 400W metal halide high bay lights. Each time I have expressed a willingness to
consider the proposal but with concerns on two fronts. Firstly the lumen output has never seemed to
be equivalent. Secondly I am concerned about light quality.
The most recent promoters took on board the concerns and provided a 120W LED high bay sample
for a test (being their suggested replacement). The energy saving would be significant being a 120W
light versus a 400W light (plus a ballast).
But would the light be the same?21
The LED appliance was UL LED Lighting model UL-H120W-FS22. The rated output was 18,600lm
(155lm/W). I set up the LED at about the same height as the others. The height was 5.9m to the
surface of the lamp. The existing high bay lamps are in 730mm diameter reflector bowl. A diffuser
can be fitted or not (with a lamp suitable for an open fitting). The diffuser height is 5.9m however it
was off for the test. The bowl and lamp are a little higher than 5.9m.
The metal halide lamps were two examples made by Philips23 and Fuzion24. Philips lamps of this
general type are rated at 33,400lm (83.5lm/W). The Fuzion lamp is assumed to be similar25.
18
www.energyrating.gov.au/lighting/lumens-watts
www.energy.nsw.gov.au/sites/default/files/2022-08/2014-06-NSW-Energy-Efficient-Lighting-Technology-Report.pdf
20
E.g. www.assets.lighting.philips.com/is/content/PhilipsLighting/fp928480410097-pss-en_au
21
There are other issues such as what happens at the end of the LED life with the entire fitting being redundant whereas the
existing approach allows for lamp exchange. But those things aren’t considered in this paper. It is concentrating on output.
22
http://ul-ledlighting.com/product/239
23
MH/U 400W637 E40 CO
Assumed to be similar to the following: www.assets.lighting.philips.com/is/content/PhilipsLighting/fp928480410097-pss-en_au
24
LMH400EC 4000K
19
6
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
The other lights in the building were off for the test which was done at night. Measurements were
made directly beneath and every 6m at one metre intervals in two opposing directions.
The results are below. The metal halide lamps were consistent with one another being 183 and 184
lux average. The output averaged over the sample points for the LED was 103 lux being 56% of the
existing type (103/183=56%).
The lux ratio is the same as ratio of the nominal lumen outputs
(18,600/33,400=56%).
The energy saving would be real. But some of the projected energy saving would be achieved by
providing less light. A 200W LED could be a better candidate for a like for like outcome. If a user was
happy with less lighting a way to do that would be to turn off some lights if the circuitry allowed, or
remove some lamps, etc.26
Table 1 Light levels (lux)
Position on floor (m)
LED 120W
(UL LED Lighting)
Metal Halide 400W
(Philips)
Metal Halide 400W
(Fuzion)
-6
40
90
89
-5
53
116
114
-4
74
149
151
-3
100
192
194
-2
132
234
237
-1
159
284
282
0
172
304
311
1
164
280
278
2
144
224
227
3
113
178
180
4
84
140
138
5
60
109
106
6
44
82
83
103
183
184
Average
25
No specification on the exact product could be found. A figure of 70-90lm/W is nominated for metal halide lamps generally
www.fuzionlighting.com.au/technical/lamp-efficiency
26
There is a second point as well being the light quality. The large dome reflector bowls produce a very even light. But I am
concentrating on output in this paper.
7
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
10 An incentive for the provider to make the light worse
The providers of the lighting upgrades make their income by obtaining energy certificates. The value
of these is proportional to the difference between the old and the new in terms of energy consumption.
They can achieve a gain by the provision of light sources that produce more light per unit of input and
or by reducing the light that is produced. In addition the lower the output of the new equipment the
less it presumably costs to provide.
The economic tension against better light is that the less light that an owner or occupier can be
convinced to accept will provide a double financial benefit to the provider; more certificates and lower
equipment costs.
The bulwark against providing too poor lighting outcome is theoretically the requirement to meet the
standards and presumably the occupiers’ own knowledge and preferences. How well the standards
requirement works is not known to me. Awareness of the requirement among the consumers could
perhaps be strengthened. Further, awareness of how lighting from the new system would compare to
the old could also be strengthened.
11 Conclusion
Promotions for upgrades of lighting focus on the energy saving. I doubt anyone could miss that part of
the intent. However it may come as a surprise that an upgrade of actual light or even a like-for-like
functional output is not part of the requirements. Achieving better or even comparable lighting for
safety and functionality does not feature in documentation as far as I can see. The example I was
offered did not produce the same light.
The benchmark when property owners and occupiers go through this process is in fact not what was
being achieved before. The benchmark is intended to be that the Australian New Zealand standards.
The standards should be met and a certificate produced to that effect.
A policy change could be helpful. Many consumers may not be aware that their lighting levels could
be reduced. A policy improvement could be about a different framing of the requirements. For
example, a few things could be considered:
a) the requirement of compliance with the standards could be made better known to the consumer;
b) the consumer should be provided with the certificate of compliance at the conclusion; and
c) the lighting minimum could be set as being to meet the standards and the existing levels,
whichever is greater, unless consultation is such that less than the existing is agreeable.
There could be other ways to advance an improvement. But the theme of what I believe it needed is
that the way that the program will deliver functional and safe outcomes via lighting should be made
more prominent.
The functionality and safety aspects could be a stronger part of the materials
available to the property owner and occupier and the engagement that they have with the provider.
8
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
12 Appendices
12.1
Measurement case study arrangement
Figure 2 120W LED (left) and 400W metal halide (right)
Figure 3 120W LED, UL LED Lighting, UL-H120W-FS
Figure 4 400W metal halide lamp, Philips MH/U 400W637 E40 CO
9
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
Figure 5 400W metal halide lamp, Fuzion LMH 400ECDJ
10
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
12.2
Depreciation curves
Figure 6 Mock LED depreciation curve27
Figure 7 Metal halide depreciation curve
27
www.esc.vic.gov.au/sites/default/files/documents/PBL%20%20Building%20Based%20Lighting%20Upgrade%20Activity%20Guide%20-%20V%201.6%20-%2020200421.pdf
11
Culvenor, J. 2022, ‘Victorian Energy Upgrades: effect on lighting for safety and functionality’, Presented to
Forensic Engineering Society of Australia Meeting, Hawthorn, Victoria, 24 November 2022.
Figure 8 Combined curves, metal halide dashed28
28
The LED curve starts at 1 year which is an odd presentation.
12