MEPS (minimum energy performance standards) don’t perform for us. But we need to tell the Powers . . .

We’re all lighting people here and we know how to save energy – after all, we’ve been doing it for years. So if you ever wanted to codify a method of continued energy reduction, say following a global conference when our government has committed us to all sorts of targets, what would you do? I’ll give you two choices:

  1. Understand and appreciate the complexity of lighting installations and look for a way to measure actual light energy consumption at the service head, or
  2. Just apply an across-the-board minimum standard on a luminaire performance – a lm/W figure, for instance.

Here’s a clue: if you answer (2), then you’re wrong, or maybe you work for the Department of Business Energy and Industrial Strategy (BEIS), whose agents certainly believe that they are correct.

This is all about the Energy-Related Products Policy Framework consultation. We’re currently in the middle of it and we need to turn things around very quickly.

The stated objectives are laudable:

  • Reducing emissions by transforming how products use energy while minimising the disruption to consumers and businesses.
  • Reducing the lifetime running costs of products to increase energy bill savings for consumers, businesses and the public sector.
  • Building a circular economy in which products are more repairable, durable and recyclable, ensuring maximum retention of value in the economy for as long as possible.
  • Driving innovation by optimising smart technology use and installing incentives for manufacturers to research and develop more efficient technologies.

The current thinking from BEIS appears to address the first of these objectives while effectively jeopardising everything else. And that’s a good trick if you can manage it, but we have a government that rules by sound bite and minimum effort, so they want something that fits into a headline, rather than something that might actually work.

Here’s why it won’t work:

Going to a MEPS-only metric will lead to lighting projects being based solely on the use of an ultra-efficient light source. Because MEPS does not rely on ‘lighting in use’ there will be no need to consider / procure / commission the type of lighting control that will ACTUALLY lead to energy saving. It will stifle the kind of innovation and creative thinking that we currently see from the design and manufacturing communities.

This is about Minimum Energy Performance Standards (MEPS). We already understand what MEPS is about because we’ve all read and understood Part L of the Building Regulations. But what we’ve not been ready for is an energy code that relates only to a MEPS figure, rather than a methodology that addresses the installation as a whole.

I realise that I haven’t included the targets that BEIS is looking for, so grab a hold of something solid:

Tier 1: Introduce MEPS level to 120lm/W for a wide range of light sources from 2023

Tier 2: Increase MEPS level to 140lm/W for a wide range of light sources from 2025.

And the crucial point here is that this would be a move to a SINGLE MEPs figure – all ALL light sources. Shooting for the stars with a 140lm/W target may be achievable with industrial luminaires – perhaps street lighting . .but small lumen packages. Those lumen packages that make up the way that we illuminate our homes, leisure and commercial spaces? With warm colour temperatures, high colour rendering and tunable options? We already know that this is a technical struggle; its not as if LED manufacturers haven’t been trying to increase their source efficacies.

Previous versions of MEPS allowed for achievable balance between efficacy and lighting quality. Its fundamental to LED physics and, let’s face it, its fundamental to how we want to experience our lit environments.

This has all come about because we’ve been wrapped into a multi-pronged, catch-all, approach to energy efficiency and we’re sharing that space with:

  • hydronic space heating (domestic)
  • domestic cooking
  • professional and commercial cooking
  • taps and non-electric showers
  • water pumps
  • low flow temperatures and heating emitters
  • direct electric heating
  • building automation controls
  • commercial refrigeration
  • servers
  • compressors

I’m not going to ask you what the above energy guzzlers have in common with lighting, because I’ll tell you . . . very little.

I know people who have big houses and maybe a couple of kitchens, though I find that a bit extravagant; and a lot of people don’t think much about their energy usage when taking their twice-daily showers; but I don’t know anyone who applies an aesthetic sense to the sheer number of appliances that they have in their home or business – unlike the lighting business, where fixtures proliferate just because they can.

MEPS is a smoke screen that avoids a proper methodology; it seems good because it looks as though we’re controlling our borders . . . sorry, our numbers. But it leaves the door open for designers / installers to use as many highly-efficient fixtures as takes their creative fancy. Its for good reason that we’ve  become familiar with concepts like ‘the rebound effect’ and ‘The Jevons Paradox’.

So what do we actually want?

It only makes sense to measure lighting at the level of actual energy consumption and we have the Lighting Energy Numeric Indicator metric (LENI) to provide those metrics for us. Of course, its more complicated than looking for a number on the packaging, but we’re dealing with a complex system here. LENI is based on illuminance levels and the hours of use, framed within in the context of the energy strategy in the lighting planning. And that makes sense to me.

It all depends on how serious we are about managing lighting energy usage. If we are, then we need a system of calculation that mimics the way that an installation will be used. A number on a box or an arrow on an energy label doesn’t do anything of value other than disguise how wasteful a lighting installation might be.

What I’m asking you to do:

At root, I’m asking you to think about all the things that we risk losing if this MEPS-only approach is approved by BEIS.

  1. Read all you can find out the current consultation process and get involved in it directly if you’re able.
  2. Contact your own MP and let them know that we’re heading for yet another government-inspired embarrassment when MEPS is exposed for the clumsy (and lazy – remind you of anyone in Downing Street?) metric that it is.
  3. And if you want to make a comment and don’t know who to contact, please send me an email ( nomeps@thelightreviewonline.com ); I’ll collate the responses and forward them to my friends who are on the front line of this latest struggle.

If we go on the basis of previous campaigns to try and introduce something sensible into proposed statutory codes we’ll just end up with a list of exemptions, while the baseline buffoonery continues. Maybe this time we can aim for something higher and more relevant, aiming for a radical review of how we manage lighting energy both at the design desk and in the real world.

It doesn’t mean that we have no interest in improving the energy-efficiency of light sources and lighting systems. But we know that we’re approaching the practical limit to improving LED efficiency (there’s science involved here – just don’t ask me to explain it) so expecting year-on-year improvements isn’t going to happen – and while that’s not happening we’re not getting any closer to a proper system of energy management.

We have just enough time to do something about this- but we need to let BEIS know that we’re not happy with progress thus far.

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