Proposed Lighting Regulations

In general, it does make sense to ramp up minimum efficiency standards on LEDs. However, I do have overarching concerns. Some may be relevant for this Regulation; other feedback may be more useful at higher level considerations.

1. Australia has attempted to shift from incandescent lighting to LEDs due to individual luminaire efficiency. Will this facilitate lowering lighting energy use in real terms? The Consultation Regulatory Impact Statement (RIS) makes many assumptions about energy use. If households simply switch lighting form non-LED to LED there will be efficiency gains. However, the RIS assumes that no rebound effect will occur with lighting and does not provide a reference for why this should be the assumption. According to the IDA's State of the Science Report 2022, there is a major concern that the rebound effect IS happening in lighting (https://www.darksky.org/wp-content/uploads/2022/06/IDA-State-of-the-Science-2022-EN.pdf). Even if we do assume rebound effects might not be the case in housing luminaires alone, it does not account for the many products (e.g. battery powered LEDs) that are now part of the market or how additional lighting may be added to products that don't traditionally have lighting.

2. Product waste impact of LEDs. Even if LEDs do offer efficiency in the aggregate (an assumption), they are considered e-waste and contain plastics (where-as incandescents could be recycled more easily or tossed in a bin with fewer environmental impacts). Australia has a waste and recycling management problem at the moment and without a pathway for recycling LEDs they are not well accommodated in a move to a circular economy. They could be a major environmental hazard moving forward if not disposed of properly--only about 17.4% of e-waste is disposed of properly in Australia.

3. Spectral Power Density (SPD) should be included in all labelling. As we move forward to reduce light pollution a key factor is wavelength of light. Blue light in particular is very disruptive to humans and other organisms. LEDs tend to have high level of blue content, though LED technology may make wavelength control more possible. Correlated colour temperature (CCT) is a poor indicator of the level or percentage of blue light or any wavelength of light in a luminaire. We should use this opportunity to require lighting products (LED and incandescent) to show spectral power density. This will help consumers make the right decision for their lighting needs (for example, when considering environmental or health impacts) SPD can be displayed in graph form or, potentially (though less accurately) with three ranges and their corresponding percentages. For example: 380-450nm 10%, 450-620nm 60% 620-700nm 30% (not scientifically sound, just an example). Alternatively, a warning that CCT does not accurately indicate wavelength should be included.

4. There really isn't much of a reason to allow for CCT above 5000k (and really even 3000-4000K) for common household luminaires. Since exclusions have already been made and could presumably include any CCT. I suggest revisiting this and restricting CCT going into the future.

5. Within Section 3, Part 17, remove "ecodesign"; "Energy efficiency design requirements" would be satisfactory and more accurate. "Ecodesign" is factually incorrect as ecosystems and the natural environment are more likely harmed by LEDs in general (also the e-waste potentional as mentioned above). We need to do a better job of not conflating energy usage with environmental considerations. Energy related climate change is only one small facet of ecological conservation. LEDs are a large source of light pollution that is known to harm wildlife (See the National Light Pollution Guidelines for Wildlife).

6. Table 4, what is RG? No definition in this document.

While LEDs are and should be part of Australia's product mix, they also present many potential problems. Phasing out other lighting may not be the best approach for efficiency and environmental considerations.

unsure. While efficiency should be ramped up, it should not be to the exclusion of using incandescent bulbs.

Spectral Power Density (SPD) should be included in all labelling. As we move forward to reduce light pollution a key factor is wavelength of light. Blue light in particular is very disruptive to humans and other organisms. LEDs tend to have high level of blue content, though LED technology may make wavelength control more possible. Correlated colour temperature (CCT) is a poor indicator of the level or percentage of blue light or any wavelength of light in a luminaire. We should use this opportunity to require lighting products (LED and incandescent) to show spectral power density. This will help consumers make the right decision for their lighting needs (for example, when considering environmental or health impacts) SPD can be displayed in graph form or, potentially (though less accurately) with three ranges and their corresponding percentages. For example: 380-450nm 10%, 450-620nm 60% 620-700nm 30% (not scientifically sound, just an example). Alternatively, a warning that CCT does not accurately indicate wavelength should be included.

Other safety or emergency lighting such as maritime lighting.

AS/NZS 4282:2019

Spectral Power Density (SPD) should be included in all labelling. As we move forward to reduce light pollution a key factor is wavelength of light. Blue light in particular is very disruptive to humans and other organisms. LEDs tend to have high level of blue content, though LED technology may make wavelength control more possible. Correlated colour temperature (CCT) is a poor indicator of the level or percentage of blue light or any wavelength of light in a luminaire. We should use this opportunity to require lighting products (LED and incandescent) to show spectral power density. This will help consumers make the right decision for their lighting needs (for example, when considering environmental or health impacts) SPD can be displayed in graph form or, potentially (though less accurately) with three ranges and their corresponding percentages. For example: 380-450nm 10%, 450-620nm 60% 620-700nm 30% (not scientifically sound, just an example). Alternatively, a warning that CCT does not accurately indicate wavelength should be included.

CCT should really be excluded. It is an indicator at best and does not tell consumers about wavelength content.

Waste. LEDs are e-waste which presents a problem for Australia's circular economy and efforts to reduce plastics.

Other safety or emergency lighting such as maritime lighting.