Feedback reference
F15139
Submitted by
Rob Halliday
User type
Other
Organisation
Association of Lighting Designers
Organisation size
Large (250 or more)
Country of origin
United Kingdom

The Association of Lighting Designers represents lighting designers and lighting technicians working in entertainment and performance lighting, with members from around the world. The Association has been involved, through the European Entertainment Ecodesign Coalition (EEEC) and Pearle, with all of the discussions about Ecodesign as it pertains to entertainment lighting throughout 2018, since it became clear that the proposed regulation would remove the current clear, unambiguous exemption for 'studio lighting, show effect lighting, theatre lighting'. During this time, the ALD has aimed to ensure that the concerns of lighting users (including venues, producers and shows that own or utilise lighting equipment) have been represented alongside those of lighting manufacturers.

The ALD, on behalf of its members, fully supports the overall aim of the regulation: to reduce the energy consumption of lighting. In many cases new productions and venues are ahead of these regulations, adopting new high-efficiency luminaires where they match or exceed the functionality and performance of traditional entertainment luminaires.

The ALD notes and is grateful for the exemptions included in the June and October drafts of the regulation which will allow the continued supply of light bulbs for the many traditional entertainment luminaires that remain in active service and so let them continue to be used. Given the use patterns of entertainment lighting (carefully controlled at different levels only during performance times) the energy used by such fixtures is much lower than might be expected. These exemptions prevent such fixtures, some decades old, becoming waste, reflecting the guidance of the EU’s ‘Circular Economy’ initiative.

Similarly other exemptions will allow the continued creation of suitable new lower-energy entertainment luminaires to replace those existing luminaires as budgets permit.

However, the ALD notes that some key issues remain that would hamper such progress, in particular with:

- the standby power requirement of 0.5W, which is unattainable in lighting fixtures that have to always be active and able to respond immediately to commands, for example to light up in time to a beat in a musical performance.

- the inability of high-output white LED light sources to meet the efficiency requirements, because of the Auger effect and etendue, which affect the efficiency of high-output LED sources and the efficient collection of light as light sources become physically larger. If such fixtures are not available, productions will have to continue to purchase older, less efficient arc fixtures which are exempt.

- the specification of green used in the definition of colour-tuneable light sources, which omits the peak area of green sensitivity at 555nm and would limit the ability of manufacturers to make trade offs between gamut, purity and the rendition of pastel colours and to achieve the best possible efficiency.

- specialist lamps used predominantly for entertainment lighting which have not been exempted from the regulations, including but not limited to 24Volt crown-silver lamps using K39d and E40 lamps bases, and high-output R7 lamps. No suitable LED equivalents are available in these or the other cases.

A fuller examination of all of these issues can be found in the attached document.

The ALD also notes that the proposed regulation will lead to entertainment luminaires being governed by combinations of different exemptions. Retaining the previous exemption for ‘studio lighting, show effect lighting, theatre lighting,’ just as exemptions are provided for marine and rail lighting applications, would provide greater clarity and scope for innovation.

If that is not possible, the ALD would ask that careful consideration be given to the points raised here to ensure that suitable low-energy fixtures for entertainment lighting can continue to be created under the new regulation.

Thank you.

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