States Don't Follow Stricter Standard, Says Former 90.1 Chair

There are some problems with the May article “Mood Lighting” written by Beck Ireland starting on page 42.

The 1992 law described is the Energy Policy Act (EPACT), not Energy Protection Act. Most importantly, and contrary to the article, most states do not comply with the requirement in EPACT and federal regulations to have energy codes no less stringent than ANSI/ASHRAE/IESNA Standard 90.1 (90.1). While most states have adopted the IECC, compliance with 90.1 is simply one option — and one that is rarely used. The IECC is not nearly as stringent as 90.1, and does not cover many of the provisions that 90.1 does. Specifically for lighting, there are considerable differences. Space does not permit an exhaustive description of the differences, but anyone who carefully compares the lighting provisions in the two documents can immediately see the differences. I can speak with some authority as the immediate past Chair of the 90.1 committee.

The sidebar “Commercial Buildings Deduction,” on page 44, also errs. Owners may not “deduct the full cost of the systems, as opposed to depreciating their cost over time” if the full cost exceeds the amount allowed for deduction, for which the maximum deduction for lighting is 60 cents per square foot, and provided the lighting wattage is substantially reduced in comparison with the limits in 90.1. In addition, contrary to the statement, the Web sites mentioned are not those of the IRS. There are many other requirements in EPACT 2005 for getting the tax deduction, such as computer simulations and certifications, and the cost of compliance with those requirements alone can often exceed the amount of the tax deduction. The tax deduction provisions expire at the end of next year, not this year.
Larry Spielvogel, P.E., CEng, FASHRAE, FCIBSE, FSLL, MIESNA, consulting engineer, based in King of Prussia, Pa.

Author's reply: Thank you for your comments. The law passed by Congress was indeed the Energy Policy Act, and not the Energy Protection Act, as written in the article. On your main argument, my source was the Washington, D.C.-based Building Codes Assistance Project (BCAP), a joint initiative of the Alliance to Save Energy (ASE), the American Council of an Energy Efficient Economy (ACEEE), and the National Resource Defense Council (NRDC), which reports that 15 states have adopted codes that meet or exceed 2006 IECC/ASHRAE 90.1-2004 or equivalent, 14 states have adopted codes that meet 2003 IECC/ASHRAE 90/1-2001 or equivalent, and six states have adopted codes that meet 2001 IECC/ASHRAE 90.1-1999 or equivalent. Had space allowed, we would have accompanied the article with the organization's research (Map above). I don't disagree that the provisions of 90.1 are more stringent than those of IECC; however, my point was that indeed most states have current provisions in place that require lighting controls in commercial buildings. The statement was a segue to the bulk of the article.

While underlining the year of installation versus depreciation over time, I did not mean to give the impression that the full cost of the systems — without a cap — would be deductible. Each deduction summary is followed by the cap to which it is subject. In addition, you're correct in stating the deduction has been approved through the end of 2008, not 2007. Finally, the first Web site was mistakenly identified as the IRS, when it should have been attributed to the Commercial Building Tax Deduction Coalition. The NEMA Web site was attributed correctly.


“Lights Out for Incandescent Bulbs” Brief Draws Industry Feedback

In the May issue, you ran a Market Watch story on page 16 titled “Ontario Declares Lights Out for Incandescent Bulbs.” While I am as much for greening the world as anyone, I find it disappointing that EC&M prints such “news” without any comment. So I would like to elaborate on this topic, as many states are also jumping on the bandwagon without a clear understanding of where it is heading.

There are many critical issues that your readers need to be made aware of.

  1. Compact fluorescent lamps (CFL) have mercury in them, thus it creates a major disposal problem of this highly toxic substance.

  2. CFLs do not turn on instantly, when compared to incandescent or LEDs.

  3. CFLs are only good for long duty cycles, as their life is degraded with many on-off cycles.

  4. CFLs cost significantly more than incandescents, nominally by a factor of 20 or so.

  5. The color rendition of CFLs and LEDs are not very good.

  6. CFLs are very temperature-sensitive and often are very dim if they turn on at all in cold climates or applications.

The economics, therefore, make sense only if one gets subsidies, else one pays up front for potential future electricity savings. Using LED-type lamps may be a much better alternative to CFLs. In my view, having mandated stupidity is not the way to go. There are many alternative lighting sources that are more efficient than incandescent bulbs, yet few seem to bother with the economics. I was quoted CFL lifetimes of five to 10+ years, however my personal experience with CFLs indicates them to be much lower.
Peter Soltesz, president, PAS-COM, Inc., Rockville, Md.

Editor's reply: Thank you for your comments. We really appreciate hearing from our readers.

The items that appear in the Market Watch department are categorized as “news” items. As such, we do not comment on the merits or shortcomings of the industry news items in this department.

The only page in the magazine where the editor's personal thoughts are presented is in the Industry Viewpoint. If you take a look at my viewpoint in this particular issue, you'll see that I do raise the issue of mercury content in CFLs and the disposal dilemma this presents to the us all. In addition, we've addressed many of the technical items you mention in your listing in other technical lighting related articles we've run in the pages of the magazine over the past few years.

I'm sorry you were unhappy with our coverage of this important topic, but we strive to inform our readers of changing events through many different channels. The Market Watch department is just one of these paths. Please visit our Web site (www.ecmweb.com) to search for other articles we've run on this topic.


Typical Motor Control Circuit Schematic Prompts Reader Inquiry

While I don't profess to be the world's greatest authority on electrical construction and design, I have learned a few things in the last 40+ years. On page 20 of the April issue, there is a ladder diagram (Fig. 3) that shows a typical 3-wire motor control circuit. Oops!

This circuit, as shown, will never start the coil of this contactor due to the fact there is no power available to the START button. I seem to remember that a STOP push button is always wired normally closed (N.C.), which puts power to the START button. I do hope this was just a typo. I'd hate to think I've been wiring them wrong all these years.
Thomas R. Wolf, Sr.

Author's reply: The STOP push button is normally closed (N.C.), and the start push button is normally open (N.O.). Please note the ladder diagram does show a NC push button for STOP and a N.O. push button for START. However, the illustration for the N.C. STOP button should have shown the line a little closer to the two dots. Standard practice is to show the line below the two dots for a momentary N.C. push button, and the line above the two dots for a momentary N.O. push button. I hope this helps clear up any confusion. The corrected graphic of a typical 3-wire control circuit is shown above.
Steve Vidal, president of Joseph J. Vidal & Sons, Inc., Throop, Pa.