payback period considerably 2. Methodology for the market study 12 Efficacy: computed for information only, as lumen divided by power. It has been assumed that declared lumen values are compliant with the definition in regulation 1194/2012 (see also point 2). Where both nominal and rated values were available for lumen and/or power, rated values have been used for efficacy computations. [declared lumen values are assumed to be compliant. This should have been underpinned by appropriate testing] 2. Methodology for the market study 13 The thermal effects of the substitution of a halogen lamp by a LED lamp have not been evaluated: these depend on the type of luminaire and on the burning position, which in general are unknown in this study. [This should have been researched more carefully]. 2. Methodology for the market study 15 R39 Form factor: For R39, R50/63/80, it is assumed too easily that consumers may compromise on shape, because most luminaires for spots are typically designed around the bulb shape (eg
by the study team for discussion as in Figure 1. the most optimistic forecast on efficacy improvement and without margin , where in the same document it is also mentioned (page 14) that the increase may freeze in near future due to market developments on the forecast 4 Summary 16 Re-wiring for LED tubes The re-wiring that can be necessary for LED tubes in retrofit application is not limited to LED tubes only but applies to other categories too. Make the observation also for other retrofit applications. 4 Summary 18 Availability of retrofit for R7 It is correctly stated that not for all R7 lamps adequate retrofit exist (due to dimensions, spatial light distribution,…) This is also valid for other products, even for non-directional GLS and CFLi Add references for retrofit issues for other product categories. See figure 4 4 Table 17, 18, 19, etc 80, etc Different electricity rates used per technology Is it a sound ecodesign criterion to use different electricity rate to compare technologies? Use a uniform electricity rate 4 Table 27 101 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED replacement starts at lower wattages (see also last paragraph on page 100) 5 General Only one LED category Why is there only one general LED category while the other categories are split up? Split LED into subcategories, make comparisons for same Tc, luminous equivalence as per 244/2009 5 General Product characteristics Are figures based on actual measurements or catalogue data 5 Summary 6 Figure 1 LCC Results differ significantly from other studies Calibrate 5 Table 10 23 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED
replacement starts at lower wattages 5 Footnote 17, table 20 12, 40 Different electricity rates used per technology Is it a sound ecodesign criterion to use different electricity rate to compare technologies? Use a uniform electricity rate 5 lm/W value for CFL Typical figure of 55 lm/W for 6000 hrs is conservative for CFL. Calibrate. Propose 12Watt average with 60 lm/w efficacy 5 Table 20 40 Typical lm/W value per technology 244/2009 differentiates lm equivalence with GLS per alternative technology Use 244/2009 equivalence table 6 General e.g. page 5 LED 2015 and LED 2020 “If LEDs meet the projected 2020 characteristics, and classic technologies maintain their current characteristics, ….” See comments for task 4 and 5 on LED status and perspective Use margins on future projection and calibrate application specific 6 Summary Page 5 Availability of retrofit “it is recalled from the Task 4 report that LED retrofit lamps for halogen capsules and for linear halogen lamps with R7s caps in general have larger dimensions than the lamps they aim to substitute” This is not limited to R7. See also comments task 4 and 5. 6 General Differentiation of energy rates As for task 4 and 5 6 2 Analysis 9 14 The ‘rebound effect’ indicates the consumer’s tendency to buy energy saving lamps that have higher luminous flux than the classic Plse elaborate on the rebound effect and relate to the equivalence table in 244/2009