Lutron Electronics Co., Inc.
Manufacturing and selling of solar shading and lighting controls products
ID: 521196240851-45
Lobbying Activity
Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and Brussels Consulting Kft.
23 Jan 2023 · Right to repair, Artificial intelligence
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
20 Mar 2021
Dear Madam, Sirs,
We suggest the following:
1. Require the use of the Commission’s Level(s) framework to assess and benchmark the sustainability performance of buildings.
Reason: The framework has been embraced by the industry and is the result of a long testing procedure of the users. Currently, there isn’t a more fact-based, tried and workable assessment for sustainable building indicators.
2. Build Requirements for Lighting Controls into EPBD. Lighting controls are existing technologies, proven to bring high levels of energy saving (as well as other consumer benefits). At the moment, they are still under-utilised in Europe, compared to the US, for example. We strongly recommend EPBD encourages all Member States to follow the example set by many countries by introducing requirements into their Building Regulations necessitating the installation of lighting controls for occupancy and daylight detection, at least in commercial spaces.
Reason: Lighting still consumes around 17% of the electricity in a typical office. Occupancy detection has been shown to save between 20% and 60% of a lighting’s energy consumption, and daylight harvesting a further 20% to 60% on top of that. The US DoE Energy Savings Forecast of Solid-State Lighting in General Illumination Applications Report (2019) details energy savings ranging up to 70% depending on the application and type of controls used, in addition to those realised by LED lighting. Wireless lighting controls are very well suited to retrofitting into existing buildings allowing the savings to be easily achieved after refurbishment (in line with the objectives of the Renovation Wave Initiative). We propose that a new article is written into the EPBD stating requiring that non-residential buildings of over 400 m2 are equipped with automatic lighting control systems by 1 Jan 2024 where such systems are capable of occupancy control for indoor lighting with automatic detection; and automatic dimming of the lighting power based on daylight levels; and enable continuous monitoring, logging and fault detection; and allowing end-user control; and allowing communication with relevant connected technical building systems inside the building.
3. Ensure that the comfort and wellbeing of building occupants is not sacrificed as a result of striving for higher energy efficiency performance.
Reason: Indoor environmental quality (IEQ) is a key contributor to the health, comfort and wellbeing of occupants in a building. It’s essential that buildings are optimised also in ensuring that they work best for the people they accommodate. Provision of natural daylight and views as well as good quality electric lighting, in workplaces at least achieving the requirements laid down in EN12464 should be included in EPBD as a minimum.
4. Include automated internal and external solar shading as a technical building system in EPBD.
Reason: Daylight plays a key role in providing a good visual, biologically effective and energy efficient lighting of indoor spaces. It enhances health and well-being. It maximizes the positive effects of daylight (having bigger windows for daylight and outdoor view accesses), while preventing negative issues of glare and overheating. Automated systems allow maximum access of building occupants to the comfort and wellbeing benefits provided by daylight. By including automated solar shading as a technical building system, higher recognition of the highly efficient contribution of these systems to the full-lifecycle building energy performance and occupant wellbeing can be achieved. We suggest that following the “Energy Efficiency First Principle”, the prioritisation of passive solutions to reduce building energy consumption including automated internal and external solar shading must become mandatory. In addition, they can also be used to mitigate light pollution and the resulting hazards to migratory birds that tall buildings have been seen to present.
Read full responseResponse to EU strategy for sustainable textiles
2 Feb 2021
Dear Madam/Sir,
textiles are applied to an immense variety of different product types and over a broad range of applications. Confining textiles to “all kinds of textile products” misses the target.
We kindly request that the Commission ensure engagement in this regulatory development process from key representatives from the complex international supply chains of many of the industries in scope. There is a risk, otherwise, that suppliers will take the view that the regulations are not their problem and will therefore not engage. This leaves other representatives from industry to provide input in areas in which they are not expert.
We support the idea that regulatory focus should be on minimizing short lifespan textiles. The solar shading (indoor blinds) industry is not one categorised by short product lifetimes the way that some other textiles industries are, and so we recommend that regulatory instruments reflect the lower environmental footprint of the shading solutions (and recognize them also as complex services rather than products). This is even more true given the high positive contribution automated shades can make to the environmental footprint of a building through their ability to maximise the amount of natural light in a space with all of the associated benefits that come with that; including reduced need for electric lighting. Automated shading solutions are known to bring savings of between 20% and 60% of a building’s lighting energy consumption. It is important that steps to improve shade textiles’ sustainability do not inadvertently reduce the use of shades and the sustainability benefits that they bring to a building.
We fully support the Commission’s ambitions of removing hazardous substances from products wherever possible, including from textiles. At the same time, we ask that caution is exercised when it comes to important functional and safety needs that could be put at risk by making over-ambitious restrictions based on political pressures and/or without considering the ramifications of chemical restrictions on the intended use and required safety standards of a product. A good example is fire retardancy on solar shading products, including blind fabrics, where in order to ensure appropriate behaviour in the event of a fire, blind fabrics often need to be treated with chemicals with fire-retardant properties. There are examples in the United States, where conflicting regulations simultaneously require the fire performance that is achieved through the use of certain substances, whilst at the same time banning the use of the same substances. It’s important to ensure such regulatory inconsistencies do not emerge in Europe. We encourage that double regulation is avoided in the area of hazardous substances and request the Commission to use only the existing regulatory vehicles of REACH and RoHS to manage hazardous substance use in textiles.
We applaud the ambition of the Commission in working to introduce greater material efficiency in textiles, but kindly request that focus should be given to the sustainability outcomes that are sought rather than to the specific means by which those outcomes are achieved. An example taken from the EU-funded Reprolight project looking at light fittings, showed that the extra components needed in every product intended to allow repair of highly reliable, long life light fittings could perversely result in a net increase in the total amount of materials needed by an installation over its life.
Finally, we fully agree with the Commission that a universal change towards circular economy is needed. However, we also think that there should be no further regulation without effective market-surveillance to identify and remove non-compliant product as this simply results in additional burden for compliant producers and a resulting un-even playing field benefitting non-compliant producers.
As always, we remain at the disposal of the Commission to discuss further if needed
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