Energy Bill

Memorandum submitted by PhotonStar LED Group Plc (EN 33)



Lighting accounts for a significant proportion of energy used – and wasted – in buildings. The installation of latest light fittings and lighting controls is playing an important role in improving the energy efficiency of buildings. This has been widely recognised in the commercial sector. Such measures have been supported through initiatives such as the Enhanced Capital Allowance and Carbon Trust Energy Efficiency Loan Scheme. These schemes have had the attraction of placing relatively a low burden on suppliers and users. The most recent revision of the Building Regulations (2010) virtually implies the existence of lighting controls, if the minimum efficiency standards are to be met. However, there is too much focus on the lamp (bulb) efficiency. The focus should now shift to the effectiveness of the whole lighting system. Fortunately, a British Standard method exists, to take into account how much energy will be used to illuminate a given area. The approach includes consideration of how much light from a lamp (bulb) actually reaches a work surface and the effective use of daylight-linked sensors and presence detectors. This new focus would help to shape future revisions to Building Regulations. If adopted in the national calculation methodology for energy performance certificate calculations, this would enable much better alignment of expected performance from lighting measures supported through the Green Deal mechanism. The carbon intensity of electricity supply has been recognised and the intensity figure was increased by around one quarter in the recent revisions to building regulations. If the domestic sector is to deliver planned energy and carbon savings, there is much work to be done. A significant opportunity exists for installed lighting measures. Example Retrofit for the Future properties show that fabric lighting measures rank alongside top-up insulation and glazing. But the existing model and calculation methodology use for domestic properties needs to replaced or updated. It is based on a very small sample of 24 houses, from one county. The data are nearly 15 years old. And whilst typical figures have been extracted, it must be understood that very wide variation in energy use is found in practice. Updated and representative surveys of occupancy, types of lighting, patterns of use and attitudes is needed. Fortunately, the lighting industry recently compiled a report based on a commissioned study which may be made available to the Committee. The existing calculation tool does not offer sufficient detail to support moves to low carbon housing. A simple count of the proportion of low energy fittings will no longer help to propel a move to low electricity consumption and cannot continue further on the road towards zero carbon housing. Minimum standards for lamp performance may have been considered sufficient in the past. Now, the way we use light is changing. Recessed ceiling downlights have become more prevalent – particularly in refurbishment projects. Whilst standardised models for buildings make sense, much closer attention to the effects of behaviour will be needed if savings are to be realised. Simple lighting controls in the house can address the potential for the situation where lights are left on in an unoccupied room. The finance cost to the consumer for Green Deal measures is looking to be a potential turn-off. Reduction of VAT to 5% on all approved Green Deal energy saving measures for domestic installation may go some way to address the concerns. The burden of regulation of approved measures should be minimised to reflect the reality of uptake in commercial properties and to reflect the delivery route through accredited installers rather than retail channels.

About PhotonStar LED Ltd 


1. PhotonStar LED designs and manufactures in the UK award-winning solid-state illumination products. These products using white light emitting diodes (light-emitting diodes). PhotonStar continues to develop innovative reliable products that utilise the advantages of solid state lighting to maximise savings, sustainability, control, functionality and aesthetics. However, Additional information about PhotonStar LED Ltd and the PhotonStar LED Group of Companies can be found in Annex A.

2. Specific worked examples are included in this document. No particular proprietary claims are being made. Concrete examples, based on real products can be more compelling.

Context – Use of Electricity for Lighting in the UK 


3. Lighting in the UK uses 64TWh (tera watt-hours) of electricity each year – 49TWh in commercial and street lighting sectors and 15TWh in homes. This represents about 20% of total electricity usage in the UK. Market Transformation Programme (MTP) energy savings measures were expected to reduce commercial consumption to 41TWh by 2020 and domestic to 13TWh by the same time [1] .

Figure 1. UK Domestic Lighting Electricity Consumption and MTP Projections to 2020

4. Defra actions have helped to reverse the trend of continuous increase in electricity demand for non-domestic lighting, largely through the Market Transformation Programme [2] . (2004: non-domestic estimate 48TWh – 6.7MTCO2. Without Lightswitch intervention, it was reported that an increase of 14TWh would have been expected between 1999 and 2020. MTP actions were projected to save 2TWh/year by 2008.) Based on figures for domestic lighting, this implies that the existing MTP measures would produce a 19% drop related electricity demand for 2020, compared with 1990.

5. Defra [3] estimate that lighting accounts for 19% of average electricity use in homes, from an average electricity consumption [4] per household of 4,800kWh/yr. PRP architects compiled data [5] for Zero Carbon Hub, suggesting 4,588kWh/yr. 19% of 4,588kWh represents 872kWh used for lighting (2.4kWh/day; about £87/year at 10p/kWh).

6. The CERT (as well as EEC1 and EEC2) programmes have previously been used to address domestic energy efficiency. For lighting, this has primarily been delivered through subsidised or free supply (262m given away in seven years [6] ) of compact fluorescent lamps [7] (CFLs). This support for CFLs has been curtailed in CERT and was not expected to continue in the CERT extension or under the Green Deal. Part of the reasoning is the phase-out of certain classes of incandescent (GLS) lamps in the UK, a little ahead of EU action.

7. An update to evidence on domestic patterns of use and attitudes to lighting is needed. Much of the understanding and modelling of lighting use in homes is based on the DELight report. The data from this report is nearly 15 years old. The sample of UK homes was taken from just 24 properties in Gloucestershire.

8. We expect better energy performance from our homes now. Lighting is one of the dominant uses of electricity in homes that don’t have electric heating.

9. The current carbon intensity of electricity supplied into homes was upgraded in the 2010 revision to the Building Regulations, to reflect the fossil-fuel component in the generation mix.

10. At times of peak demand, such as during winter evenings, when domestic lighting is in use, the carbon intensity will be even higher.

Figure 2. Estimates of EU Lamp Sales to 2007

Lamp Sales – Trends in the UK and EU 


11. The evolution of lamp sales in the UK beyond 2007 provides an interesting story. Certain classes on incandescent (GLS) lamps have been phased out. But the CERT support for CFL lamps in the UK has stopped.

12. Plug-in halogen replacement lamps do not save as much energy as CFLs. But there are indications that their more attractive quality of illumination, smaller form-factor and lower purchase price may accelerate their uptake, at the expense of CFLs.

13. Without proper attention to dedicated LED fittings, the VITO study on lighting suggested that halogen lamps may become the best available technology for many applications.

14. In addition, planning for energy-related product directives for the phase-out of reflector lamps is currently making slow progress.

15. More details of consumer trends and attitudes to lamps are available in a confidential GB survey recently carried out by the UK lighting industry.

16. Without subsidy such as CERT support, consumer investment in newer lighting technologies will not be attractive as the payback times would be expected to be longer than 1-2 years in many instances. Many installed lighting and lighting control measures could be expected to pay back in accordance with the Golden Rule. However, their energy efficiency benefits are not properly recognised under the current EPC assessment methodology.

17. It is proposed that ways be found for Green Deal mechanism to include support for the substantial opportunities to offer installed lighting and lighting control measures, from the menu of choices to be offered with assessment advice.

Dedicated illumination-grade white LED (light-emitting diode) light fittings 


18. The NHER [1] found that by extending penetration of low energy lighting in homes from 30% to 100% low energy lamps reduces dwelling DER by 7%. It is suggested here [2] that further move to dedicated LED luminaires already offered a 33% improvement in illuminance performance (W/m2/100lux) in 2009.

19. Moving from 30% of low energy lighting to 100% LED luminaires could bring an additional 6% saving off the DER [3] . As LED chip efficacy continues to improve, additional DER savings can be attained.

20. As a proportion of peak electricity use in homes, lighting accounts for around 27% of demand.

21. Further savings are to be won by appropriate use of appropriate daylight, presence detectors and daylight-linked dimming. This type of approach underpins a great deal of energy efficiency investment in the private and public sector.

22. None of these potential savings would currently be recognised in the present National Calculation Methodology used by SAP [4] , the assessment tool selected for domestic settings.

Commercial Opportunity 


23. The commercial opportunity for savings from investment in lighting is clear. Lighting may be used for longer periods each day. The payback from reduced energy use will therefore be shorter. The refurbishment cycle may in some cases also be relatively short (3-5 years).

24. Investment in lighting systems and lighting controls makes strong economic sense in non-residential settings. Commercial decisions on lighting systems and controls are made every day, based on the combination savings through reduced energy bills and reduced maintenance costs.

25. The lighting system could be upgrading inefficient T12 fluorescent strip lighting to use the more efficient T5 tubes, along with high frequency ballast and optional controls – occupancy detectors and daylight sensors.

26. Many hotel corridors, reception areas and dining rooms might still use halogen lights. Dramatic power savings are available from a switch to dedicated LED downlights. There is a side benefit because the need for frequent replacement of halogen lamps is eliminated.

27. Maintenance savings can dominate where guaranteed life, such as is offered from a dedicated LED light fitting, can be a real benefit in remote, hard to reach or other significant locations.

28. Admittedly some lighting investments have at least half an eye on carbon savings. With respect to the Carbon Reduction Commitment, corporate social responsibility or carbon savings to be claimed by the Carbon Trust or power companies.

29. But, essentially, the financial decision is usually largely based on energy savings providing a reasonable payback period. In some circumstances, this depends on implementation of lighting controls and possible new lighting to match with these controls.

30. Financial support and incentives have been offered for investment in lighting, based on manufacturer’s claimed performance and calculated benefits. Loans have included Carbon Trust Energy Efficiency Loans for SMEs, and from Salix Finance in the public sector. Example anonymised Carbon Trust loan payback calculation can be made available.

31. In situ results for lighting systems will have been audited by the Carbon Trust as part of the

Energy Efficiency Loans follow-up. Loan payments were based on energy bill savings. Hotels would provide an obvious area of audit data.

32. Of course, certain carbon-related criteria needed to be met to qualify for a CT EE loan. But the central calculation of energy bill savings and loan repayment is based on actual electricity bills, unit charges for electricity, projected savings – and hence simple payback. Thus, the Carbon Trust loans database will have details of a great number of installed lighting systems and controls. A proportion of these will have been audited.

33. Tax reliefs through the Enhanced Capital Allowance similarly state performance requirements for lighting systems to comply and are based on written claim supported by manufacturer. No specific third-party data has been required to provide this support. Auditing of actual energy savings occurs in a proportion of projects and market surveys are undertaken, to monitor industry claims and actual performance.



34. Conversely, recommendation for consumer lighting products has, in the past, required costly third-party testing in order to have a chance to qualify for power company support under the CERT programme. This may have proved an appropriate approach for lamps (bulbs) with retail sale and promotion.

35. It is understood that Green Deal arrangements would not apply to lamps but rather would require lighting systems and/or controls to be approved measures and to be installed by accredited installers. It would not be necessary to cover the costs of assumed consumer marketing, based around a notional recommended specification in this Green Deal approach.

36. The recent update to the lighting industry survey of GB housing points to a growing dependence on halogen lamps. The end of CERT support for CFL lamps may reasonably be expected to reduce the popularity of this kind of low-energy lamp.

37. The European lamp industry has been promoting the advantages of halogen lamps. The VITO study for the European Commission even points to halogen lighting as a likely baseline and ‘best available technology’ for many fittings.

38. Efforts to bring reflector lamps into the scope of energy-related products seem to be slipping.

39. The anecdotal trend [probably supported by evidence from the lighting industry] towards increasing numbers of kitchen halogen downlights in the UK is of particular concern from an energy efficiency standpoint.

40. These factors suggest that practical energy saving may be available from installed lighting measures. This has been demonstrated in commercial sector, where long hours of use make for attractive economic payback times, typically of between one year and three years [1] .

41. In a domestic setting, payback periods for light fittings and controls measures will depend on occupancy, use and behaviour patterns.

42. External light fittings are expected to incorporate low energy lamps or controls. Yet the potential benefits of controls are not recognised inside a property.

43. Increased illuminance efficacy and use of controls are not recognised in standardised EPC assessment by SAP (SAP 2009 9.90 from 17 April 2011). In the calculation methodology, each light fitting would be assumed to be used for an average of 1.3 hours per day [2] .

44. For Green Deal measures, focus is drawn to the operating hours of primary fittings, rather than an aggregated picture of average light use. It is in the primary fittings that greatest energy saving potential would be recognised, particularly if halogen lamps proved difficult to displace.

45. Lower-use fittings may offer energy saving benefits through lighting controls (presence detectors) if there is a danger of lights being left on, but this is more difficult to account for in a generic building model.

46. It is hoped that the Green Deal will enable recognition of specific patterns of occupancy and building use where these may reasonably be expected to persist beyond a change in occupants. For example, sheltered housing or some social housing accommodation might be expected to follow different patterns of use to the implied average.

47. NOAA in 1999 showed only 31% of lighting energy used during periods of occupancy – remaining 69% available for savings. A study is needed on savings available from lights left on in unoccupied rooms or opportunities to dim down automatically when there sufficient natural light, in domestic settings. So, there is a possible stand-alone role for lighting controls in the situation where lights are often left on in otherwise empty or daylight rooms. This again would not be recognised in an EPC or SAP assessment. But could realise significant energy savings in some realistic scenarios.

48. It is proposed that a new/replacement methodology be used (particularly for lighting), to better help realise low and zero carbon housing. It should work to recognise properly the contribution of dedicated lighting, as a fabric measure, to DER reduction. Latest Building Regulations recognise an increased carbon intensity associated with primary electricity supply (+23%). This makes DER more sensitive to all uses of electricity. Lighting is a key element of this but is not modelled with sufficient detail and flexibility to realise savings through improved illuminance efficacy (W/m2/100lux or kWh/m2/yr). Nor are the appropriate use of sensors and controls recognised.

49. A route is available to provide third-party data on energy efficiency measures, to gain approval of from building control officers. But the evidence base should be developed nationally. Until a revised EPC tool is ready, it is proposed a national look-up table be developed to show standardised benefits for accredited lighting measures. This could be quite simple, to include examples of common situations like an occupancy sensor in a lounge where lights are often left on, replacement of halogen downlights in a kitchen by installing LED downlights.

50. he ECA abandoned attempts to list every lighting system and measure. Appendix Q in the SAP methodology would be a cumbersome way to attempt this, as installed lighting measures would be relatively standard – dedicated LED downlights, occupancy sensors and daylight-linked sensors and controls. Individual product marking with Appendix Q information on light fittings would not be acceptable to householders, nor would it be necessary when the assessor simply has to identify the type of installed light fitting.

51. The AIMC4 homes consortium is studying this issue. Several of the cost-effective fabric measures aimed at achieving emissions reduction needed to attain Code for Sustainable Homes level 4 are not recognised by SAP. Yet the performance benefits are being proved out. We need a pragmatic approach that will allow a wide range of effective measures to be offered to enhance the attractiveness of the Green Deal to consumers.

52. A sensitivity analysis should be carried out on the impact of smart meter variable tariffs on cost of using electricity for lighting in the home. Lights are often used at times of peak demand. Smart meters may open up time-of-day tariffs, in which case the energy savings for peak uses of electricity will have a proportionally larger potential for cash savings for the householder. With today’s generation infrastructure, the carbon intensity of peak electricity supply can be very high. Measures to reduce peak demand could be given a premium or incentive based around the ability to reduce the peak grid requirements. The peak demand for electricity and lighting is most obvious in the winter months. But summer daytime peaks can be expected to become more common, associated with use of lighting and air-conditioning.

53. Domestic evaluation tools (SAP development or successor) should also cover and reward measures that reduce the risk of summertime overheating.

54. Power factors of less than unity imply additional energy consumption – but this is lost as waste heat in the distribution network, for example substation transformers. Someone must pay for the extra work done by electricity generators to meet this non-resistive demand – more energy and more carbon from fossil-fuelled electricity generation. At its most extreme, poor power factors can induce faults in the distribution network.

55. A study of power factors for various home appliances and lighting types needs to be carried out. Commercial users must meet requirements for balanced reactive and inductive loads. No effective study has been carried out to model the evolving effective load of a domestic property, as the power factor and harmonics from lighting, appliances and other electrical items evolve over time. This is the subject of much debate in the lighting industry. To what extent is it necessary for new lighting products to take on a burden of minimum power factor specifications. Are the capacitive loads from integral ballast lamps actually balanced out by older white goods and televisions. For example, a significant installed base of compact fluorescent lamps in homes could leave exposed a significant power factor problem as older TVs and fridges are replaced.

56. The Lighting Association have called for a practical study, including through the EEPH Lighting Strategy workgroup. Certain power company modelling teams had indicated their willingness to look at the effect on network distribution at scale, once base household data had been gathered. Expert input has been initiated from the ENA. Initial contact has been made with UKERC. But no study has yet been put together. It is now hoped that this will be picked up by at least one of Second Tier Low Carbon Networks projects (Ofgem).

57. Firm data on lighting performance will come from the monitoring of relevant Retrofit for the Future properties. More details in Annex C.

58. Approaching lighting as a fabric measure brings a some significant benefits. Firstly, lamp changes are eliminated. The average cost for lamp replacements (by the householder) can be added onto the projected energy savings, hence improving the actual payback period for the householder. In social housing settings, the elimination of lamp changes would be expected to make a bigger contribution to payback, since labour costs would have to be included. With the move to a fabric measure, there will be less lamp waste to manage.

59. Another positive side-effect is the potential to reduce the number of electrical accidents in UK domestic properties. Accidents involving a light/lamp are by far the most prevalent in the home [3] . Dedicated LED downlight units are sealed, preventing ‘sticking in fingers’ and low voltage. One third of accidents related to light/lamp involved carrying out maintenance on the equipment while live.

60. Verbal and written evidence is available from regular contractors, who have described the installation as very straightforward and the light performance as ‘surprising’ or ‘pleasing’. One Housing Trust’s senior electrician’s verdict neatly summarises this – "bright and simple to install". Initial customers often over-specified the number of light fittings, anticipating poor light output. Please of ‘it’s too bright’ were most commonly met by substituting the LED drivers with ones that operated with a lower drive current.

61. Community-scale works are usually negotiated and let through tendering processes. Provided accreditation does not suffer, this would be a very cost-effective way to deliver installed lighting measures. The ECA would have more detailed comments on this.

62. Integration of microgeneration measures with local DC supply in the home. Potential to make more efficient use of power generated by a photovoltaic array if it can be re-used as DC power, rather than being inverted then injected back into the local grid. LED lighting on a 24V DC system supplied by PV provides a symbiotic example. Possible after-market for electric vehicle batteries as their condition starts to deteriorate, to manage loads such as lighting locally, in the DC domain.

Replacement for kitchen halogen downlights 


63. By extension from commercial applications, some lighting installations should enable energy savings within the home. But the payback periods can be expected to be longer, reflecting the shorter average hours in use as assumed by the SAP model. One target application will be selected for examination. That is replacing the seemingly ubiquitous reflector downlights in the kitchen. For this treatment it is assumed that consumer preference has dictated the use of these lights. The CFL alternatives have limited success in displacing the halogen fitting, primarily on concerns on initial installation cost – but also consumer views on warm-up time, colour rendition and ‘sparkle’.

64. LED lights are particularly well suited to situations where light is required to be directed forward – or downwards, as it is in the case of a downlight. Increasingly popular in people’s kitchens and bathrooms, downlights are also prevalent in reception areas, hotel corridors. LED downlights have been adopted in the hospitality, retail and catering (Horeca) sectors in the last two to three years. Primarily attracted to the energy savings, elimination of lamp changes and quality of light. Compatibility with simple lighting sensors and controls is another positive factor.

65. Using concrete examples from PhotonStar, a range of dedicated LED downlights has been developed specifically for domestic settings. To work with mains electricity, they are pre-wired with LED ‘drivers’ and have spring-clips fitted for quick installation. A wide trim on the visible part of the light fitting covers possible ceiling damage – e.g. if it has been scorched by previous halogen fitting or where minor damaged is incurred while the light fittings are being replaced.

Examples of dedicated LED luminaires manufactured in the UK by PhotonStar LED Ltd 


66. EcoStar: The EcoStar6/6+ products are intended as a simple replacement for halogen (or CFL) downlights. Tested independently by WUELC, EcoStar LED luminaires offer payback times as short as 4 months in high use areas, when used to replace halogen downlights. Wide examples of use in hotels, reception areas and domestic settings.

67. Brighter than 35W MR16, 50W GU10 or >60W incandescent downlights. Colour rendition is good (Ra>80). Each light fitting is supplied with an LED driver, to enable 1:1 replacement of existing fittings, using existing wiring terminations. The energy consumption is significantly lower than for halogen downlights and the LED light does not get as hot during operation. The front face of the EcoStar6 is designed to cover any scorch marks from previous halogen fittings. These IP65 fittings are suitable for use in bathrooms – zones 1, 2 or 3. Instant-on and compatible with occupancy sensors. Designed and made in the UK. The EcoStar4 is designed for installation in insulated ceilings. A summary of performance characteristics is included in Annex B.

68. There have been discussions with the Electrical Contractors’ Association (ECA) to develop an understanding of installation cost and experience of proportion of wiring faults, etc discovered. More details are shown in Annex D. Based on current pricing, the range of simple payback periods lies between 5 and 15 years, typically about 8 years. When elimination of lamp replacements is included, the typical simple payback is 6 or 7 years. Reduction of VAT from 20% to 5% would remove about one year off the payback period. Further economies of scale would be expected from a Green Deal scheme. Further reductions in cost of light fittings with volume and reduced cost for whole house or neighbourhood refit would all serve to reduce the payback period.

69. The EcoStar6+ currently features a driver with higher efficiency and longer warranty period. However, carbon scoring approaches under CERT – for example – did not necessarily reward the additional performance from this lighting solution and the EcoStar6 is kept as a cost-reduced variant.

70. The EcoStar range would prove ideal for application such as laundry areas, lounges, kitchens and other communal facilities in social housing. It was hoped that this would be trialled in the third phase of the Environmental Transformation Fund LED lighting field trials, which was cancelled. See note in Annex C.

71. This CS5 range of lights provides additional flexibility over colour temperature, beam angle and driver selection – including dimming drivers, such as trailing-edge dimmable driver. Considered less relevant to primary fittings like kitchens, dimmed operation can be expected to deliver addition energy savings in locations like living rooms and dining areas. Payback on the additional cost of dimming may be offset against additional energy savings, were these to be recognised in the assessment methodology. Summary of technical performance details in Annex B.

72. The CS5 product offers very similar performance to the EcoStar. Illuminance efficacy comparisons demonstrate that the LED downlights outperform even CFL downlights when illuminating a work surface – such as in a kitchen. Tests and modelling carried out by PhotonStar in 2009 were based on the CS5 product range. They showed [1] that the compact florescent GU10 downlight, although comparable in output (lumens) to the PSL CS5 requires 63% more power then the efficient CS5, to illuminate the same area to 100 lux.

73. Further ranges of light fittings bring additional features for domestic settings, including range of colour temperatures, surface-mount lights and central ceiling fittings.

Further Comments 


74. Assessment advice on lighting measures and controls should be updated to include specific

advice concerning halogen downlights. Refreshed information could include reference to LED lamps but should highlight the additional energy savings available from dedicated LED light fittings. The role of natural daylight – e.g. through sun-pipes – and lighting controls, including presence detectors and daylight-linked sensors, should also be covered.

75. Green Deal assessors should also look at secondary factors that may influence shorter payback times for key energy saving measures. For example, extra heating and lighting times required in vulnerable households.

76. Integration of lighting controls, such as light-level (lux) sensors and presence detectors, into light fittings have already been demonstrated in commercial deployment. Integrated sensors help to reduce costs – fewer wires, fewer connections and less commissioning effort required, These sensors could be included in domestic dedicated LED fittings and would help to realise energy savings. The benefits of lighting sensors are not represented in the domestic energy assessment calculation tools in SAP 2009 and so their energy reduction effect would not feed through to an improved EPC rating.

77. Many advanced LED light fittings can be connected to a dimmer control. The energy saving benefits of dimmers are not currently recognised.

78. Reduction in the energy used for lighting could obviate the requirement to replace some of our ageing central generating plant. LED lighting is particularly efficient when used in conjunction with on-site renewables and so should act as a key enabler for distributed energy production. Improved lighting efficiency has a multiplicative effect in scaling back the load on air conditioning. In the non-domestic sector this may relieve the strain on city-centre distribution networks by helping to soften summer peaks in electricity demand, which look set to become increasingly important in a changing climate [1] .

June 2011

Annex A – Information about PhotonStar LED Ltd 


PhotonStar LED Group PLC ("PhotonStar" or the "Group") is a British designer and manufacturer of smart LED lighting solutions.  The Company's proprietary technology seamlessly integrates LEDs, sensors and controls to provide intelligent lighting for commercial and architectural applications which benefit from greater CO2 reduction, lower cost of ownership & improved functionality compared to other available light sources.  PhotonStar's lighting products have won numerous awards for performance, innovation and reliability, and are unique in the industry for the use of recycled, and recyclable materials, which means they have 90% less embodied CO2 than equivalent products providing the same levels of illumination.


PhotonStar comprises two divisions: PhotonStar LED which works with lighting designers, architects, house builders, facilities management companies and sustainability consultants to provide intelligent, high-end LED lighting solutions for the commercial and architectural market, and PhotonStar Technology which provides LED lighting solutions for specialist applications such as film & television production lighting, UV curing and medical applications.


PhotonStar is based in Romsey Hampshire, with manufacturing in Swansea. 

In May 2009, PSL acquired Architectural Lighting Controls Ltd (ALC). The Company was admitted to AIM in December 2010 following the reverse takeover of AIM-listed Enfis Group. Most recently, the PhotonStar LED Group PLC acquired Camtronics Vale Limited, based in Tredegar Wales. Camtronics is a specialist contract assembly company, focusing on complex electronic products covering everything from surface mount PCB population to final product assembly, test and distribution.

The acquisition of Camtronics will provide PhotonStar with an expanded manufacturing base as it continues to broaden its presence in the LED lighting space.

Annex B – Performance Characteristics of LED Downlights Manufactured and Designed by PhotonStar LED Ltd 


Up to date product information is available from

Product performance may be subject to change, particularly owing to the continued improvements in the efficiency of white LEDs.

This summary was prepared at the end of March 2011, to form the basis of a submission to the Energy Efficiency Partnership for Homes call for evidence, supporting DECC and the Green Deal.

Fair comparison

In order to make a genuinely fair comparison between these products, it is essential to consider and adjust for the fitting, ballast, driver and control gear which make a considerable impact on the complete performance figures.

Manufacturers usually quote performance figures of their lamp (bulb) tested outside of any fitting. Installation in the fitting results in a reduction in light output which should be considered in order to fairly compare lamp products against complete luminaires such as those from PhotonStar. A well designed fitting may have a light output of 90%, however LOR (light output ratio) of less than 50% is common. For the purposes of this assessment we have used a LOR of 80% for all the low energy downlighters which would be the high side of average.

The fitting will have an effect on the lamp life, affecting the published figures as it will raise the operating temperature. For LED complete luminaires this is already considered in the calculations, but for lamp products including LED lamps and halogen, the lifetime may be affected considerably from the published manufacturers data. This has not been adjusted in the report as the results are not predictable.

The power consumption of a lamp must also be adjusted to factor in any control gear, ballasts or drivers. With the exception of a GU10 lamp which does not require control gear. This report considers a factor of 0.9 for MR16 fittings and 0.85 for LED luminaires. The result – a 50W MR16 will consume nearer 56W when the control gear is considered.

The CeilingStar5 from PhotonStar is a complete fitting and published results are for light output from the luminaire.

This halolite fitting (used in our tests) will reduce the light output from any lamp installed into it. Published Lamp performance figures refer to the lamp without adjustment for a fitting.

To make comparison easier, we have created a mock project of a simple room measuring 4.5m square. 9 fittings are equally spaced within the room and the lux levels can then be assessed for each set of fittings. This allows us to calculate the amount of power required to illuminate to a certain lux level (lumens per square metre). A figure of 100lx is the industry standard for assessment.

The GE MR16 50W wide flood, is in this application the least efficient product requiring 12.8W/m2/100lx. The PSL CeilingStar5 NIC 7W is in this application the most efficient product requiring 2.7W/m2/100lx.

35W GU10 Halogen

PSL CeilingStar5 7W

By reviewing the lux levels achieved at the work plane in this application, the CS5 is shown to provide greater illumination where needed (at the work plane) than the 35W GU10.

Another observation is that the room with the LED luminaire has a more desirable even distribution of light.

Conclusion: The compact florescent GU10 downlighter, although comparable in output (lumens) to the PSL CS5 requires 63% more power then the ultra efficient CS5 to illuminate the same area to 100 lux.

EcoStar product performance summary


Luminaire power

Incl. Driver

Min. Lumens

Min lum. flux





Light aperture










50mm Ø

75mm Ø









50mm Ø

75mm Ø









50mm Ø

75mm Ø

LOR: light output ratio – the proportion of useful light that comes out of the light fitting, expressed as a percentage of the light emitted by the LED chips

CCT: Correlated colour temperature. The closest match equivalent illumination colour quality expressed as the filament temperature of a [hypothetical] incandescent lamp

3,000K correlated colour temperature is ‘warm white’

CRI: Colour rendering index. Standardised method to evaluate the accurate rendition of a test array of colours.

EcoStar6/6+: Suitable for shallow (60mm) recess. Beam cone is 70o

Illuminance comparable to 50W GU10 PAR20 Halogen, >75W R80 incandescent or >35W MR16 halogen

EcoStar4: Suitable for insulated ceilings. Beam cone angles 12 o, 32o or 70o

Illuminance comparable to 35W GU10 PAR20 Halogen, >60W R80 incandescent or >20W MR16 halogen

CS5 product performance summary

Versions of the CS5 are available for insulated ceilings and surface-mount, for solid ceilings. The CS5-SM is designed for use in situations where recessed ceiling fitting is not appropriate - e.g. small ceiling void, concrete ceiling, or no penetration allowed to insulation structure. The slimline capability of LED Light fittings (20mm thickness) is pertinent to these applications.

The CS5-IC was Highly Commended in the ‘Select Awards 2008’.


Luminaire power*


Min. Lm

Min lum. flux





Light aperture










50mm Ø

75mm Ø









50mm Ø

75mm Ø







CCT/CRI for all models

50mm Ø

75mm Ø







53mm Ø


*Total power depends on driver selection and dimmer setting.

3,000K correlated colour temperature is ‘warm white’

4,000K is neutral white – bathrooms

Illuminance comparisons

A: >60W incandescent; >35W MR16 halogen; B: >80W incandescent; 35-50W MR16 Halogen

C: >60W incandescent; >35W halogen

LED chips are most effective when both the thermal path to the heatsink and optical route for light have been given careful design consideration. If LED chips are properly mounted onto a heatsink and are not over-driven, their operating lifetime will be in excess of 50,000 hours. PSL quote 50,000 hours maintenance free operational life to L70 [1] at high ambient temperatures, typically 45oC for most products. But also up to 55oC - example: CS5 product range, backed by 5 year guarantee. Supported by LED chip data and 29 months of continuous operational test data for the light fitting.

CS30 and Muro light fittings

Higher luminous output. Central light fitting with surface mount fitting.


Luminaire power

Incl. Driver

Min. Lumens

Min lum. flux


Illuminance comparable to







1 x 26W CFL

at 4,000K






2 x 18W CFLs (36W)






2 x 26W CFLs (52W)

Beam angle 100o Additional 5% lumen and luminous flux output for the same power from 6,500K variants. Driver included - dimmable versions available

Additional lights used in communal areas - social housing example. Backed by the Defra Environmental Transformation fund, a range of LED light fixture have been trialled in communal areas of social housing. Whilst energy savings have been achieved, the opportunity was taken to bring lighting up to CIBSE guideline levels and frequently emergency battery packs have been installed as an upgrade at the same time. Hence, energy saving and payback comparisons may not prove useful.

Laser Lite

An example of a tilting LED light fitting – products like this would be appropriate for sloping ceiling installations. In independent tests by 42 Partners for Lux Magazine, the Laser Lite with XPG [light] engine was voted "Best Halogen Replacement".


The SmartWhite LED luminaire was named ‘Product of the Year’ in the Lighting Association awards 2010. Offers high colour rendition (Ra>90) and good illuminance efficacy across the range of colour temperatures.


Announced more recently, featuring the ability to replicate both the intensity dimming and colour temperature shift of tungsten lighting. May be valued by some householders who like the warm colour temperatures at lower light levels. Product pricing might be higher than for standard LED luminaires. However, consumers may wish to be offered a choice of dimming and colour temperature tracking for ‘mood’ or ‘scene setting’. Payback times may be reduced through judicious application of allowance for energy reduction during dimmed operation.

There is a much wider range of light fittings and controls available. These are almost exclusively used for non-domestic applications where the payback period is typically shorter.

Annex C – Public Funding Examples Retrofit for the Future and LED Field Trials 


Public installations in domestic settings - TSB/BIS/SBRI Retrofit for the Future programme

The Retrofit programme includes a number of properties with 100% LED lighting, including examples with 100% dedicated LED downlights, such as 31 Byron Square. This was one of the first properties to be completed. Ranking of measures by projected energy (carbon) savings placed LED lighting alongside other installed measures considered for Green Deal support. Payback may not be expected to be as attractive as loft insulation fitted where there was none. But LED lighting ranks fairly in comparison with glazing solutions, top-up fabric insulation, and microgeneration systems.

It is a shame that cash absorbed by some of the remedial work required for Retrofit properties did not leave room for some of the newer or more innovative measures to be trialled, as per the original plans. Refurbishment work is only now nearing completion for some of the Retrofit properties.

Detailed monitoring of energy use is being carried out on the Retrofit properties. This is planned to carry on for two years. We have not been able to get access to any preliminary data, which might otherwise have proved useful to inform this call for evidence.

31 Byron Square: After retrofit works, this 1940s steel frame house achieved a Energy Performance ‘A’ rating. Energy savings in this programme are ranked according to carbon savings. Dedicated LED downlighter saves over 100kg CO2 per year. [With potential for further savings from integrated sensors/controls – absence and daylighting.]

One of several Retrofit projects using PhotonStar LED luminaires. In this example [1] , LED lighting was ranked 7 in terms of absolute CO2 (DER) savings per year, again with potential uprating through current higher figures for carbon intensity.

1. 868kg/year: PV panels

2. 609kg/year: 200mm external foam insulation

3. 260kg/year: energy efficient appliances

4. 279kg/year: air tightness and ventilation

5. 222kg/year: triple-glazed windows and doors

6. 197kg/year: solar thermal panel

7. 105kg/year: LED lighting

8. 84kg/year: waste water heat recovery system

9. 40kg/year: flue gas heat recovery/ high efficiency boiler

10. 17kg/year: 25mm extra floor insulation

11. 17kg/year: mineral wool loft insulation increased to 350mm

Dedicated luminaires from PhotonStar LED Ltd; EcoStar 6, EcoStar 4.

These kgCO2 savings can be converted back to kWh saved, using official figures in force at the time for carbon intensity of primary electricity production (0.43 kgCO2/kWh) and for mains gas (0.13 kgCO2/kWh). In turn, these kWh savings can be represented as cash savings using nominal retail prices of 10p/kWh for electricity and 3.9p/kWh for natural gas. The energy savings and raking of these measures is shown in the table below.

No halogen downlighters were assumed used in this property.


Measure and savings:





PV panels





200mm external foam insulation





air tightness and ventilation





triple-glazed windows and doors





energy efficient appliances





solar thermal panel





waste water heat recovery system





LED lighting





flue gas heat recovery/ high efficiency boiler





25mm extra floor insulation





mineral wool loft insulation increased to 350mm




Retrofit for the Future: ECD Architects/Hyde Housing. This 1930s property was brought from SAPEPC rating of 60 up to 94. Projected benefits [2] were ranked by cost of carbon savings – relating to DER. LED lighting ranked alongside solar hot water in terms of cost per tonne of CO2 saved. At £2,505, the total lighting replacement was projected to save about 4% of total emissions, at a cost £8.32/kgCO2/year saved. These savings from LED lighting refit were estimated to be about double the cost of savings achieved through fabric insulation. Carbon savings through investment in LED lighting were about 40% of the cost of making carbon savings from triple glazing. It should be noted that the PV installation attracted a 50% grant; energy savings per kWh from LED lighting costed only 44% of the cost of savings from a full-price PV system.

The figures for carbon savings have been converted back to energy savings with standard carbon intensity factors at that time. The results are presented in the table below.

Measure and cost per kWh saved


Fabric insulation


Triple-glazed windows, doors


Condensing boiler/C-Heating


MHVR/airtightness; testing


Solar collectors and store


Replacement LED lighting


Photovoltaics, after 50% grant


Environmental Transformation Fund

The Environmental Transformation Fund trials of LED lighting for communal areas of social housing should be a source of data on energy and maintenance savings. The picture has been complicated in the fact that the trial sites took the opportunity to improve illumination levels and, in some cases, install emergency lighting systems. The energy savings and payback will be distorted as a result. Refer to Energy Savings Trust for details.

Sustainable Blacon

In partnership with suppliers and local installers, LED lighting has been installed in some rooms of low carbon communities challenge demonstration houses in Blacon, NW Chester District Council.

UK Entry for 2010 Solar Decathlon

The Nottingham H.O.U.S.E. implemented a DC lighting system and energy harvesting controls throughout the property, in order to obtain the best lighting efficacy. (Summary of technical performance included in submission documents.)

Numerous private residences benefit from LED lighting. Public information on energy savings may not be available.

Annex D – Illustration of Simple Payback Period 


The total cost of professionally installing these energy efficiency measures for different types of property and locations

Residential example: Example of integrated/dedicated LED luminaires replacing kitchen halogen downlights. Reasonable scenario for fitting costs, developed with the assistance of the ECA.

Fitting replacement labour






mins per fitting



mins total









days @







per fitting plus VAT


The assumptions behind the costs including a detailed breakdown of the components, for example, materials, labour, other ‘hidden costs’ and "make good costs";

Two elements. The products and the installation.

EcoStar6 lights are sold at £35+VAT trade price today in quantities of 100.

Fitting costs are estimated at £13+VAT per fitting.

Details of contract installation costs have been developed in consultation with the Electrical Contractors’ Association (ECA).

The EcoStar products come with a pre-wired driver to make installation simple in new build

and retrofit applications. A screwdriver would be used to detach old luminaire and to connect up to the driver for the LED luminaire. The driver fits in the ceiling void, though the hole cut out for the luminaire. Spring-clips attach the luminaire to the ceiling.

Typical installation process would look to install a number of replacement light fittings at one time. The single visit might take up to 3.5 hours. This might enable the replacement of 6 kitchen downlights, for example. Allowing 1.5 hours overhead for travel, setup, and a generous 20 minutes per fitting. Installation would probably be speeded up with a second person in attendance – trade-off between reduced time and increased hourly cost. It is assumed that the opportunity has already been assessed and only one visit is required by the (accredited) electrical contractor.

Hidden costs and make good

The EcoStar bezel has been designed to cover any ceiling damage

resulting from a previous halogen installation making it ideal for energy saving retrofit


The ECA can advise better on a representative proportion of lighting circuits that may need additional work. Their experience is that there are very few installations in need of additional work, remedial work or fault rectification. These costs are typically expected to be borne by the contractor when working on a larger contract, for example – area refit of council housing stock.

Note: under Part P of the Building Regulations, the renewal or replacement of a light fitting is considered to be a maintenance activity. No new circuits are being added nor created. Renewal of a light fitting does not require a certified electrician. But Green Deal measures must be fitted by certified installers.

Information on the average time taken to install measures. Potential innovations which aim to avoid or reduce disruption for the occupiers of the property;

Fitting replacement labour




mins per fitting


mins total






days @

Example of changing six light fittings. Essentially a simple and straightforward measure. As work is best done at a time agreed with the householder. Perhaps an on-line booking system could be offered. Coordination with other energy efficiency measures might be preferred. Might suggest clearing worktops in anticipation of bits of debris. Power will have to be turned off for a short while.

Actual installations usually take significantly less time: roughly 10 minutes per fitting.

Evidence of how measure(s) or products perform in terms of energy efficiency, energy savings, and/or cash savings on energy bills, and any other benefits (against a stated counterfactual).

Again, the assumptions should be set out where know, including assumptions on the type of property or energy source; whether the data is from "in-situ" trials or not, whether savings have

been verified and how, and what assumptions are made about building occupants and their patterns of energy use;

Worked example, showing payback in years and sensitivity to electricity prices and hours of use of these primary fittings

Payback range


Electricity bill savings alone









£ 57.60

£ 50.40





3 hours/day 8p/kWh





4 hours/day 10p/kWh or 5h/day@8p/kWh




4 hours/day 11p/kWh or 6h/day@8p/kWh




6 hours/day 12p/kWh


Second analysis, including savings from elimination of lamp changes in the payback calculation.

Simple payback times again shown in years.

Payback range


Electricity savings plus lamp replacement








£ 57.60

£ 50.40





3 hours/day 8p/kWh





4 hours/day 10p/kWh





4 hours/day 11p/kWh





6 hours/day 12p/kWh




Payback between






Typical range






Favourable VAT treatment could knock nearly 1 year off payback

Full details of assumptions and calculations for these residential examples are available.

Additional worked application examples (AE) are available on the company website. The headline titles are listed here:

· 4 Story office (Arrow Works)

· Bathroom

· High Bay

· Hotel Room Entrance

· Hotel Summary

· Kitchen – 4.5 x 4.5m

· New-build office

· Pool Changing Room

· Science Park Foyer

· Social Housing*

· Social Housing – 3 Bed New Build*

· Hotel Corridor (St Michael’s Hotel)

· Hotel Pool Refurbishment (St Michael’s Hotel)

· Hotel Reception (St Michael’s Hotel)

· Technology Strategy Board

· BDP London Offices

*It should be noted that the points for dedicated light fittings have been removed in the most recent Code for Sustainable Homes.

[1] Defra Market Transformation Programme, BNCL12: L ED s - Innovation Briefing Note , April 2008

[2] Defra Market Transformation Programme, Case Study CS03: MTP_CS03, 2005

[3] DEFRA (June 2007) Act on CO2 Calculator: Public Trial Version Data, Methodology and Assumptions Paper

[4] BERR Energy Trends December 2007 -


[6] Ofgem

[7] (light-)bulb is the more common term used for lamp


[2] Illuminance efficacy comparison, PhotonStar LED Ltd. ‘Housing Associations Complete Pack’

[3] DER: Dwelling Emission Rate. CO 2 emissions associated with energy use in a dwelling, either through on-site consumption of fuels such as natural gas, or emissions associated with generation, transmission and distribution of electricity used in the home.

[4] SAP – Standard Assessment Procedure. Used to generate standardised Energy Performance Certificates (EPCs) for dwellings.

[1] Example Carbon Trust Energy Efficiency Loan application – showing energy bill payback in 2.24 years

[2] DELight Report, 1998 and Market Transformation Programme assumptions

[3] Analysis of electrical accidents in UK domestic properties ; M. Barrett, K. O'Connell, Cma Sung and G. Stokes

[3] BUILDING SERV ENG RES TECHNOL 20 10 31: 237 Jun 2010  

[3] Authors investigated the cause and effects of electrical accidents in domestic properties over a 3-year period (2000–2002) in the UK based on the 24th Report of the Home and Leisure Accident Surveillance System (HASS/LASS). The electrical accident data from this database was analysed to establish electrical injury trends for various categories and groups.


[1] More detail in ‘Social Housing information pack’, available on request

[1] UKCIP02 and UKCP09 – UK Climate Impacts Programme

[1] L70 is used to indicate the number of operating hours before the light output has fallen to 70% of its initial value. This is an industry standard measure for defining lifetime for lights. A drop in illuminance flux of 30% is barely noticeable to the eye.



[2] – page 29

Prepared 22nd June 2011