U.S. Department of Energy - Energy Efficiency and Renewable Energy
Building Technologies Office – Information Resources
Text-Alternative Version: Model Specification for LED Roadway Luminaires Webcast
Below is the text-alternative version of the "Model Specification for LED Roadway Luminaires" webcast, held November 15, 2011.
Theresa Shoemaker: Welcome, ladies and gentleman. I'm Terry Shoemaker with the Pacific Northwest National Laboratory, and I'd like to welcome you to today's webcast: Model Specification for LED Roadway Luminaires, brought to you by the Municipal Solid-State Street Lighting Consortium, supported by the U.S. Department of Energy Solid-State Lighting Program.
Today we're happy to have as our speakers, Edward Smalley of Seattle City Light, and Jason Tuenge of the Pacific Northwest National Laboratory. Edward Smalley is the Director of the Municipal Solid-State Street Lighting Consortium and has more than 20 years experience in the design, construction, and operation of public outdoor lighting systems. For the past 11 years he has worked at Seattle City Light, where he has been the streetlight engineering manager responsible for that city's LED Streetlight Conversion Program. Edward is also the Vice Chair of the IES Street and Area Lighting Committee. Jason Tuenge joined PNNL in 2008 and has 11 years of experience in the lighting industry. He provides lighting engineering support for DOE activities within the commercial building initiative and the market based programs for Solid-State Lighting. Jason also manages the technology fact sheets program, producing educational materials on topics ranging from Solid-State itself to human factors in economics.
Edward will open by providing an overview of the Consortium. Jason will then present the model specification and explain how it can be customized to meet the particular needs of each municipality or utility in order to help them put together effective bid documents for LED street lighting products.
After the presentation, the questions received online will be addressed by the speakers as time allows. And now Ed will begin.
Edward Smalley: Thank you, Terry, and welcome to all of you joining us for today's webcast on the Consortium's Model Specification for LED Roadway Luminaires. It is important to thank all of those who have spent many long hours over the past year in putting the model spec together, of particular note however, is the hard work of Jason Tuenge of Pacific Northwest National Lab. And I wanted to thank him very much for his hard work with this document. By now we are all familiar with the drivers behind the heightened activity surrounding LED street lighting - energy efficiency, green image, ARRA funding, and ARRA funding goals and timelines, et cetera. The Consortium is intended to bring users up the learning curve as rapidly as reasonable, and in an effort to help those on the front lines of this implementation. In a moment, as Jason discusses the model spec, he will go over a number of the other tools we are working on for the end users that are out there, many of you on the conversation today. But for now I wanted to give you a brief overview of the Consortium, so let's take a look.
A little bit of background about the Consortium, created in 2010 using ARRA funding by the U.S. Department of Energy. The Consortium is supported by the Department of Energy's GATEWAY program. It is intended to be an educational resource on Solid-State street lighting and associated technology for those involved in lighting streets and other outdoor public areas. As an independent resource, the Consortium is available to help those unfamiliar with LED technology identify important issues and how to begin the evaluation process. So we have a number of folks completely unfamiliar with the technology, and one of the core functions of the Consortium is to help bring them up to speed with this, and to accelerate the adoption of Solid-State Technology in the nation's street lighting systems.
Our vision of course is to accelerate the adoption of high-performance Solid-State street and area lighting by leading end-users collaboration in the areas of performance, evaluation, application, and standardization.
The mission of the Consortium is to not only increase this knowledge, but also to develop a national structure that will help folks understand where they can go to get some independence guidance that is not only well thought through, but really has a good understanding of where the industry is and what the needs of the end user are. And we want to take that understanding and influence the standardization of different benchmarks, classifications, designs, and performances. And we believe that the tool that we are presenting today on the specification, the model specification, is going to be one of the primary tools used throughout the nation to help folks understand where we need to go in standardization.
So we have a number of far - - our membership is far-reaching throughout the country, and we even have a number of countries outside the U.S. that are participating with the Consortium. But as a rule, our primary membership is open to municipalities and other governmental agencies and utilities. In addition to that, we have others that are responsible for public lighting in different areas of the country. We have a number of guests that are found among consultants, members of academia, and a number of public service energy efficiency organizations. Advisory members are selected from those guests to participate on specific goals and task forces such as the specification here for luminaires and our specification, for instance, for adaptive lighting controls. Manufacturers however and their sales reps are excluded from membership, however, they've played a vital role in helping the Consortium with developing these tools and a number of them have been invited to participate on different task forces, such as the model specification for luminaires. And this is very much appreciated.
When you take a look at the scope of primary type organizations, well over 306 at this time, you can understand why the vast majority of those are municipalities, but there are a number of - - a large number of utilities, both municipality owned utilities and other publicly owned utilities, as well as IOU type but utilities that are out there, and then a number of non-municipal governments. And we think this is a very healthy makeup for - - that really indicates the representation of the ownership and those responsible for paying for the public lighting across the nation. As we know, there are well over 35 million street lights out there.
So when you take a look at the scope of the national map here, you first of all you notice there are some states that are not very well represented in the Consortium. But it was interesting to note that when we took a look at those registered for today's webcast, all 50 states were represented very helpfully.
So in taking a look at the downloads of the actual specification, there were a number of those who had expressed interest in receiving updates to that, well over 450, and so we'll continue to update this document. But for now, at this point, we wanted to just get right into the discussion of the model specification. And so I wanted to turn this over to Jason to get into the details. So again, thank you for joining us, and let's turn this over to Jason. Jason.
Jason Tuenge:Thanks, Ed. This specification, or model specification is actually one of several documents recently or currently under development. Accompanying documents on the way include a model specification for adaptive controls and remote monitoring of LED roadway luminaires. We will also be - - have also started to work on a cost benefit analysis tool. And are just beginning work on a supplemental guidance document to accompany the model specification for LED roadway luminaires. The idea of this last item is really to serve as a compliment to the specification itself. In terms of guidance, it's really supposed to give the user some more background as they go to customize this model specification to make it specific to their own needs. It is not intended to be something that would replace, say, guidance from IES. It's not supposed to be something duplicating such guidance; it's really geared just to the model specification itself. So in other words, this specification and guidance document even together will not prevent things like what you see in the image on the right where we have a luminaire, well, not directed toward the ground.
The development of the model luminaire specification has basically taken about a year. We started back in September of 2010 when the idea was first introduced at the inaugural meeting. This was in response to basically a survey of members, which indicated this was an area of interest to the membership. From there it moved on to a really early beta version that went to Kansas City, they were looking for some guidance. We got this version over to them basically to kick the tires and demonstrate that even in the early form it would be of use, and it proved to be the case. In April, after fleshing some items out a little bit, we went ahead and issued the first draft of the specification, so not Version 1.0, it's just still a draft at this point for a public comment, and got a lot of comments and a lot of feedback. And based on the feedback decided to go ahead and host a series of manufacturer workshops where we could make sure that whatever we're specifying by default in the document. And basically in its structure is something that the manufacturers could actually provide, and thereby ensuring that when specifications are produced using this model spec, it's something that manufacturers will be interested in participating in and will cooperate in submitting products that actually meet the specifications. So we had these series of workshops including some kind of more informal meetings at the IES Street and Area Lighting Conference. IES, sorry, being the Illuminating Engineering Society of North America. So these were just kind of wrapping up some final details as we went on towards release of Version 1.0, which actually happened in October, late in October.
So first, you know why bother creating a specification, why should the Consortium get into this sort of thing? As I mentioned before, Consortium members have already indicated interest in such a thing, and knowing this and basically we need to establish goals for what this specification would do. The idea is basically to take a lot of the specifications you see out there, they vary quite a bit in terms of standards that are referenced and whether they're referenced properly or not, and all kinds of terminology that you see out there. Basically harmonizing all this so that we're all speaking the same language and in a format that's fairly common, so you can compare specs more easily and adhere to them more easily. This is also intended to compile experience gained from members with Solid-State Lighting to date. And then take all of this and put it essentially into the form of a checklist, that's what specifications are good for, and make sure you don't forget various nuances because it's all covered in your specification. So this gives us a very robust document that you can just step through and make sure that everything is covered. This document will change over time as we learn from lessons in the field, and as we get information coming in from membership feedback from membership as well as for manufacturers. Last, I've mentioned several times that this is a model specification, it is not a standard. It is not something that you can basically just simply meet. It's intended to be something that any given user will adapt to meet their needs. So it's a moving target for manufacturers that gives flexibility to the user to make sure their own particular requirements are met.
So the specification is intended to cover streets and roadways, the title just says roadways, but that's really just for brevity, and then any adjacent pedestrian ways or bicycle paths. It is intended for pole-mounted luminaires. So these could be your cobra-head type products, or something like an acorn, a decorative post top luminaire. We are looking at both initial and maintained quality and quantity of illumination. Details of warranty coverage, rather than just saying five years and calling it good there, we actually get into some specifics. Plus a number of other items, of course input power, we're definitely concerned with being able to track energy savings and energy use. As well as some other items like electrical immunity, resistance to the elements and vibration resistance as well. We look at the LED drivers, including the interface of the LED driver with any controls that might be used beyond simple photo controls. We don't specify the photocontrol itself in the document, but we do have a place there for photocontrol receptacles. So what does the spec not cover? It doesn't directly cover simple lamp/ballast retrofit products. These can be appealing in certain applications, but you have to get into a little bit more detail. For instance, what if the product is going in behind an existing lens, do you really know what the output is going to look like? You know where is the light going, how much is there? More detail would be needed. You could still use the spec, but you'd need to add some more elements in there to cover items like this. It doesn't address lighting control systems. So adaptive dimming, remote monitoring, things like that, we decided to keep that in a separate document. For one thing, it may not be utilized on a given project at this time, and for another, that's a very tricky specification unto itself. We kept that separate so we can tackle it in parallel. It also does not, as I mentioned earlier, cover or provide a lot of guidance in terms of lighting design, this is really left to IES. It doesn't even give you a lot of explanation in terms of what values to choose or whether you might need to change something, maybe fault spray testing? Depending on where you're located it's assumed that the user knows these things, but as I mentioned, we will be putting together a guidance document to help with some of this decision making and to clarify the basis for some of the default values that are given.
The specification structure and some of its content really came from a specification that already existed for parking lot lighting developed by the Department of Energy Commercial Building Energy Alliances, or CBEA. This spec is just for LED products and it's, again, this is what we used basically as the starting point, and then tailored it to meet our needs for roadway lighting. And also updating a few elements. We will continue to stay in sync with the specification as its updated, again, trying to keep some commonality for all these different applications and products. What's nice about this specification is that it really looks at application specific performance, rather than just looking at say the output of a luminaire. It actually specifies things in terms of illuminants. So you need to know your mounting height, your pole spacing, et cetera, to actually find out how the product is going to perform in a system. As a result you cannot get a single qualified products list from this specification. You know performance will vary from application to application. We like this idea and incorporated these elements into the specification. Going one step further, rather than being a static document issued in a PDF form, this specification is out there as a Word document, meant to be edited by the user, because the needs will definitely vary from locality to locality, and based on the type of user, the city or utility or something else. Then the other thing is that we had in giving users the ability to tailor the spec to meet their needs, and recognizing differences between municipalities and utilities, we set up a structure whereby the user can specify either illuminants or luminants based criteria, so it is application specific. Or being able to specify it based on just the product itself not really knowing where it's going to go. And this is largely to recognize the situation of utility space where you're really just replacing products on poles and not knowing necessarily what the spacing will be between those poles.
So the specification is structured such that there are basically two documents that you work with, two files that can be downloaded. One contains some instructions, the body of the text and most of the appendixes. And then another file is your Appendix A. I'll get into this in a little more detail shortly, but the idea being that most of your spec is contained in a single document, and then you can choose which Appendix A you want, whether it's going to be application-dependent or independent. The instructions are meant to be read before being deleted. I say this a little bit tongue in cheek because we've seen some adopters, some early adopters of earlier drafts of the specification, namely the April draft that appeared to have simply deleted some sections that really shouldn't have been deleted. So it's a good idea to read the instructions just like you would for anything else. Body of the text will look very similar to a lot of other specifications. And then the appendixes basically allow for deep dives into various topics. Appendix A basically takes all of your very specific criteria for any given product types. So say you're replacing 100 watt and 150 watt luminaires, you probably want to treat those separately, they might even have different housing colors, and so one being white and the other being gray maybe. So Appendix A gives you the opportunity to specify criteria that are specific to your 100 watt, and then on a different page, specify everything specific to the 150 watt replacement. So that's really the idea of Appendix A. Appendix B gives us a chance to do a deep dive on how we characterize lumen maintenance, lumen maintenance being a very important characteristic for LED products. That's really how lifetime is evaluated for the most part for LED products. Product family testing, testing can become a real burden for this new technology. Testing is necessary because it is new and we've got to make sure we know what we're talking about and what we're working with. But we need to be realistic in terms of how many different product configurations can really be tested without making cost become a major issue. Appendix D is a pretty major item in terms of contribution from the Consortium. We've developed essentially a new standard for electrical immunity and we'll be working with ANSI to see this become a standard at some point, hopefully. But again, for now this is simply a voluntary model specification, so it's just kind of a starting point, kind of a nebulous standard here in Appendix D. Appendix E then is your submittal form. This is what the manufacturer uses as they submit for any given product type, they can go through and indicate this is how much light my product actually produces, this is the wattage, et cetera, et cetera, so it's all very clear and concise as they submit documents.
So the body of the text looks basically like this, your basic specification format. We've whittled it down a little bit, it used to be longer than seven pages, seven pages still isn't one page, but basically this does a pretty good job of very concisely hitting all the important points. You see some text in red, that's hidden text that when you print isn't supposed to show up. So when you issue an RFP, make sure that text doesn't show up. This basically, this hidden text basically serves as interim guidance until that guidance document itself is created. Once that's created we'll probably get rid of most of this hidden text.
So in the body of the specification, we look at not just LED-specific items that also some items that really have nothing to do with the LED technology. This is a decision made early on. We really wanted to give users something that was self-contained to the greatest extent possible so they wouldn't have to have kind of a basically relying on say HID specifications being referenced or paint finish and things like that. You can still do that via the document, it has the ability to reference other documents. That's perfectly fine. We tried to cover as much as possible because frankly many users will not have any specifications of their own. So it gives a good starting point, everything in one location. It's been interesting going through all these items in the body of the spec. Every single item as you move through it when you discuss with manufacturers and users, they all have their own ideas of how it should be treated. And as we look at LEDs with a magnifying glass, we keep finding over and over again that this magnifying glass should also be applied to a lot of things that existed before LED technologies. So we've got a number of things that are there, basically as a consensus value for the time being, but we'll probably be revising these default values over time. And these default values are really based on, in large part, finding something that's reasonable in terms of costs, and often we're deferring to the same values that have been used for HID products in the past. One item that we get into, obviously we deal with LED luminaires themselves as a complete system. We deal a little bit with the LED light sources themselves, but really you care more about the complete system. But then we also have some items covering LED drivers, you know the power supplies for these light sources. And specifically we're interested in the interface that we're going to have with any controls that are going to be out there acting on the luminaires, controlling them. And we also want to know if these things say will be dimming or dimmable, what happens as it's dimmed? When you say 70% are you talking about light output or wattage or both? So how do these things looked based on the control signal that the driver receives.
Some items that are not specific to LED technology include things like serviceability and resistance to the elements. So for instance, salt spray testing, UV testing, ingress protection ratings to keep out insects, things of that sort. Definitely not specific to LED, but things that we have tackled as part of this specification. Also vibration resistance, you've probably heard that LEDs are essentially immune to vibration, and it seems to be true for the light sources themselves. But if you think about it, there's more to an LED luminaire than just the light sources, you've got wiring connections, and the LED driver and other components, and if these things aren't all secured properly in the luminaire, they'll rattle around and fail just like anything else would on a bridge application. So we do get into this, fortunately it's a fairly easy thing to specify. Interestingly in looking into this, found that there does not appear to be a vibration or resistance standard for HID lamps. They're just tested basically just the fixture because they know the lamp is going to fail, so, interesting.
Looking then at the appendixes, Appendix A is, as I indicated earlier, is broken down into one of two options, you shouldn't use both. You decide whether you can realistically set criteria based on typical geometries and light level requirements for a given product that you're replacing. So if you've identified a 100 watt product, which might be a Type 2 or cut-off, or whatever, but it's what you call your 100 watt product, you should have a pretty good sense of what it can and cannot do and where it's used. So ideally you can get in and set up site specific typical parameters that your 100 watt meets, and then say that your LED products also have to meet those values. The alternate is to look at the luminaire level, not knowing anything about the site, and just take your best stab at equivalency, looking at things like output and wattage. It's worth noting that whereas the body of the specification can, for the most part, just be left as it is, Appendix A must be edited by the user. The values there will not be adequate for your application. We specifically chose an unusual wattage for this sample that's shown in the document, with the idea being that hopefully nobody will take it as it is and make that their spec. The idea is to take the sample that's given and edit it to meet your needs, and definitely do not simply delete Appendix A.
So looking at the application-dependent version of the specification or the system specification, what we see here is something that would be familiar to anyone who has operated lighting software. You basically dial in all of your site geometry information and your pavement type, as well as some information regarding your criteria. So you might be following IES guidance, or you might have criteria of your own, but whatever the case, it should be specified. And if your existing product meets these requirements, then so should the LED products. We also have something built in here to address mesopic multipliers. You've probably heard by now that broad spectrum light sources are generally better tailored to low light levels in terms of visibility. And we only recently have we received guidance from IES on how to make use of this information. So it is pretty limited in terms of where you can use these multipliers. The big one is that you're not supposed to use them in areas above 25 miles an hour, so that gets a little bit tricky, but we have incorporated this in the specification, it's just defaulted so that it's not really doing anything unless you make use of it.
So then at the bottom of the page for this Appendix A system version, we've got some other elements like input power, CCT, voltage, other things that are going to be specific to your product. Also, the driver interface and vibration level.
I want to emphasize that it's no trivial task to set up these typical or representative scenarios for each luminaire type. This is something that needs to be done early in the process and not put off to the last second. You know you want to make sure that you really know how to characterize performance for your existing and your future, say LED products. In reality, things like pole spacing do vary in the field. And as I mentioned earlier, this is why we created or offered an alternative to the application-dependent version of Appendix A. The independent version is primarily geared toward utilities where pole spacing is almost random and they just need something that basically performs like what they had before. So rather than just ignoring this need, we're accommodating it, but identifying that this is not the preferred approach, this is just the approach you take when you really can't characterize typical performance or typical requirements. So we've got a portion at the top that basically describes the existing product, just to get people in the ballpark, but these are not requirements, these are the values in orange. Then below in green are the actual requirements. So similar to the system, but really scaled back because we don't know anything about the site or even the light level requirements, all we can really talk about is wattage and output and things of that sort. And then again, some other non photometric items, you know voltage and vibration, et cetera, just like the system version.
Appendix B, because lumen maintenance is not a simple thing to evaluate, we allocated room for this topic in its own appendix. We did update it just recently. As I recall, TM-21 was released in August of this year, so not long ago at all, and we've already incorporated that, but with a caveat that TM-21 is really only telling us about the light source installed in situ. So TM-21 tells us how the light sources will do over time based on available data. It does not tell us if other things might fail in the luminaire. I mean you might have your driver fail before the lights get too dim, or before the LEDs get too dim. You might have other things happen because it's a complete system and TM-21 is really just geared toward the light source, but it does look at in situ thermal operation in the luminaire, or it allows you to do so. So basically we offer two different approaches for evaluating lumen maintenance, and this is definitely parallels earlier criteria from ENERGY STAR where you can make use of LM-80 data. Again, data that's gathered just at the light source level, not at the luminaire level. But then you take some temperature measurements at the luminaire level and that allows you to do some correlations and some calculations to find out what your expected lifetime is using the TM-21 methodology. So that's one approach. The other approach is to not even use LM-80 data, simply take the luminaire and let it run long-term. So analogous to LM-80 but now we're running the whole luminaire. This would be preferable because then if something like the driver fails, that's captured in the testing. But because of all the different configurations that are out there, it's probably unlikely that we're going to see a lot of manufacturers take this approach. It would require a lot of testing and it's not something you find being done with other technologies like HID.
So some earlier criteria before TM-21 was available looked at basically how much, you know, what percentage of initial output is maintained at say 6000 hours of operation. This method assumes that all manufacturers follow the same kind of a form of decay. TM-21 gives us something better, and so we're taking that approach anyway or instead. So then looking within this approach, not only do we allow two different methods of demonstrating maintenance, you know either using LM-80 at the light source level or testing the whole luminaire. We also then have requirements in terms of how much light needs to be maintained, and there's two different ways you can approach this. One of them is to let TM-21 do its thing, and maybe you specify a point in time and say that I want to know what all of the products I'm looking at, how they're going to be doing after 10 years of operation or nine years or something, and you set a point in time. And you find out, okay, this product maintains at 90% of initial, whereas this other product is down at 60% of initial. That's one approach you can take now that you have TM-21. The other approach is the more traditional approach, which is just to assume that all products are going to be replaced when they drop to 70% of initial output, so L70, as you've probably heard referenced often in giving lifetimes for LED products. This is consistent with the IES Lighting Handbook where they indicate that basically as a conservative means of estimating what these things will actually look like when they're replaced. You know assume that they're going to drop down to 70% and maybe even lower. This is a little bit problematic because you don't get credit for products that actually do better than this, you know that will maintain, well basically that you are going to be so far in the future before they hit L70 that you might have replaced them by then anyway. So it's a little bit problematic in that regard, there's some implications for pricing and lifetime. So we give both options because we know there's going to be demand for both, and we'll give more guidance for this in the forthcoming guidance document.
One thing worth noting, that only makes things a little bit more confusing, is that some products, probably more and more, will not actually have light output dropping over time as you would expect when you just run your product at constant drive current or constant wattage. Some products are basically under driving or being under driven initially so that you don't have to over light initially and use more wattage and more LEDs, probably a more expensive product. Basically it allows you to get some savings upfront and then ramp up your wattage over time. So it's an alternative approach that we're probably going to see more and more people pursuing.
I mentioned before, product family testing is something we want to acknowledge. You see all forms of how this is implemented by different programs. In this document it seemed most realistic, basically to offer some guidance so that users understand that they won't necessarily see or have readily available an LM-79 photometric report for the exact configuration they're interested in. So a type three of a certain bug rating, et cetera, et cetera, and a certain correlated color temperature, there's a good chance that when they ask for a certain thing it has not been tested and it may take awhile to get tested. And a manufacturer offering hundreds of different configurations, you probably can't expect them to test every single configuration. Again, they don't do that for HID, probably don't need to do it for LED either, but we need to keep a close eye on any interpolation that is performed. And there probably shouldn't be any extrapolation unless it's conservative. In other words, you're just taking worse case and then saying, "Well, okay, these other ones will all do better than this case. So we offer some structure in terms of how to evaluate this and the structure applies to LM-79 testing. The same concept basically applies to temperature measurement, or in situ temperature measurement testing, ISTMT, but does not really apply to LM-80 testing for the light sources themselves. This gets pretty tricky, especially as we look at generations being updated. You pretty much just have to look at the report, the LM-80 report and see what's covered and what isn't.
So looking at, say, LM-79 testing, the photometric testing for a product family, you can basically boil down in some cases, not all cases, and it needs to be something that's actually supported by the manufacturer, you know that they know how to characterize their products. But rather than, say, having 108 tests that you need to perform for a number of, you know for 108 different configurations, you can boil it down to something more like 10 tests where this one set of tests can allow you to do some interpolation with pretty good confidence that you're going to have accurate results. So one way to do this, as we've illustrated in these tables, is to test several different distributions. So like Type 2, Type 3, Type 4, all at the same correlated color temperature, so color appearance; drive current, so basically how hard they're being driven, which impacts lifetime and efficacy, and the number of LEDs in the product. These are some pretty common variables as you look from product to product. So if you test them all, hold these other variables constant but test different distributions, and then for one of the distributions play with the other variables. That allows you then to go back to the distributions. If we tested in test four through 10 the Type 4 optic, you can then find out or estimate pretty accurately what your Type 2 distribution would look like at things other than 4000 kelvin and 700 milliamps and 80. You can take a look at 5000 kelvin for Type 2, or 325 milliamps for Type 2, just by doing some interpolation based on the available test data. And this is basically what we're showing in the second table here.
As I mentioned before, electrical immunity, this is actually something that - - it's our only task force that we've pulled together to date, specifically within the realm of this specification where we saw an item that there was no clear cut answer to. And so we pull together a number of experts and identified problems with existing standards that are often referenced. Some of them are very outdated and still referenced by a number of specs. And then also referencing good standards, but just doing it improperly. And then also really honing in on LED in particular, you know what are the needs of LED products? Are they more sensitive? How do we cover that? So basically we look at these IEEE recommended practices as our basis for criteria and testing, but then basically choose what we want to make it really fit our needs. So from these standards then we get a set of tests, and the ones that are most relevant are Ring Wave, Combination Wave, and Electrical Fast Transient. In the body of the specification, the user is able to choose between one of two options, basic or elevated. And this really pertains to the combination wave test and associated criteria. Ultimately then the user of the spec, because all of this is already covered in Appendix D, all they need to do is determine whether they want basic or enhanced, understanding that if they choose enhanced that's going to be more expensive, and may not be appropriate for their application. In some areas you see a lot more lightening than others and in some areas or for some customers basically the expectations are higher for resistance to variations on the power line and the sensitivity of products. So based on how long you expect the product to last and what kind of environment you're in will determine basic or elevated. And this will be another thing that will be elaborated on in the forthcoming guidance document. One more thing to point out is that this is one where there doesn't seem to be a clear-cut answer for everyone, so for the time being we're just simply asking manufacturers to indicate the failure mechanism. Does failure of this immunity system result in power being disconnected to a luminaire? We aren't specifying one way or another, just want to make it transparent for the user so they can determine themselves what's going to be appropriate.
Appendix E is our submittal form, as I mentioned earlier, this does not cover every element in the specification so it's a little bit risky in that regard. You can't get lazy in reviewing submittals and just assume that you can review the submittal form and be done. It's just meant, it is kind of a table of contents where you can go through quickly and check some key items, but you still want to go through and make sure all of your criteria are met.
I mentioned that early on when the specification was really just in beta version, we were approached by Kansas City; they were interested in getting some guidance. We thought, well, this is a good chance to test out the concept and got them to work with us so that we can have a number of products installed out there. There's an RFP issued based on the specification, again, tailored to meet their needs. And since I personally have been on site there have been tours taking people through the various installations ranging from 100 watt replacements to 400 watt replacements and basically the project was a success. I mean the specification was in its early form, there are definitely improvements that have been made in the meantime, but even as it was, they felt it was very useful in terms of getting an RFP out there that insures they're going to have products which meet their needs. We have performed measurements out there, we have consolidated our findings to some extent, but we have not yet issued a report on this project.
We have, I'll also mention this, we've had a number of municipalities that we've heard about and seen some of the editing done to the April draft where they just needed something, kind of like Kansas City, they just want to get going and needed some guidance. In some of these cases, unfortunately, we're seeing things like just deletion of the appendices, which basically makes the spec so it doesn't do anything. So that's been a little bit interesting, but it was an early indication that there's a lot of interest out there and some urgency. We've had others indicate interest as well, and one of these is actually, well, there's a group out in Iowa that's actual been among some of these early adopters who also had interest from the Bay Area Climate Collaborative in that they've been waiting on Version 1.0, and so we'll be talking with them in the coming weeks to see whether it's going to be meeting their needs, what kind of edits they might be making and what kind of projects might be springing out of this. So it will be interesting to watch that one. In addition, I personally have been working with the City of Philadelphia, PNNL and DOE have been supporting a demonstration project they've had in the works recently through the Consortium. And as part of this process, they have definitely come to appreciate some of the complexity in the process and the value of a specification to make sure that their needs are going to be met.
So what's going on right now in Philadelphia is that we've got a number of products that are going to be replaced or that they are considering replacing. It's a very early stage right now, we're not at the point of replacing thousands of luminaires, we're just looking at quantities of say, four, and just kind of kicking the tires, the technology, and they're getting acquainted with the technology. We're looking at a number of different streets, looking at performance measurements, and just doing some visual evaluations and seeing what residents think of the technology. Also, there's one application where it's not a bridge but a light rail structure that they're mounted to, and I guess the HPS don't really do too well there. So we're going to see if in fact the LED products really perform well there and if the existing standards for vibration are a good indicator of whether they'll survive in that kind of an environment. At this point we've basically ordered all the samples, I think almost all of them are in, there's just a handful that are still on their way. We'll be out there taking measurements pretty soon, performing some surveys of residents to get some feedback, and then eventually issue a report. Working with the city, again, PNNL is representing the Consortium in this project.
The first product being looked at is 100W HPS. We've got a dollar sign there basically indicating that this is one, you know the lower the wattage basically the better chance the LED has of replacing the product cost effectively. For the 100 watt HPS we're going to be looking at both field measurements and visual evaluation, and we've found quite a few products that fare well against HPS at this wattage.
This is the light rail structure that I mentioned. Here they've got some 150 watt HPS luminaires mounted and kind of an unusual configuration where instead of pointing out into the street they're pointing out away from the street. You can see why this is the case based on the mounting configuration. We've got - - we're going to be looking at vibration here. We may actually install some sensors to see what's actually happening out there in the terms of vibration, but the most cost effective thing will probably be to just simply do some correlations between product claims or ratings versus results in the field. We are looking at one retrofit kit as part of this evaluation, or at least I believe that's still the case, just to see how that one fares.
250 watt HPS for awhile had only found one manufacturer, and then one of the newer products that just came out also offers enough light output to replace HPS at this wattage. These are probably not going to be the cheapest of products, so it remains to be seen whether it's going to be cost effective, but we do seem to have the performance, and by the way, this evaluation is using this simple L70 basis, assuming LED products will drop over time to 70% of initial output before being replaced. So it's kind of conservative in that regard and we may be able to find some better options using TM-21.
So what's next? We had used - - we have created a task force to tackle electrical immunity. We will probably do the same for some other topics, and here's kind of laundry list of other items that came up in discussions internally and with manufacturers for things that have been identified elsewhere and we're just kind of compiling a list of things we'd like to tackle. End-of-life indication, you know you can't tell just by looking at the light whether it's at 70% or not. So do you need to get out there and take measurements every now and then? Are the TM-21 calculations perfectly accurate? Do we want the thing to cycle like an HPS lamp to indicate that it's failed? These aren't - - there's no easy answer to these things, so we'll be doing a dive into that most likely. Looking at the method I described earlier whereby products are operated at partial output initially and then ramped up over time as a means of saving energy and actually using cheaper products basically, potentially. It's kind of a sticky topic, but one that's very interesting and worth looking into. Warranty coverage of lumen maintenance was something that was definitely of interest from the user perspective, but there's some practical issues of obtaining results that are accurate and enforceable in terms of warranty. There's a lot of uncertainty in field measurements, for example, so how do you really know how much the typical luminaire has dropped to? When you sample products for a lab testing, how many samples do you need? What are the tolerances, how do you deal with those? So it's a complicated subject and we'll probably tackle via a taskforce eventually here.
Looking at the material approach to Appendix A, you know the application independent where you just look at the luminaire level, possibly trying to look at some different metrics that might dial in a little bit better, rather than just downward luminaire output. Looking at other characteristics that might give you a better sense of where light needs to go. Also looking at housing finish durability, assuming they actually already tackled pretty well so I'm not sure this is going to be the most critical of items. Characterizing dimming performance, there's a lot of work to be done here just to really all be speaking the same language. LED package reliability, there's some standards already out there, JEDEC and JADA being the two that are apparently most common. But these are very tricky to really standardize on in a specification. And, yeah, this will take some more work if we are going to incorporate something along these lines. And last, we really want to move a lot of this content over to the ANSI committee working on a document in parallel with us. C136.37, the American National Standard for Roadway and Area Lighting Equipment – Solid-State Light Sources Used in Roadway and Area Lighting, was released just recently; I think it was in September. So this is something else that we - - now that it exists we don't want to simply defer to it, we want to make sure that in a specification it's doing what we need it to do. But at the same time as items agree between these specifications or between the standard and our specification, we want to point to the standard, just to make the specification briefer and more harmonized of what's happening in the industry. So we'll be working closely with them as we move forward.
We'll be updating the specification continually; this isn't going to happen every four years. As we see something is important to update we'll do so, just like you would with software. We'll be issuing some reports for demonstration projects, and identifying new demonstration projects as we move along to make sure the specification is working and being adjusted as needed. It'll have a controls specification to accompany it fairly soon here. They're pretty well into it, but still months out. The supplemental guidance document is just getting underway so probably a little while before that's ready. And we may eventually do some other specifications, but we'll make sure that if we do dive into this it's well coordinated with other existing specifications like those from the CBEA. And that is the end of the presentation. At this point we will begin fielding questions. Thank you very much.
Okay, so, the first question that came in was regarding the instant on capability of LED products, and whether people are trying to use motion sensing for control of street lighting. This is something that is being implemented in parking lots, and that's still a pretty early application because the sensors aren't all necessarily compatible with such an application. In street lighting though, it's not necessarily as appealing. Drivers basically need to have the luminaires come on well in advance of the car and that's probably well beyond the reach of a sensor attached to the luminaire, for instance, so you have to put a lot of thought into whether you're going to be controlling by motion sensing. And even then it's probably a better idea to use dimming, rather than simply switching luminaires off. So it really depends on the application for street lighting motion sensing, and especially switching on the basis of occupancy is probably not the best application.
Next question that came in is: What's the reduction in maintenance cost that we can expect with the installation of LED street lights? And I'll hand this one over to Ed, given that he has some hands-on experience with this.
Edward Smalley:Sure, Jason. And I think it's one of those questions similar to others where it really depends on the application. It depends on a number of factors of the incumbent system, what your current maintenance costs are, and what your future maintenance plans will be. As an example, you may simply have a HID system where you go out every three or four years and you re-lamp. You may do that on a group basis, you may do that on a spot basis, but the bottom-line is, you add about every three or four years you've probably replaced a quarter of your system. And then from there at that same time, you probably go out and clean that lens on that fixture. Well, as you start looking forward to a LED installation, you're going to have a system that's not going to need those lamp replacements. It may not see a 70% reduction in lumen output for 12, 15, or even 20 years depending on the predictor chip that the manufactures use and et cetera. But you might decide that you want to, as an example, clean the lens. You have someone go out with some solution and spray from the ground every seven or eight or 10 years to keep that lens clean. So it's going to depend. I know that in Seattle we've seen some drastic reductions, more than a 50% reduction on the energy so that hits the cost there, and we're projecting a 50% plus reduction in the actual maintenance cost. So it really depends on the system, but you've got to look at those existing factors and your future plan.
Jason Tuenge: Then to clarify one item there, it's not just a matter of the LEDs that are incorporated in a luminaire, it's also a matter of how hard they're driven, and you know what the drive current is. One way to get a cheaper or less expensive LED product is just to drive it harder and use fewer LEDs to get the same output, and that ends up giving you a product that doesn't live as long. So yeah, again, it really depends on the design of the product and your own expectations and maintenance plan, et cetera.
Edward Smalley: And that's an excellent point, you've really got to be cognizant of how you're planning on using the system after it's installed.
Jason Tuenge: Next up, another question for Ed. What approach would you recommend for municipalities working with utilities that do not believe LED is a viable technology at this time?
Edward Smalley: A very good question here as well. One approach I would recommend is nonetheless, most municipalities have the ability to do testing on their own and to do evaluations. And to really look into the cost and benefit analysis of the system and then work - - I recommend you continue to work with that utility so they can see the results, and then as a team, hopefully you can make some really good decisions together moving forward. But as we all know, that's not always the case. We aren't always as fortunate to have a great partner, and so it's something we want to have. But my advice would be to do some evaluations, and either way, but it would be best to be doing that with the utility.
Jason Tuenge: Okay, so the next one is: What reduction in lighting triggers replacement for LED lights? And so, you know as I had mentioned the failure mechanism that's expected for most LED products is not for them to just simply go out. They are probably going to dim to an unacceptable level before they simply go out. And that may take a long time, but that's probably the likely failure mechanism, at least for the LED light sources themselves. So what triggers replacement really again depends on the application. Unfortunately it's not simple. One thing you hear very commonly is L70 or the point in which you drop to 70% of initial output. This isn't necessarily something that is going to be appropriate for any given application. Some users may only want to have 10% reduction and output over the life of the product. Some products may not give you much of an option; they only drop that much so you'll never hit L70. So it really depends and it takes some scrutiny to see what's going to be required. As I mentioned, one of the items that we may look at as a task group, a separate task group from the one we used for electrical immunity or that we created for electrical immunity. We might create another group that looks at indication of when these LED products have dropped to some percentage of initial output. So that's one thing we'll be looking at. Another item worth pointing out again is that some of these products may be designed to maintain constant output, and really it's the wattage that's changing, i.e. increasing, and so then it's a question of what point does the wattage become unacceptable and you need to get out there and replace it. So food for thought, but it really depends again on the application.
Another question for Ed. Do you have a timeline for the availability of the additional materials?
Edward Smalley: We do have a timeline that we're working on, and a lot of this is fluid because we really want to make sure we are doing a diligent job and making sure the information is accurate. But as far as the model spec for adaptive control and remote monitoring, we're looking at being able to publish a draft for public comment in the first quarter of 2012. We think it will be early in that quarter, end of - - well, in January, February, but I don't want to put that date out there because we do want to make sure we've done our homework on our end of getting this thing as good as we possibly can. We're looking at a guidance document, however, for the model spec for luminaires, and we hope to actually get some guidance up on our website here within the next week, couple of weeks. We actually were looking at some drafts here over the last couple of days where we want to put out some guidance a little at a time that we think might help, that people need immediately, and then we're looking at the second quarter of 2012 having a full-fledged document available to folks. And then lastly, the cost benefit analysis tool, we are very, very close on that. We actually believe the tool is ready for publishing, but we also think it's important to have some really good guidance with that tool so that people don't get frustrated. So we were actually ready to release that in the beginning of October, but we're holding back for several weeks here and we think our goal is hitting the end of December here or early January to get that out with some good enough guidance so folks won't get frustrated. Because that's a different tool that folks may not be used to using, a financial guidance tool in the lighting world.
Jason Tuenge: Okay, next question: How applicable are these model specifications to highways, in particular, junctions like on ramps and off ramps? Basically the specification is, again, it's a model specification so it's meant to be tailored to meet your needs. And, excuse me; basically the user is definitely free to adjust either the table back in Appendix A so that it captures the necessary information for doing calculations and lighting software. In addition to this, if the user feels it's necessary or helpful, they can by all means insert drawings or sketches to show what some of these dimensions mean, and then that helps to ensure that you're not going to have manufacturers misinterpreting these values, and then running calculations that actually don't really apply to your project, so absolutely. You know this specification can be used for things of this sort, but of course make sure that you're not in conflict with anything that already exists locally. You know, for instance, Caltrans and Minnesota both have some specifications of their own. So yeah, just make sure that you adhere to anything local and for the most part you can apply this to really almost anything. But the more you deviate from typical street lighting or roadway lighting; probably the more difficult it's going to be to customize your spec. It still serves as a good starting point though.
Edward Smalley: Jason, I want to back up just a little bit.
Jason Tuenge: Oh, go ahead.
Edward Smalley: You touched on the Caltrans and Minnesota, and I think with this question it's important to note they, especially Caltrans, they are actively using LEDs in highways, so it really is we're talking about applications and how these things are used, and I just wanted to kind of point out that using LED street lighting on highways is not only a probable, but it's an actuality.
Jason Tuenge: So next question: Are there DOE or other funds or resources available to assist in modifying the spec to fit their individual needs? In other words, is there help on a case-by-case basis from DOE or the Consortium to customize these specs? So I'll give this one over to Ed.
Edward Smalley: Sure, and the extent of modifications needed will depend on the needs of the local jurisdictions requiring and understanding of the local installations, and they also require a consultant to assist. So depending on the knowledge base of that local jurisdiction, the DOEs primary support, however, comes through the Consortium in this fashion. And as evidenced through the spec, the model spec, the only spec support to a municipality would come if they were selected as the focus of a Consortium demonstration as Jason was just pointing out, Philadelphia for instance, and Kansas City. In other words, they would be the host. So other than that, support is mainly focused on educating people on how to tailor these specs and these needs. But as we said, when we do work with these hosts, we want to make sure that we provide those - - that guidance as needed.
Jason Tuenge: And next up: Does the topic of electrical immunity address potential damage caused by lightning strikes? In general, what type of lightening and or surge protection should we expect to find built into LED fixtures? For this one, I'm going to hand this off to one of my colleagues, just actually down the hall, Michael Poplawski from PNNL who has helped development of, he was on the task force for electrical immunity, so he helped develop that set of criteria for this specification. And he's also helping out with development of the controlled specification that's still in development. So with that I will hand it over to Michael.
Michael Poplawski:Hi, thanks, Jason. So absolutely the electrical immunity requirements were intended to address not of course direct lightning strikes, but induced events, electrical events from lightning. To answer what type of protection should we expect, there currently appears to be definite variation in the market and what level of protection is provided in products, and how it's provided. The IEEE documents that Jason referenced have a long history behind them, presenting information, detailed information that attempts to model the environment, the outdoor environment for the creation of surge events. And that presents models for how to simulate those electrical events that are induced. And as Jason mentioned, the requirements that were put together of course leveraged heavily that material that recommended practice or guidance. And the levels that we selected, we offered the ability and the specification for the user to select, again, kind of a basic level of protection as defined or referenced to the IEEE recommended practice, and then an elevated level of protection. And how they correlate to what you're going to experience in the field is a much more detailed question based on where you are and what type of events you see. So hopefully that sort of answers the question and we can get into more details at another time if necessary.
Jason Tuenge: All right, well thank you, Michael. We've got a lot of questions coming in and we will definitely not be able to get to all of them. Basically just keep moving through them, so far they've all been good questions, so sometimes we have to just simply disregard some of the questions that make no sense, but we're actually getting a lot of good questions.
Next one is: What does the 25 mile an hour requirement in Appendix A refer to? And this is getting back to the mesopic multipliers, so basically accounting for the benefits of blue content in a spectrum in terms of visibility at low light levels. You know we do now have guidance from IES in terms of how to incorporate this and adjust requirements accordingly. But a really big major consideration for mesopic multipliers is knowing whether you're going to be installing luminaires in a zone that's less than 25 miles an hour because this is really where they're applicable. So this makes it difficult, as you might imagine, in terms of specification. Do you really know that, say, all of your 100 watt product, you know 100 watt HPS luminaires are all in 25 mile an hour zones? Not necessarily. So you've got to be careful in replacing them. So that's there basically as a reminder. So it can by all means be stripped out and then the mesopic multipliers stripped out as well, just to avoid any confusion. But if you want to use them, they're there for some guidance.
Next up: Does the model specification clarify the ambient operating temperatures the average the luminaire will be exposed to during operation when energized, or is the maximum temperature the luminaire will be exposed to during operation? This is definitely a tricky item, and right now basically what we're doing is defaulting so that there is no benefit or reduction due to ambient temperature. You know the value in there is basically assumes that you're at 25°C ambient. You know reality will differ and will often be lower than 25°C ambient. The guidance document will really do a pretty good dive into this subject. It's going to vary by locality and whether one metric or another works better for any given need in your specification. It's going to take a lot of explanation, we can't cover it all here, but yeah, we will be looking at this item. And currently we're not really giving credit for the lower ambient temperature at night, so it's conservative in other words.
Next question is: Will this new document and method be the industry standard for performing roadwork re-lamping, or lamping, re-lamping, and retrofitting with LED fixtures? Do these documents need to be submitted and monitored through the DOE when jobs or bid are submitted? As I mentioned several times actually, this is definitely not a standard. When you release something like this though it can, you know if it proves very popular, become kind of a de facto standard, but again it's a moving target, there is no single target to hit. It depends on - - you know criteria will vary from city to city, utility to utility. So that's one point. The other point is does this need to be submitted through the DOE? I want to say yes because we want to track all these projects and get a sense of the adoption of the specification. But there is no such requirement, you can definitely just take the spec, do what you want and not give us a heads up at all, you're free to do so, anyone that wants to use the specification. But we definitely appreciate feedback and we also like to hear whether the specification is being used and what changes are being made to the specification.
Edward Smalley:Excellent point, Jason.
Jason Tuenge: So last question, well maybe we'll get one more in still before - - after this one. But question now for Ed. You may want to address the tariff utility cost implications if the fixtures consume more energy over time, specifically where street lights are built by the utility on a non-metered flat rate basis. So to clarify, this is pertaining to those cases where rather than letting light output drop over time, fade over time as it naturally would with these products, you increase the drive current to the products to maintain constant output that results in increased wattage over time.
Edward Smalley: Oh, okay, actually I read the question a little bit differently, but I think we can answer both of those, and we might even be able to tie in the next question on roadway luminaires pricing, et cetera. But as Jason mentioned earlier, when you look at the expectations for HID they were pretty loose and then when you start looking at LEDs, people are starting to look with a magnifying glass on what the expectations are in a lot of arenas. And I think this isn't any different. So my thoughts are simply that when you install this, just like you do your simple HID fixture, it's basically average hours over a 12 month period and the initial energy you use, and so that's basically how the tariff is built. However, if you decide to use controls, Jason was just alluding to, then I think I wanted to see if Michael had some thoughts here, but we are looking at that specification and we're really talking about how accurate will those controls be? Plus or minus 2% accuracy, which is meter rate. But there are some questions in there, and I think it really depends on how you're trying to do this. The overall point, however, is you will have to work directly with the utility, and a good case study for that is going on in the Bay area where San Jose and others are working with the folks down there, the utility, oh I can't remember the name for some reason, to actually, their testing this actual procedure right now, this process of using controls and what happens with part night dimming, et cetera, et cetera. So that's kind of a brief answer there. That other question I wanted to roll in is that you're seeing prices of fixtures come down, I think over the last 10 months they've come down more than 25%, so there you have it.
Jason Tuenge: And that leads us in then to the next question regarding the pricing of LED products dropping over time, and that's yeah, as you just indicated, that's definitely the case. Prices are definitely rapidly dropping. But we will continue to see that basically as the wattage of the HID product you're replacing goes up, so does the cost of the LED luminaire. So what we're probably going to see is where maybe 100 watt currently makes sense in a lot of cases and maybe 400 watt is a little tougher, over time we're going to see that say 400 watt makes more and more and more sense as that price continues to drop.
Edward Smalley: And we're looking holistically at your installation, and you're looking at your total installation cost of say you've got 100,000 street lights and you're going to replace the whole thing. Then the difference between a 400 and a 100, while there's a price difference, holistically the program likely will still make a lot of sense.
Jason Tuenge: All right, quick one: What about ETA loads? That is included; it's an effective projected area, so wind loading on a pole that is already included in the specification. We were careful not to simply set some kind of a value there, saying the fixture needs to be less than some value of square feet, because this is one of those items that definitely needs to be dialed in to the application because it'd be very risky to say that it should be less than 2.0 square feet, and then install it on a pole that's not meant for a 2.0 square feet. And then it blows over. So this is one of those things you definitely need to specify for your own project, it should not be something listed in a standard, and one of the reasons why the specification continues to do some things on its own rather than just simply referencing another standard.
Any plans for Solid-State Lighting photocontrols? Basically you don't necessarily have to have something specifically for Solid-State Lighting products, but there are some potential issues, and I'll let Poplawski dive into those.
Michael Poplawski: Well, in terms of DOE plans, I think Ed and Jason already referenced or commented on the model specification being developed for controls. Now it should be pointed out that that specification is really focused on a certain class of control capability, and it's focused on controls that can provide remote monitoring and adaptive lighting. So network control systems that have the potential to save energy by identifying day burners and failed lamps and also adjust the light levels of luminaires. So that's really the only kind of on the higher end of the spectrum type of control that might be used with Solid-State Luminaires. This question seems to be more focused on just simple PEs* and maybe like Jason mentioned, one of the issues is will the PE be matched in lifetime or reliability to the solid-state luminaire, which hopefully will have a longer lifetime than some of the previous technologies. We're not directly right now doing anything to address that, but I would probably point out that the IES, one of the IES committees is updating the DG-28 document that has historically addressed outdoor lighting controls, which were primarily addressing PEs. But now it will try to address the whole range of potential technologies or equipment that may be used to control outdoor lighting sources, and it should serve hopefully as a design guide to help users select the type of controls that they may - - that would best suit their needs. And then if, for example, they were to identify a few that kind of selection process that they wanted, a network system that could do adaptive lighting and remote monitoring, then we would have this model specification to point people to as a tool to use to specify the purchase of that system.
Edward Smalley: And maybe I can add just briefly to that, and I think Michael touched on it when we talk about simple controls of just off dusk to dawn. A number of cities are looking at longer life photocells. For instance, Seattle has specked out 20 year photocell on our website. So yes, those products are available, but as Michael just pointed out, the DG document that is currently available has very good guidance on the Solid-State specifications for photo controls.
Jason Tuenge: And we are basically down to the last closing points. So I want to say thanks to everyone for attending. The last question was, the last couple questions were also pertaining to controls and j just wanted to point out that there's nothing in the specification that really restricts you in any way in terms of what controls you might want to implement. It's intended to be designed to accommodate a separate control spec, for instance, the one being developed by the Consortium currently. So yeah, it's definitely something we have in mind, there's no need to stop you from implementing controls, and we certainly intend to accommodate them ourselves.
I think one point in closing is that at this point we definitely have some pretty broad support from manufacturers, so you should be seeing some good submittals coming your way if you use the specification; they're not going to be resisting. The specification and feeling that it's going to be requesting items that aren't necessary, et cetera. So this is something that should definitely help streamline the process for everyone. And, yeah, I think that's about it. Anything else to add, Ed?
Edward Smalley: No, just wanted to thank everyone and not only for the work, Jason, that you've done here, but also for everyone's participation.
Jason Tuenge: Well, thanks again to everyone for attending.