Field Adjustable Light Output and Concerns



As part of the Design Lights Consortium’s® Technical Requirements V4.4 update, Field-Adjustable Products can now be listed on the SSL QPL. This policy update allows the QPL to keep up with innovations in this rapidly changing technology. Utility incentive programs response to this new policy has yet to be fully revealed, but early anecdotal discussions have given rise to some concerns, primarily regarding the following statement in the policy:

“Field-adjustable products, will be listed on the QPL at the full output setting, with the product performance characteristics from the LM-79 test: Light Output, Power Consumption, Efficacy, THD, Power Factor, CRI, CCT, Zonal Lumens, Spacing Criteria. Additionally, field adjustable products will list the reported default light output and default wattage.”

Default Approach Consequences

When evaluating a FAO product, the default behavior of the utility rebate program is to assume the highest possible wattage and lumens to calculate energy savings and incentives. This is the most conservative approach. Since the device settings could be adjusted after installation or inspection, it is understandable why utilities would lean toward this approach. However, utilities are not typically looking to be conservative when determining their energy savings, they’re trying to be accurate.


Taking the most conservative approach is not going to generate the most accurate results and could have the following impacts:

  1. Significantly underestimating energy savings. Utilities have energy savings goals every year, by assuming the highest wattage for FAO products, they are almost guaranteed to be underestimating the energy savings.
  2. Distorting the value of the rebate. If it’s a kWh or kW based calculation, the energy savings will be understated and the customer will see a lower rebate based on the conservative approach.
  3. Inaccurately representing the relationship between rebate dollars and kWh savings. When evaluating the rebate program, utilities may believe they are overpaying for savings. This could lead to a utility lowering their rebates in future years if they are seeing that the kWh savings are not lining with the rebate dollars distributed.

To illustrate the impact, we created two scenarios to help better explain what is happening.


SCENARIO 1: Metal Halide High Bay Replacement

250w MH recommended replacement with 112w@12000 lm LED HighBay
Manufacturer creates FAO device that replaces 150w-400w MH.
Max wattage for 400w replacement is 146w @ 18000 lm


  • For 250W scenario, 1 year kWh saved is reduced from 732 kWh to 596 kWh (19% less)
  • Average increase in rebate $/kWh of $0.01. As high as $0.14/kWh for some utilities


Example Values in Pennsylvania

Utility State Rebate Rebate FAO
PECO Energy Co PA 75 42.5
UGI Utilities, Inc PA 87.84 71.52
Metropolitan Edison Co PA 36.6 29.8
Pennsylvania Electric Co PA 36.6 29.8
PPL Electric Utilities Corp PA 36.6 29.8
Pennsylvania Power Co PA 36.6 29.8
West Penn Power Company PA 36.6 29.8
Duquesne Light Co PA 45 60


High-Bay Rebate $/kWh Saved – Original

High-Bay Rebate $/kWh Saved - Original

High-Bay Rebate $/kWh Saved – FAO

High-Bay Rebate $/kWh Saved - FAO


SCENARIO 2 – Type C LED Tube Retrofit

28W existing fluorescent replaced with 12W LED Type C tube
Manufacturer FAO device ranges from 10-21 watts


  • Max wattage results in 1 year kWh saved is reduced from 64 kWh to 28 kWh (56% less)
  • Average increase in rebate $/kWh of $0.03. As high as $0.64/kWh for one utility


Example Values in Pennsylvania

Utility State Rebate Rebate FAO
UGI Utilities, Inc PA 7.68 3.36
PPL Electric Utilities Corp PA 3.2 1.4
Metropolitan Edison Co PA 3.2 1.4
Pennsylvania Electric Co PA 3.2 1.4
Pennsylvania Power Co PA 3.2 1.4
West Penn Power Company PA 3.2 1.4
PECO Energy Co PA 6 3
Duquesne Light Co PA 3.5 3.5


Type C Tube Rebate $/kWh Saved – Original

Type C Tube Rebate $/kWh Saved - Original


Type C Tube Rebate $/kWh Saved – FAO

Type C Tube Rebate $/kWh Saved - FAO



Assuming maximum wattage of field adjustable products that are installed at lower wattages:

  • Underclaims measure savings by 19% and 56% in 2 scenarios analyzed
      • May increase your program rebate $/kWh:
      • Average increase of $0.01/kWh and $0.03/kWh in 2 scenarios analyzed
      • Increase of up to 0.64/kWh for some utilities
  • Distorts value of rebate


Hopefully alternative approaches will be employed in incentivizing these new devices.  Alternatives could include allowing for self reported wattages/lumen levels and adjusting for an average error/fraud rate, or an average case wattage adjust by historical use case data.


By Mike Cham, Chief Technology Officer

Environmental Focus: Energy Savings, Sustainability & Global Warming



Most of the time when we talk about energy efficiency in this industry, we talk about the economics. When trying to convince building owners, businesses and policy makers to invest in energy efficiency, our first instinct is to make the financial argument; these are solid investments with quick and reliable payback times. And while those arguments are getting easier and easier to make, the environmental argument is just as important. Recently we’ve seen a lot of scary headlines about the effects of climate change, and the devastating hurricanes and floods along the east coast have made those dangers visually present. And since we have a suite of tools (Encentivizer® – you can read more about it here) that helps all users make better energy efficiency decisions we truly get inspired that our tools help reduce strain on the environment as well.

The Paris Agreement developed in 2015 by the United Nations Framework Convention on Climate Change set in place the international goal to maintain global temperature rise under 2º Celsius, and to strive to keep it at 1.5º Celsius. The most recent Intergovernmental Panel on Climate Change (IPCC) report only strengthened the argument and highlighted the difference between rising temperatures of 1.5º and 2º Celsius. Compared to 1.5º Celsius of warming, at 2º Celsius warming 2.6 times more of the world’s population would be at risk for regular severe heat waves. Three times as many species would lose over half of their habitable space, and we would lose over 38% more arctic permafrost (WRI). Countless other effects including the sea-level rise, declining fisheries, and the loss of practically all coral reefs, we could be looking at a very different earth in the next 20-40 years.

Thankfully, the IPCC report doesn’t only tell us how destructive the global temperature rise could be, it also presents different situations on how to achieve the 1.5º Celsius benchmark. While all these situations require a rapid change to our energy supply from fossil fuels to renewable energy, to around 50% by 2030 (Brookings). But even with a change to clean energy, all situations also require either a reduction or stabilization in total energy use. Without a drastic change to our daily habits and industrial system, energy efficiency will play a huge role in achieving our climate goals. The US DOE estimates we could reduce our projected energy use by 16% by simply implementing energy efficiency measures that are currently achievable (DOE).

While the United States may not be federally mandated to comply with the Paris Agreement, we can all do our part in lowering our energy usage. We can lobby and encourage our local policy makers to further promote energy efficiency programs, and create projects with our customers and ourselves.

If you are in the energy efficiency industry as a professional, manufacturer, or utility, Encentivizer makes achieving your energy efficiency goals easier. Get help with utility rebates and help reduce the strain on our planet.