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Comment Report Form: 2nd Draft NLC Technical Requirements V

Document: Networked Lighting Control System Technical Requirements


Version: Draft 2 of Version 3.0
Comments Due: COB, Thursday May 10, 2018

This document lists all of the proposed updates in the second draft of the 2018 DLC "Networked Lighting Control System Technical Requireme

To comment on these updates, enter your Organization, Name, Email Address and Phone Number at the top of the worksheet. Then enter an
Rationale" along with the Topic, Line, Table, or Row number of the document that your comment applies to. If applicable, please provide alte
support your comment; and responses to any questions posed in Column E "Explanation by DLC". Provide your proposed change correspond
Instructions and Background:
Change".

Comments to the Technical Requirements that are not related to a specific revision the DLC has proposed may be added at the bottom of the

Save the Excel file with your comments, with your initials appended to the end of the filename, and email the file to info@designlights.org by

Reviewer Organization Reviewer Name


Change

Location in TR (Line or Table &


Topic Proposed Change in NLC Technical Explanation by DLC
Row numbers) Requirements

Accept Direct Current and Power


over Ethernet systems; qualify These systems were formerly excluded because the DLC SSL (Solid State
systems publicly when the Lighting) QPL (Qualified Products List) excluded DC/PoE luminaires. DLC
1 Lines 21-27 DC/PoE
corresponding SSL application plans to accept DC/PoE luminaires on the SSL QPL in September 2018, so
process is available in this exclusion will be removed.
September.
A primary purpose of the QPL is to assist specifiers in product selection. If
information about a particular capability is not publicly available to
specifiers, contractors, or customers through an applicant’s documentation,
then under this new proposal DLC will not list that system as having the
capability. The intent of this new documentation requirement is to improve
In order for an applicant to claim the documentation of listed systems. The DLC seeks to differentiate systems
a capability listed in Tables 1 and that provide documentation to their customers about their system's
2, operational instructions for capabilities and how to implement them, versus systems that do not
Publicly
that capability must be publicly provide this documentation.
2 Lines 51-60 Available
available in an instruction
Information
manual, except for “continuous As an example, some applicants have claimed the Demand Response
dimming” and “startup and capability because their system has a dry contact, but without any literature
configuration party”. claiming that the system has Demand Response or describing how to
implement the capability. Other applicants have developed robust how-to
instructions for how to implement demand response with their system.
Under the new proposed documentation requirement, the systems without
documentation would no longer be listed as having Demand Response
capability.

For re-applications without If a recorded presentation from last year is still applicable to the current
3 Lines 74-76 Presentations major product updates, accept a product, then DLC reviewers can view that recording, in order to reduce the
recording from last year. time and effort needed from the applicant.
Systems that calculate energy usage and savings based on nominal or
manually entered wattage values are subject to human error. In addition,
rarely are any specifiers, installers, or commissioning parties paid to ensure
that wattage values are accurate or entered at all. Anecdotes and
preliminary research suggest that errors of 15% to 40% are not unusual with
these types of systems, and the step of entering the wattage values often
Phased approach: does not happen. Utility efficiency programs have expressed a desire to no
longer allow manually-entered "calculated" energy monitoring to qualify as
energy monitoring within their programs.
V3 in 2018: Similar to V2.
Energy metering integrated circuits continue to become more widely
V4 in 2019: Energy Monitoring
available at lower cost. Efficiency programs can justify and support higher
4 Lines 80-95, Table 3 Row Energy will be required, that complies rebates and incentives, and ongoing performance rebates for continuous
11 Monitoring with a new ANSI standard(s) if
improvement, when the energy performance of NLC systems can be easily
available. Otherwise, calculated
methods will not be accepted, documented. Most networked lighting control systems available now are
capable of some form of energy monitoring, including lower cost simple
and manufacturers will self-
room-based systems. Utility efficiency programs have expressed a desire to
report the accuracy of direct
require that all eligible networked systems include energy monitoring
measurement methods.
capability. It should be noted that the technical requirements propose to
require systems to have this capability, but not that it must be deployed on
every project.

An ANSI standard to define the accuracy of energy monitoring may become


available. If not, then a requirement for direct measurement is a simple
way to promote an acceptable level of accuracy (on the order of 2% to 5%,
rather than 15% to 40%).
Efficiency programs are concerned about the risk of providing rebates and
incentives for networked systems that could be involved in security
breaches. In addition, customer concerns about network security raise a
significant market barrier to the broader adoption of NLC.

These concerns can be addressed at the component level by compliance


with ANSI UL 2900-1, and at the level of a manufacturer by compliance with
Phased approach:
ISO 27001-1. In addition, the NIST Cybersecurity Framework provides
guidelines for manufacturing best practices. Adherence to these practices
V3 in 2018: Report components
can be assessed by various third parties, although DLC is not aware of a
that comply with ANSI UL 2900- standardized test for compliance.
1; and manufacturers that
comply with ISO 27001-1, NIST
Other relevant standards may become available, that DLC can reference in
Cybersecurity Framework.
Lines 96-114; Table 3 Row the future. For instance, a lighting-specific version of ANSI UL-2900 could be
5 Security
20
V4 in 2019: Report compliance developed.
with a list of options developed
A webinar introducing ANSI UL-2900 in the context of lighting controls is
in stakeholder process.
available here: https://industries.ul.com/events/lighting-systems-and-
cybersecurity-are-your-systems-ready
V5 in 2020: Require compliance
with a cybersecurity standard on
The ANSI UL 2900-1 standard is available for purchase here:
the 2019 list.
https://standardscatalog.ul.com/standards/en/standard_2900-1_1

The ISO 27000 family of standards is available for purchase here:


https://www.iso.org/isoiec-27001-information-security.html

The NIST Cybersecurity Framework website is here:


https://www.nist.gov/cyberframework

Some systems provide control of scenes, while others do not.

7 Tables 1,2; Table 3 Row 23 Scenes Add Scene Control as a reported This capability provides essential support for interoperability between
capability.
systems from multiple vendors. Interoperability will support market
expansion.
Emergency Shorten, and replace "Interact" with "Connect", to more accurately describe
8 Table 3 Row 19 Clarify description
Lighting the physical connections shown in a wiring diagram.

For comments about other


aspects of the Technical
9 Other Other Requirements, please include
the line number from the
Technical Requirement or the
Row number within a Table.

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ements V3.0

Technical Requirements".

heet. Then enter any comments in Column F "Comment and


please provide alternate approaches, technical justification, or data to
change corresponding to your comment in Column G "Proposed

at the bottom of the worksheet.

@designlights.org by COB, Thursday May 10, 2018.

Reviewer Email Address Reviewer Phone #

Comment & Rationale Proposed Change

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