19-0828 v3.X Design for Disassembly - Lighting in Tenanted Spaces

Question

Our project is a neighbourhood shopping centre, which includes 40 – 45 different tenants, currently working through gaining LBC compliance for lighting.
For context, the average lease period for specialty tenants is five to seven years, at which point each tenant usually would either vacate or update their fit–out (notwithstanding those businesses that may terminate prior to the conclusion of their term). Cyclical refurbishment, upgrades, and tenancy changes are often events that generate a lot of unnecessary wastage, particularly in the retail sector.
In terms of lighting, specialty retailers have on average somewhere between 10 – 15 light fittings in a tenancy, and again, due to the diversity of tenancy types, there is a diverse range of lighting needs as would be expected in a shopping centre. Tenants design and procure their lighting individually from a range of suppliers. The range, volume, and diversity of tenants does not allow for the project team to procure in bulk for the tenants. In other words, lighting is bought in small quantities.
Hardwiring vs Plug-in
In some cases, lighting could be hardwired, but the overwhelming preference is that lighting is plugged into a socket / General Power Outlet in the ceiling space. See the attached image  as an example.
The benefits of plugging lights into sockets rather than hardwiring are many:
• Flexibility of lighting, i.e. products can be easily changed over
• The installer can position and reposition the light on the ceiling (or walls) without having to change the wiring or damage the ceiling
• Flexibility of other power uses, e.g. lights can be plugged in, but so can signage, projectors, artistic ceiling features, menus, etc.
• It radically reduces disassembly waste
• It removes downtime in the tenancy, i.e. there is no need to close up shop to be able to put in new lighting
• In most cases, an electrician is not required every time a light needs to be changed
The downside is from a Red List perspective, i.e. lighting is manufactured and delivered as standard (off-the-shelf and from trade suppliers) with a connector and plug (very similar to many standalone appliances).This connector is almost always PVC.
Note – we are obviously not treating lighting as miscellaneous, despite it being plugged into a socket and not necessarily on its own circuit!
Suggested approach
We request an exception for our retail tenants to be able to procure plug-in lighting, particularly for the design for disassembly and waste reduction benefits. In turn, we will advocate to every lighting supplier on the project for the removal / substitution of PVC in their lighting.
Please confirm this is an acceptable approach.

Answer

Project teams are not required to use hardwired lighting fixtures. Plug-in light fixtures that are not permanently affixed, and do not require a dedicated power circuit, may be considered Furniture, Fixtures & Equipment (FF&E), and are not required to be vetted for Red List compliance. For additional clarification on FF&E, please see page 10 of the 3.1 Materials Petal Handbook and the Dialogue post titled " 18-0306 v3.1/Equipment and Appliances Scope for Materials".

Even if the light fixtures are not required to be vetted for Red List compliance, teams are encouraged to use Red List Free options when possible, and to advocate to lighting manufacturers for the removal of PVC from their products. 

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