Discussion
An LED attached to an alternating current system requires electronic drivers to convert from direct current to alternating current. Poor quality designs or low-quality components can lead to flicker that some sensitive receptors can see. This flicker is exceedingly disruptive to the lives of those who can see it.
Figure 1 shows a dentist’s office. Watch the video showing the flicker at this link: https://youtu.be/4Lw5X0w7pLU
Figure 1 – Flicker in dentist’s office
Modulation at low frequencies for office and residential lighting can cause health related problems, such as headaches, eye strain and epileptic seizure.[1] The United States Department of Energy recommends avoiding PWM dimming unless combined with other techniques.[2] A scientific phenomenon called saccades helps explain why LED lights can be mentally in tolerable.[3]
Proposed Regulations
California has already used a system for solar systems where the State approved certain inverters that were safe and energy efficient. We propose that the DLC use a similar system for outdoor LED lights. To guarantee that outdoor lights do not have sub-sensory flicker, the State must approve the electronics of the fixture or have in place a list of manufacturers that guarantee that their products do not cause sub-sensory flicker.
We propose that the percentage of flicker of any static outdoor light shall be less than the flicker frequency multiplied by 0.03
[1] https://pdfs.semanticscholar.org/de59/abcc2a3b18f95cbfeec0860649903617a2b8.pdf
[2] https://www.energy.gov/sites/prod/files/2015/05/f22/miller%2Blehman_flicker_lightfair2015.pdf
[3] https://theconversation.com/the-scientific-reason-you-dont-like-led-bulbs-and-the-simple-way-to-fix-them-81639