OP
Limara
thank you for the answer, I think I am having gu10 bulbs in every room in one form or another and plan to have them all led i dont want to be running that lot with 50w halogen bulbs.With LED you are fitting low energy lighting, because they are not really bright enough to be counted consider the set of downlights in each room as one fitting. Then you have complied OK.
They were not considering that you could get >400 lm out of 5W when this was written. BC will not really be too interested anyway as everything is low energy.