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Last week, without advance notice or public consultation, the US
Environmental Protection Agency (EPA) released Energy Star Program
Requirements for Residential Light Fixtures (RLF), Eligibility Criteria
– Version 4.2, which contains reference to LED-based fixtures. As
described in our initial report
of June 6, this puts the EPA at odds with the US Department of Energy
(DOE), which has already released Energy Star criteria for SSL after
several years of work and consultation.
The EPA's RLF 4.2 document
defines the product specification for Energy Star qualified residential
light fixtures and replacement GU-24 base integrated lamps, indicating
that a product must meet all of the identified criteria if it is to be
labeled as Energy Star by its manufacturer. Energy Star is a labelling
program for energy-efficient products, and is run jointly by DOE and
EPA.
The intent of Energy Star for RLF is to move consumers from traditional
incandescent fixtures to fixtures that use high-quality fluorescent
lamps, LEDs, or other energy-efficient technologies, including
motion-sensors and daylight-sensors for outdoor fixtures. The
specification covers the requirements for indoor and outdoor light
fixtures, recessed downlight retrofit kits and replacement GU-24 base
integrated lamps intended primarily for residential type applications.
So far so good, but here is where the contention stems from. EPA added
five new pages of specifications to RLF, expanding the scope of the RLF
to include fixtures using “LED light engines” for “primary
illumination.” These specifications address a wide variety of LED
performance measures, including efficacy, color rendering index,
correlated color temperature, lumen maintenance, color stability,
operating frequency.
EPA announcement
In a June 2 open letter
from the EPA’s Office of Air and Radiation (which administers Energy
Star), Alex Baker, Manager of the Energy Star Lighting Program stated,
“The purpose of this letter is to inform you regarding a technical
amendment to the Energy Star residential light fixture (RLF), ceiling
fan and vent fan specifications. With this amendment, EPA is responding
to a number of requests from manufacturers to incorporate test
procedures and metrics to allow LED-based fixture performance to be
evaluated against the requirements of the existing RLF specification.
This is pursuant to the recent finalization of a new testing procedure
for LED light engines which makes it possible to test LED-based
fixtures in a manner comparable to the way other technologies are
tested under the longstanding Energy Star residential fixture program.”
Baker's letter said that EPA believes it is appropriate to
allow LED-based fixtures to be eligible for the Energy Star "if they
indeed demonstrate the performance required in the current residential
specification (while also ensuring the products deliver on their claims
of long life). This technical amendment clarifies the procedures and
requirements for these fixtures to qualify. Given the importance of
providing a level playing field across today’s efficient lighting
technologies, it is effective immediately.”
EPA has not completely ignored the DOE Energy Star program. The
letter continues, "This technical amendment compliments the DOE SSL
program by allowing for a broader set of LED-based light fixtures to
participate in a harmonized manner with other Energy Star qualified
residential light fixture technologies.
Later, Baker's letter says that "This amendment allows for the
immediate qualification of LED-based fixtures that are intended for
residential general illumination, and it allows them to qualify at the
performance levels required for other lighting technologies. EPA will
be coordinating with the DOE as to how best to provide manufacturers
with as seamless a process as possible to qualify and promote the full
array of Energy Star qualified residential light fixtures."
The letter contains many phrases and statements that could
easily be described as "spin". The question is this: what does this all
really mean when it comes to general illumination and the years of
effort and work in the SSL general illumination space conducted by the
DOE. This includes the input and participation of the many - and I mean
many - stakeholders from the SSL industry, other government energy
agencies, utilities and energy efficiency organizations, of which I
represent one.
Shining some light on the issue
I am certainly not alone in thinking that the "new" criteria in
EPA's RLF 4.2 allowing qualification of light fixtures using LED light
engines directly overlap and contradict DOE's existing Energy Star
criteria for solid state lighting (SSL) luminaires. The DOE's much
stronger Energy Star SSL document was published on September 12, 2007
with an effective date of September 30, 2008. Our article entitled Energy Star for SSL gets energetic start
gives a good review of the DOE's work. Sources close to the issue
object to EPA’s action for a variety of reasons, including the
following:
1) Lack of public review:
The EPA issued the new LED specifications, without public review or
comment, declaring them final and effective immediately. Failure to
allow for public review and comment violates long-established Energy
Star program protocol. The specifications were developed in secret,
without the knowledge of the DOE, EPA’s co-manager of the Energy Star
program, and without any public announcement of EPA’s plans. DOE
learned of the new specifications only after they were announced as
final, and effective immediately.
2) Overlap and contradiction:
EPA's new criteria contradict the DOE-developed Energy Star SSL
criteria. EPA’s new specifications allow for residential LED fixtures
that are already covered by the DOE-developed specifications, creating
two competing sets of Energy Star criteria covering the same products.
This creates significant confusion for manufacturers and other Energy
Star partners, who are in the process of preparing for the phase-in of
DOE's SSL criteria.
3) Non-standard test procedures:
EPA’s new specifications reference test procedures developed by the
Lighting Research Center, not the Illuminating Engineering Society of
North America’s (IESNA) new LM-79 standard or its forthcoming LM-80.
Yet at this point, LRC’s test procedures documents are basically
thought pieces, which haven’t been subjected to the rigors of review by
industry standards organizations. In contrast, the DOE-developed
specifications were adopted in close cooperation with all major
lighting industry standards organizations, including the IESNA.
4) Inadequate lighting quality requirements:
The EPA's criteria are so lenient that they allow for a wide range
of low-performing products, many likely to share the same poor light
quality attributes associated with early CFLs. For example, EPA’s
specifications allow for very high color temperature lamps, which
consumers have clearly rejected in the CFL market. Further, they allow
for products with very low light output, despite clear evidence that
consumers rejected CFLs because they were too dim.
In summary, a source close to the issue commented that, “The
EPA actions were ill-advised and will cause great turmoil within the
industry”. We often refer to the SSL industry at this point in time as
being like the "Wild West". It is unfortunate that a "shoot from the
hip" attitude appears to be alive and well in government.
READ THE REST OF THIS ARTICLE AT http://www.ledsmagazine.com/features/5/6/1
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