Pure Lighting LLC

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.

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