Insights Into Energy Star for SSL - The Battle Continues
Source/Type: Solid State Lighting Design LED Lighting News - Editorials

Author: Tom Griffiths - Publisher

June 26, 2008... The battle as I see it is "simple versus valuable". In a June 24 web conference, we heard from the US Environmental Protection Agency (EPA) regarding their "technical amendment" to the Residential Lighting Fixture (RLF) specification 4.2. It's a simple way for a manufacturer to achieve Energy Star qualification for any fixture incorporating a qualified LED "light engine". If you need a catch up, you can read more about the reaction to this "double top secret" program in our last editorial. Overall, it didn't play really well when the EPA announced that it had effectively created a whole new technology specification without regard to any public process, review or implementation mandates (Rule book? What rule book?). We can only speculate on the EPA's motivation (which we did last time), and it is really hard to assign them even somewhat noble intentions. You don't secretly create industry specifications when you believe they are the best thing for the industry. Nonetheless, our objective is to encourage the EPA to do the right thing, and helping the industry and affected stakeholders understand the issues will allow the collective pressure to continue urging them towards what most of the industry sees as the correct path for retaining value in the Energy Star "brand".

In a nutshell, the EPA came up with module-level criteria that would allow "LED light engines" to be the Energy Star qualifying unit in residential applications. Their introduction to the spec sums it up pretty well, "EPA has adopted test procedures that are focused on the light source, not accounting for the optical effects of glass or plastic diffusers which tend to be selected by consumers based on aesthetic versus performance considerations. Accordingly, the adopted test procedure is designed to evaluate the performance of LED light engines, which integrate an LED package(s), driver and heat sink into a single unit. This approach is consistent with the existing RLF program approach to testing light source and ballast combinations (a.k.a. "platforms") in the context of fluorescent technology." In their conference call, the EPA calls it a "technology neutral approach", which would seem to make sense when comparing fairly equal technologies that do fairly equal things. LEDs differ from CFLs at least as much as CFLs differ from oil lamps (and likely even more).

It is important to acknowledge that the DOE's Energy Star approach, arrived at through the public and open process that is mandated by the governing program regulations, does add a burden to residential fixture manufacturers that they have not had in the past. Since Energy Star came along fairly late in the market adoption failure curve for CFL technology, it merely got to help clean up the mess rather than taking a role to help avert it. By the time there was an Energy Star RLF qualification, consumers were generally seeing that CFLs, in their different forms, provide them with a decent quality and predictable light source. At that point, if they get a "bad one" (slow to reach full light output or flickering), they simply take it back to their local superstore and don't buy that brand again. Here is the difference with SSL: Taking it back and choosing a different CFL "bulb" or fixture is a lot different than taking it back and not buying that technology again for 3, 5 or 10 years. At the current residential early-adoption stage, if there is a poorly performing fixture, it's the LED technology inside that will take the blame since it is considered "the unknown" in the equation.

The EPA RLF specification allows such a range of light engines, from dim to bright, and from warm to harsh white, that it seems unlikely that the consumer will be able to discern whether a particular light engine is potentially useful to them or not, much less being able to extend the thinking into the impact on the fixture would be. In their conference call, the EPA addressed the classic "CFL failure" by stating that, "We will actively protect the value of the Energy Star brand. If we see harsh, dim lights showing up through the program, we'll take actions to eliminate that." Obvious question: If you know that an inferior product solution can achieve certification under the spec, why not simply define the spec in a way that does not provide inferior combinations with the opportunity for certification?" Obvious answers: A) When you're in too much of a hurry, details like that can be overlooked or B) That would have led to the larger question of whether simply basing a fixture's Energy Star rating on the qualification of the light-source component even makes sense at this stage in the adoption curve.

As far as the stakeholders are concerned, there are two main camps. One would be the fixture manufacturers that appreciate the EPA's approach because it lowers their burden. DOE kept that in mind when they adopted a "qualifying family" approach, which basically means that a fixture manufacturer can qualify the lowest performing member of basic design, where a single housing has differing lenses, trim and baffles, and apply the qualification to all the other members of the family. There will be some testing by Energy Star to verify the rules are being met, and a violation will simply need to be corrected. You aren't tossed out of the program. How much does that testing add up to for a product family? Something on the order of $500 to $1500 for complete luminaire photometric and UL-conformant heat testing. Not exactly a piggybank breaker given the current value of the LED-based products.

The other stakeholders who oppose the EPA approach are those specifically within the solid state lighting specific portion of the lighting industry, who need SSL to succeed, and the utility companies. The utilities invest billions of ratepayer funds in support of energy efficiency programs. They also want to see SSL succeed sooner rather than later, and as a result, the recognition that confusing or possibly ineffective standards will slow things down is not escaping them. At least one utility behemoth, California-based Pacific Gas & Electric Company(PG&E) made a fairly clear statement against the current EPA approach. The statement was an element of a question asked by Mary Matteson Bryan, Lighting Portfolio Manager for Emerging Technologies at Pacific Gas and Electric Company (or PG&E) during the June 26 DOE conference Energy Star webcast where she asked, "With the release of RLF 4.2, PG&E is very concerned about potential marketplace confusion with two different SSL Energy Star specifications in place. In fact, until the current issues over Energy Star for SSL are resolved, PG&E does not plan to include products qualified under the EPA RLF 4.2 specification in our incentive programs. Has DOE been contacted by manufacturers or customers who share this concern and are confused?" The DOE answer was, "Yes, we have been contacted by a number of concerned stakeholders and are working to resolve this as quickly as possible, and at high levels of our two agencies." ... C'mon EPA, let's pull the spec back and re-do the process with stakeholder involvement.

Editorial Correction: A few weeks ago, in our coverage of a Philips Lumileds Lighting announcement regarding the adoption of their Luxeon Rebel products into several Philips LED module products, we did not make it fully clear that the LED modules were not a Philips Lumileds product. Philips Lumileds designs and manufactures LEDs, not lighting modules and their intention was to highlight what they see as the advantages of Philips Lumileds Luxeon products in modules of those types, regardless of whose modules those might be. Other Philips lighting companies and divisions are responsible for the design, production and sale of the variety of modules and luminaires. We apologize for any confusion that may have resulted from our original wording in that article.

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