EPA Plays Politics with Solid State Lighting, Repeats CFL Mistakes

On June 2, 2008, a date that will live in infamy, the solid state lighting community was suddenly and deliberately attacked by the combined communication and policy forces of the Office of Air and Radiation the US Environmental Protection Agency... It will be recorded that the distance from a government-inspired concept to an actual policy makes it obvious that the attack was deliberately planned many days or even weeks ago. During the intervening time the EPA has deliberately sought to deceive the solid state lighting community by their cooperative approach and expressions of hope for continued peace. (Ref FDR Pearl Harbor speech for relevant inspiration.)

So what form did this sneak attack take? In a June 2 letter to lighting "manufacturers and other interested parties" the EPA announced a "technical amendment", version 4.2, to the Energy Star residential light fixture (RLF), ceiling fan and vent fan specifications that is of immediate effect in allowing LED light fixtures to achieve the Energy Star mark. It does that by allowing qualification to "new testing procedures" that are somewhat useful but unproven, unqualified at the fixture level and without quantitative history to substantiate their predictive reliability. In addition, the spec itself is directly contrary to the SSL and lighting industry consensus that agreed that the "dim and harsh" factor was a major consumer turn-off with regard to CFL technology at its introduction. Unappealing and ineffective CFL lamps introduced into the residential market caused a general rejection of that technology and set back the pace of adoption on the order of a decade.

The EPA's answer is apparently to repeat the mistake by allowing residential luminaires throwing out as little as 0 (zero, zip, nada) lumens to qualify as long as the light engine inside generates 40 lumens/watt with a CCT that can be as harsh as 6500K (like lighting your house with an arc welder that's malfunctioning). Oh, and you have to label it with wording such as "This fixture produces light equivalent to a 6 watt incandescent bulb" in accordance with a handy reference chart. If your integral light engine produces 40 to 69 lumens, you simply need to label it as "equivalent to a 6 watt incandescent bulb". For reference, my wife and son use those leftover 40 lumen bulbs in their tabletop snow village display each Christmas because they're too dim for use as decent nightlights! The EPA figures that qualifying the LED light engine (to whatever minimal standard) inside the fixture is sufficient. So, you can grab your Energy Star mark, push a grand 10 lumens out of a crummy LED "reading light" and claim it is as bright a 40-watt bulb because your "LED light engine" inside the fixture produces between 450 and 799 lumens that are going who knows where. That will get them flocking to the stores to buy one for every room in the house! (Relevant 4 pages of the RLF spec here, or full spec here, with SSL amendment starting on page 35 of the actual doc which is page 45 of the PDF. Note that we have to invest our bandwidth in providing it to you as the EPA hasn't yet posted it anywhere... still trying to keep anyone from noticing?).

So is the EPA unaware that consumers eventually buy these products? Heck no. They are confident that consumers are so varied (or ignorant?) with their opinions that they can simply try it and decide if they like it or not, as is made clear by their notation at the end of the spec: "Note: EPA seeks to ensure that qualified fixtures meet consumer expectations for light output. Consumer preference for light output varies widely, and the same is true for fixture design intent. Therefore it is impractical to prescribe lumen values for various residential lighting fixture applications. This consumer awareness requirement is intended to help consumers understand the limitations of LED light engines producing less than 800 lumens (equivalent to 60 watts incandescent)." No reason to accept the lighting industry and market consensus that consumers may actually have an interest in the amount of light that actually comes out of the fixture, and certainly, what does the lighting industry know about an acceptable level of brightness for different types of residential fixtures? And there doesn't seem to be any reason to recognize the directional nature of LED lighting, or that it is inherently different from any of the predecessor illumination sources. They are probably great people over there at the EPA, but somebody has made some very bad decisions.

Given that IESNA has just completed LM-79 “IESNA Approved Method for the Electrical and Photometric Measurements of Solid-State Lighting Products” and that the Department of Energy (DOE, you know, the ones actually charged with responsibility for generating and implementing energy policy and regulation in the USA) has taken their legislatively mandated SSL responsibilities and developed and honed the qualification testing procedures over the last several years with 5 rounds of the CALiPER testing, it seems perfectly reasonable for the EPA to simply assign their own way of testing these. At least they did notice that the Illumination Engineering Society (note key words, all of which imply, what's that word... oh, "expertise" maybe) was working on something. A footnote on page 35 of the document reads, "IESNA LM-79... may in the future incorporate LED light engine test procedures; as such EPA may reference LM-79 in future revisions of this specification." Those pesky illumination engineers, they left out the part about LED light engines when describing how to characterize a luminaire. Why would they do that? Maybe because it's useless to characterize "the LED bulb" and then use it to describe the characteristics of the finished system. My computer has a 1.4 GHz Pentium, isn't that specific enough to know whether it will work as the fly-by-wire system on an airliner? Oh, well it only has 64K of RAM, a floppy disk, a weak power supply and no operating system, but what difference would the system performance make in that application while I fly over your town?

So here are the interesting questions: With the DOE- and SSL-community driven Energy Star criteria completed back on Sept. 12, 2007, and set with an effectivity date of Sept. 30, 2008, why would EPA make this pre-emptive move now? Why would they do it in secret without any public comment or constituent input? Why wouldn't they even reveal to anyone they were working on this, much less work in coordination with either the broader industry or the DOE (who received the mandate to oversee the SSL program back in 2005, under Section 912 of the 2005 Energy Independence and Security Act)? Why would they make this "technical revision" of "immediate effect"? Are they just enthusiastic (albeit a bit naive)? I wanted to ask those questions of the EPA program manager, but my two messages yesterday and the day before using the words "I'm under a tight deadline" have remained unanswered so far. In fairness, he may simply be on vacation or out of touch for a few days, and if we get those answers later, we'll let everyone know. Meanwhile, we get to form our own opinion, as you should also form your own.

Our Theory: The EPA has no significant reason to be involved with the Energy Star program at all, they know it, they lost any mandate for involvement with SSL and this is a desperate "land grab" to try and retain a stake in something they have no business in. Frankly, justifying EPA co-control of Energy Star on the basis that lower energy consumption reduces energy-production related pollution is analogous to the Treasury Department claiming a stake in Energy Star because an emphasis on energy efficient products can have an effect on the distribution of tax revenues in various manufacturing sectors. Their claim to co-control is more historical, since the EPA generated the Energy Star moniker in the mid-1990s to apply to computers that had a sleep mode capability. The DOE had created an "Energy Saver" label with a full range of products, but clearly someone in the EPA had some pull at the time and while the DOE and EPA programs were merged, the Energy Star label won out and the EPA kept its stake (read "money") in the energy efficiency programs. Once again, we prove that when something is given to, or taken by, a government agency, they are generally loathe to give it up later on.

Our suggestions: A) If you are a luminaire manufacturer, ignore the technical addendum to the RLF Energy Star spec; B) If you are a specifier, don't depend on our opinion. Contact the EPA yourself and have them explain to you how the technical addendum to section 4.2 of the RLF will assure you of high quality luminaires that meet customer expectations, and how it will aid adoption of SSL technology rather than harm it (US tax dollars are paying their salaries, so they work for you... they are civil servants not civil supervisors); C) If the audience at large becomes aware of an LED-based luminaire or fixture provider that applies the Energy Star mark based on qualification under RLF Version 4.2, forward them to us here at Solid State Lighting Design and we'll post a list of those manufacturers on a special page dedicated to, "Products that may have been qualified to a less rigid Energy Star specification that could compromise the consumer perception of, and satisfaction with the LED-based lighting product that results... We recommend that you contact the manufacturer for luminaire-level test result data before making any purchase decision regarding this product. D) Pass the "permalink" to this editorial along to anyone and everyone that you think might have an stake in the success of solid state lighting (for permalink, right click here and choose 'copy shortcut' or 'copy link location' and then paste into any document or email). Let's get some buzz going before this nonsense gets out of hand and inferior products hurt us all.

Author: Tom Griffiths

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