EPA continues to create Energy Star confusion

Aug. 1, 2008
An error-strewn document from the EPA relating to Energy Star has provoked a strong response from the DOE.
In the latest twist in the Energy Star story, the Department of Energy (DOE) has reacted angrily to a letter circulated on July 25 by the Environmental Protection Agency (EPA), which concerns the two separate sets of Energy Star requirements for solid-state lighting (SSL). The unheralded announcement by EPA of its RLF v4.2 in early June has caused a huge amount of controversy (read numerous articles here).

EPA's July 25 letter contains a number of errors and misstatements, the most glaring of which is to say that SSL Energy Star criteria from DOE will come into effect on November 1, 2008. In fact, the DOE criteria, which were finalized in September 2007, will be effective September 30, 2008.

In a letter to the EPA, the DOE's Richard Karney, Energy Star Program Manager, said that EPA's July 25 document "is based on what appears to be willful disregard for the clearly stated, publicly reviewed and legally adopted scope of the DOE Energy Star criteria for SSL luminaires."

With regard to program scope, the EPA document states that the DOE SSL criteria "focuses on directional lighting and applies to seven lighting fixture applications."

This is incorrect; the DOE's criteria do not mention directionality, and are broad in scope. The criteria cover "the requirements for SSL products used for general illumination, including those with significant decorative function. If a decorative SSL product serves a significant general illumination function, it falls within the scope of these criteria. The criteria apply to both residential and commercial products."

There are seven luminaire types specified under the criteria’s Category A applications. Some of these are directional applications; others, such as porch lights, are not. Even more importantly, it has always been DOE's intention to expand this Category A list at the appropriate time.

In Karney's words, "Category A was limited to this short list of seven lighting applications because DOE’s analysis at the time indicated they were the only fixtures for which SSL technology could meet the needs of buyers, and perform at least as well as conventional lighting technologies. Page 10 of the DOE SSL criteria states, 'DOE will monitor the technical progress of the technology, steadily adding additional Category A products in future versions.'"

The EPA document also states that "a broad range of SSL lighting products are eligible for the Energy Star based on two complementary approaches." This is yet another error, because clearly, in some cases, the same products can be qualified under both criteria.

The only lighting product categories for which the two sets of criteria do not overlap are: 1) commercial luminaires, which fall exclusively under the DOE SSL criteria, which the RLF explicitly does not include, and 2) residential “downlight canisters,” which RLF V4.2 explicitly excludes.

"If a lighting manufacturer wants to qualify a porch light, or a table lamp, or a pendant fixture, which agency do they go to qualify the fixture?" asked Karney in his letter. "The scopes completely overlap. DOE clearly announced its intentions more than a year ago that it planned to adopt additional Category A lighting applications requirements as the technology improves. The unexpected release of V4.2 shows a complete disregard for DOE’s well-vetted and transparent planning approach, and thus creates a landscape of confusion in the market."

The EPA document also misrepresents testing procedures, saying that DOE's criteria "references IESNA LM-80 which is a 25,000 or 35,000 hour test with no acceleration method.” The implication, deliberate or otherwise, is that a very long period of testing would be required, which would be detrimental to manufacturers.

But in fact, while LM-80 is not yet final, most drafts have called for 6,000 hours of testing.

Karney's letter concludes "Our agencies owe the public honest and fact-based information, not self-serving, misleading misinformation…I request an immediate retraction of this document, followed by an accurate, fact-based characterization of the DOE SSL criteria, which I would be happy to help you write."