While covering all of the key salient points of the Energy Star Criteria for SSL Version 1.0, that are now considered second nature, the DOE reaffirmed and stressed their serious and sincere intention to assure the qualification of only quality SSL product coming to market and to protect the Energy Star brand.
Jeff McCullough, Senior Research Engineer, Technology, Planning & Deployment at Pacific Northwest National Laboratory (PNNL) identified and outlined the strengths of the DOE's Solid State Lighting Program Requirements Version 1.0, which clearly identified why 1.0 is the appropriate criteria for SSL and why the DOE has and will continue to be the appropriate body to implement the program.
McCullough covered important aspects, such as In Situ and UL 1598 testing and Quality Assurance Testing, as well as the Future Strategy, including the proposed additions to Category A and ‘Ratcheting’, as reported previously by LEDs Magazine - see Energy Star for SSL gets energetic start (May 2008).
Also discussed was the progression leading to the September 30th "go live" date, which will proceed as planned. Energy Star Partnership Agreements will become available in July, and an online product application submission is scheduled for August. It is expected this will lead to the availability of Energy Star SSL products in time for the September 30 launch.
Many resources will become available for manufacturers and there will be an extensive awareness and education program for end-users, including common messaging. As the market transcends to SSL, it will still be stressed that “CFLs are not the Enemy!”
The EPA issue
Richard Karney, DOE Energy Star Products & Program Manager, addressed the current DOE - EPA Energy Star issue Energy Star Wars and the battle to label LED fixtures (June 2008), commenting, “The Department understands the concerns Energy Star stakeholders have towards the present conflict between DOE's Solid State Lighting Program Requirements version 1.0 and EPA's Residential Light Fixture criteria version 4.2. We want you to know DOE is doing all it can to resolve the issues as quickly as possible.”
Karney repeated the June 13 statement of DOE Deputy Assistant Secretary David Rodgers, “DOE is aware of the confusion created by EPA's release of the amended criteria. Efforts to resolve this confusion are on-going - in the meantime, the September 2007 guidance stands as the valid guidance for SSL."
Karney added significantly to this statement: “There is direct conflict between EPA's version 4.2, and DOE's version 1.0 and the additional Category A applications soon to be shared for public review and comment. The criteria are not complementary, nor was DOE consulted. In fact, DOE learned about version 4.2 at the same time you did!"
"DOE recognizes there can only be one (set of) criteria for solid-state lighting. Two criteria occupying the same space will only create market confusion, increase program costs with duplicative marketing efforts, points-of-contact, etc. and ultimately harm the Energy Star brand. DOE is focused on resolving the issue quickly and we ask your patience during this period of confusion.
"DOE is committed to maintaining the open process that is the cornerstone of the Energy Star program. We value your participation and input.
"We will continue to focus on product quality ensuing end-user satisfaction with the technology and maintaining the trust placed by consumers in the Energy Star label. That confidence comes from the open process in establishing criteria and the use of standards and test procedures that are recognized by the lighting industry and developed through a consensus process. Failure to do so sets a dangerous precedent for the Energy Star program. The solid-state lighting industry is in the early states of its development and it is important to lay the infrastructure necessary to support future activities.
"Hastily developed non-industry consensus standards or test procedures only serve to undermine the technology and delay market introduction, potentially setting us down the same early path of CFLs. DOE will not let that happen.
"DOE will move forward with launching the first-ever Energy Star criteria for SSL on September 30, 2008 and keep pace with the technology as it evolves."
Q&A (with answers!)
After the 60-minute webcast program, there was no shortage of good questions filling the remaining half hour, and all were fielded with appropriate answers from the DOE team (in contrast with the EPA webcast of June 24 – see EPA hosts low-key webcast on Energy Star). The DOE promised to answer all questions remaining by posting responses on their website.
During the Q&A, Richard Karney read a comment from Pacific Gas & Electric Company (PG&E) outlining their position regarding the EPA RLF 4.2. Much like Efficiency Vermont, PG&E has chosen to not employ or utilize the 4.2 specifications at this time.
PG&E went on to relate the usage with their incentive programs, the subject of a previous article in LEDs Magazine - see Efficiency Vermont decides not to use EPA Energy Star spec. PG&E posed the question, “Has DOE been contacted by manufacturers or customers who share this concern and are confused?" Karney explained that they (DOE) had received numerous questions from both manufacturers and end-users, and that they (DOE) are working diligently to seek a resolution that will address the concerns and end the confusion.
Following the webcast. LEDs Magazine received the following quote from Mary Matteson Bryan, Lighting Portfolio Manager for Emerging Technologies at Pacific Gas and Electric Company (PG&E) which formed the preamble to her question during the webcast:
“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.”
Other questions surrounded the expenses incurred by manufacturers to develop quality product according to quality criteria, which could be rendered “useless” by the EPA’s actions. The DOE addressed a question as to why the LED replacement to the linear fluorescent has not been considered in the upcoming Category A additions (as previously reported in LEDs Magazine) and Jeff McCullough responded with the results of testing to date, the lack of energy savings and relative payback, as well as government fiscal responsibility to focus on products which are currently viable.
It was also asked about whether Energy Star will add to the cost of products and DOE recognized this in the process. It was reaffirmed by DOE that absolute photometry is required and not relative photometry. Asked why the Power Factor of 0.7 or greater for residential applications was so low, McCullough responded with the fact that it is actually much higher than 0.5 which was originally considered acceptable for CFLs and that the commercial threshold of 0.9 or greater is much higher as commercial customers can be penalized by utilities.
Now with the chiming in of both Efficiency Vermont and PG&E and with all questions answered to date with the exception of one, the only question remaining is what is on the mind of the EPA at this juncture. It’s time for the EPA to raise the ‘white flag’ on the ‘white light’ issue. There is another EPA webcast slated for July 8th. Once again, stay tuned!
Message from Jim Brodrick
Jim Brodrick, who heads the DOE's Solid State Lighting program, circulated an open email on June 30 with an update on Energy Star and the program in general.
View Brodrick's message on the World of LEDs blog (and make comments if you wish).
