EPA invites comments on LED Energy Star criteria

Although it has not suspended its version 4.2 amendment to Energy Star for Residential Lighting Fixtures, as requested by CEE, the EPA has invited comments on the amendment.

The Environmental Protection Agency (EPA) has invited "interested parties" to comment on the technical amendment (version 4.2) to the Energy Star specification for residential light fixtures (RLF), which controversially included RLFs incorporating LEDs.

The background to this story can be found in our June 10 story "Energy Star Wars and the battle to label LED fixtures" and several subsequent articles on our Energy Efficiency page.

In a letter dated July 9, EPA says it will be accepting written comment until August 25, 2008. Comments should be sent to RLF@icfi.com. After this period, EPA will compile any comments received and consider the appropriateness and timing of any suggested changes. All stakeholder comments on the technical amendment will be posted on the Energy Star website unless otherwise requested.

However, the EPA does not appear to have addressed an explicit request from the Consortium for Energy Efficiency (CEE) in a letter dated July 2. The CEE is a highly influential non-profit organization that works with its members in the U.S. and Canada to promote energy efficient products, technologies, and services.

Download the July 2 letter sent by the CEE.
Download the July 9 letter sent by the EPA.

In its letter, the CEE said that it was submitting comments on RLF 4.2 because "the review process used to develop version 4.2 did not consider the program interests that we represent."

The CEE letter also called for "the suspension of the Energy Star Residential Light Fixture Specification, version 4.2, until the matters described in this letter are resolved."

As far as we can ascertain, EPA has not suspended RLF 4.2 (when the criteria were announced on June 2, they were described as being effective immediately), which means that the uncertainty in the industry will continue, but at least they are prepared to listen to comments.

A copy of Version 4.2, which includes web links to ASSIST test procedures, is posted on the Energy Star website (PDF file).

The author of the EPA's letter, Alex Baker, the Energy Star Lighting Program Manager, also welcomed parties to contact him directly with any questions or concerns at (202) 343-9272 or via e-mail at. baker.alex@epa.gov.

Baker's letter said that, since the release of RLF Version 4.2, EPA has received a number of comments and questions related to whether and how the specification will ensure only high quality LED products will qualify for the Energy Star. "With this letter, EPA would like to summarize the steps it has taken to address important quality issues and to provide stakeholders an opportunity to comment on the requirements:

• EPA is consistently concerned with product quality and the potential impacts of poor quality products on the ongoing integrity of the Energy Star Program and, in this case, the potential negative impact that quality issues could have on LED lighting.
• EPA believes that the [RLF 4.2] technical amendment, extending existing performance requirements to a new technology, requires reasonable testing and other procedures to address the quality issues that are important to today’s consumers such as light output, light color, and lumen maintenance/life.
• The Energy Star specification requires testing data on light output and color temperature to substantiate manufacturer claims. The specification also references the ASSIST Recommends test procedure for lumen maintenance/life. This test accounts for heat-related performance issues and allows for an L70 lumen maintenance projection using a 6,000 hour test. This is currently the most comprehensive test available as we wait to see developments with IESNA LM-80."

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