Brodrick comments on LED Energy Star situation

July 14, 2008
Jim Brodrick, who leads the US Department of Energy (DOE) Solid State Lighting program, has circulated an email explaining his concerns over the EPA's Energy Star criteria.
[Editor's Note: this email was circulated on July 10 to DOE's distribution list, and is reproduced here without editing. Further articles relating to this situation can be found at:]

Greetings from sunny Portland. Since I’ve been in town, the most consistent question that I have received concerns the fact that there now seems to be two conflicting ENERGY STAR criteria for solid-state lighting, and “What is the government going to do about the unfortunate situation?” Excellent question, but I’m afraid the answer is far from being decided. No doubt the existence of two sets of conflicting criteria is creating a dilemma within the lighting industry that could have serious financial consequences.

Because this is a very sensitive issue between two federal agencies, and my own agency has chosen to try to resolve it in internal governmental channels, I can only provide information and views that come from myself and the team that has been working on solid-state lighting for over eight years.

EPA’s recent ENERGY STAR decisions and explanations for those decisions are troubling in many ways. EPA issued its criteria without allowing for any public comment. EPA declared the new amendments as final and effective immediately. DOE certainly was not appraised of EPA’s plans to issue these amendments, nor were any other stakeholders that I have spoken with.

EPA justifies their decision to waive public review requirements on the basis that the new amendments were technical, and only included recognition of a newly available test procedure. In fact, the scope of changes goes far beyond recognizing a new test procedure, as anyone reading the new criteria can clearly see.

EPA says that it is using an industry recognized test procedure, but I’ve yet to speak with any group or individual that has endorsed the ASSIST test procedure. The test procedure is not recognized, nor has it even been considered by any of the industry standards organizations, such as IESNA. The situation is terribly unfortunate for several reasons, but in the long run it is the potential damage to the lighting industry and the solid-state lighting market that most troubles me.

Even if one chose to overlook these violations of program requirements, one should take a very hard look at the EPA criteria purely from the standpoint of how they might impact the lighting market. While I could go into more technical detail, I’ll stick to a brief synopsis of our concerns about the EPA criteria that we believe would adversely affect the SSL market if stakeholders are allowed to choose between the two criteria.

While EPA contends that its criteria revision is complementary to the DOE criteria, they directly contradict DOE criteria. EPA claims the criteria only apply to decorative residential fixtures, yet the only residential light fixture explicitly excluded in the criteria is “recessed canisters.” The scope section of DOE’s criteria clearly state they apply to all general illumination luminaries, including decorative fixtures that provide functional illumination.

This leads to my next issue with the EPA criteria. DOE has worked very diligently with industry to chart a technically rigorous and market-appropriate path that would lead to a strong SSL market, and to the greatest extent possible, avoid the pitfalls suffered by CFLs during the early years of their market introduction. EPA, in essence, has bypassed this type of process by rushing out criteria that lack the technical requirements that would prevent the qualification of dim, bluish light products that we know will “turn off” consumers... Adopting the EPA process portends the very real possibility of inferior quality products becoming ENERGY STAR-qualified.

Part of the rigor of the DOE SSL Program has been to work closely with industry standards organizations (including IESNA, ANSI, UL, NEMA, CIE, CSA, and NIST) in the development of concrete test procedures that will assure accurate assessment of luminaries. These test procedures were established in accordance with accepted industry procedures, and with extensive review and comment. Our counterparts at EPA contend that the ASSIST test procedure also received industry blessing. Yet in the rush to recognize a new test procedure, they have completely circumvented industry standards organizations.

While my comments might seem biased to some because I’m arguing DOE’s case in an intra-governmental dispute, which I’m sure most would like to just go away, think about the ramifications of not having a sound foundation for distinguishing between good performing and poor performing products. Don’t dwell on what might seem the easy way out; or the least expensive way to qualify products; or, being able to immediately qualify all different types of products as ENERGY STAR. Think about what is the right thing to do in advancing this important new product into the market.

Please send any questions or comments to [email protected] .