Last week, without advance notice or public consultation, the US Environmental Protection Agency (EPA) released Energy Star Program Requirements for Residential Light Fixtures (RLF), Eligibility Criteria – Version 4.2, which contains reference to LED-based fixtures. As described in our initial report of June 6, this puts the EPA at odds with the US Department of Energy (DOE), which has already released Energy Star criteria for SSL after several years of work and consultation.
The EPA's RLF 4.2 document defines the product specification for Energy Star qualified residential light fixtures and replacement GU-24 base integrated lamps, indicating that a product must meet all of the identified criteria if it is to be labeled as Energy Star by its manufacturer. Energy Star is a labelling program for energy-efficient products, and is run jointly by DOE and EPA.
The intent of Energy Star for RLF is to move consumers from traditional incandescent fixtures to fixtures that use high-quality fluorescent lamps, LEDs, or other energy-efficient technologies, including motion-sensors and daylight-sensors for outdoor fixtures. The specification covers the requirements for indoor and outdoor light fixtures, recessed downlight retrofit kits and replacement GU-24 base integrated lamps intended primarily for residential type applications.
So far so good, but here is where the contention stems from. EPA added five new pages of specifications to RLF, expanding the scope of the RLF to include fixtures using “LED light engines” for “primary illumination.” These specifications address a wide variety of LED performance measures, including efficacy, color rendering index, correlated color temperature, lumen maintenance, color stability, operating frequency.
EPA announcement
In a June 2 open letter from the EPA’s Office of Air and Radiation (which administers Energy Star), Alex Baker, Manager of the Energy Star Lighting Program stated, “The purpose of this letter is to inform you regarding a technical amendment to the Energy Star residential light fixture (RLF), ceiling fan and vent fan specifications. With this amendment, EPA is responding to a number of requests from manufacturers to incorporate test procedures and metrics to allow LED-based fixture performance to be evaluated against the requirements of the existing RLF specification. This is pursuant to the recent finalization of a new testing procedure for LED light engines which makes it possible to test LED-based fixtures in a manner comparable to the way other technologies are tested under the longstanding Energy Star residential fixture program.”
Baker's letter said that EPA believes it is appropriate to allow LED-based fixtures to be eligible for the Energy Star "if they indeed demonstrate the performance required in the current residential specification (while also ensuring the products deliver on their claims of long life). This technical amendment clarifies the procedures and requirements for these fixtures to qualify. Given the importance of providing a level playing field across today’s efficient lighting technologies, it is effective immediately.”
EPA has not completely ignored the DOE Energy Star program. The letter continues, "This technical amendment compliments the DOE SSL program by allowing for a broader set of LED-based light fixtures to participate in a harmonized manner with other Energy Star qualified residential light fixture technologies.
Later, Baker's letter says that "This amendment allows for the immediate qualification of LED-based fixtures that are intended for residential general illumination, and it allows them to qualify at the performance levels required for other lighting technologies. EPA will be coordinating with the DOE as to how best to provide manufacturers with as seamless a process as possible to qualify and promote the full array of Energy Star qualified residential light fixtures."
The letter contains many phrases and statements that could easily be described as "spin". The question is this: what does this all really mean when it comes to general illumination and the years of effort and work in the SSL general illumination space conducted by the DOE. This includes the input and participation of the many - and I mean many - stakeholders from the SSL industry, other government energy agencies, utilities and energy efficiency organizations, of which I represent one.
Shining some light on the issue
I am certainly not alone in thinking that the "new" criteria in EPA's RLF 4.2 allowing qualification of light fixtures using LED light engines directly overlap and contradict DOE's existing Energy Star criteria for solid state lighting (SSL) luminaires. The DOE's much stronger Energy Star SSL document was published on September 12, 2007 with an effective date of September 30, 2008. Our article entitled Energy Star for SSL gets energetic start gives a good review of the DOE's work. Sources close to the issue object to EPA’s action for a variety of reasons, including the following:
1) Lack of public review:
The EPA issued the new LED specifications, without public review or comment, declaring them final and effective immediately. Failure to allow for public review and comment violates long-established Energy Star program protocol. The specifications were developed in secret, without the knowledge of the DOE, EPA’s co-manager of the Energy Star program, and without any public announcement of EPA’s plans. DOE learned of the new specifications only after they were announced as final, and effective immediately.
2) Overlap and contradiction:
EPA's new criteria contradict the DOE-developed Energy Star SSL criteria. EPA’s new specifications allow for residential LED fixtures that are already covered by the DOE-developed specifications, creating two competing sets of Energy Star criteria covering the same products. This creates significant confusion for manufacturers and other Energy Star partners, who are in the process of preparing for the phase-in of DOE's SSL criteria.
3) Non-standard test procedures:
EPA’s new specifications reference test procedures developed by the Lighting Research Center, not the Illuminating Engineering Society of North America’s (IESNA) new LM-79 standard or its forthcoming LM-80. Yet at this point, LRC’s test procedures documents are basically thought pieces, which haven’t been subjected to the rigors of review by industry standards organizations. In contrast, the DOE-developed specifications were adopted in close cooperation with all major lighting industry standards organizations, including the IESNA.
4) Inadequate lighting quality requirements:
The EPA's criteria are so lenient that they allow for a wide range of low-performing products, many likely to share the same poor light quality attributes associated with early CFLs. For example, EPA’s specifications allow for very high color temperature lamps, which consumers have clearly rejected in the CFL market. Further, they allow for products with very low light output, despite clear evidence that consumers rejected CFLs because they were too dim.
In summary, a source close to the issue commented that, “The EPA actions were ill-advised and will cause great turmoil within the industry”. We often refer to the SSL industry at this point in time as being like the "Wild West". It is unfortunate that a "shoot from the hip" attitude appears to be alive and well in government.
The Energy Star website states that “Energy Star is a joint program of the [EPA] and the [DOE] helping us all save money and protect the environment through energy efficient products and practices.” The key word is "joint" although the EPA continues to battle for supremacy unnecessarily.
Importantly, the DOE is designated as the lead federal agency for SSL though provisions of Section 912, the Next Generation Lighting Initiative, of the US Energy Policy Act of 2005. This legislation establishes a road map for introducing SSL technology to consumers and end-users.
The Energy Star brand
In a recent Canadian Energy Star Participants’ Meeting that I attended in Ottawa last week, attendees discussed the importance of the Energy Star "brand", including managing and protecting the brand, as well as strengthening the brand by "raising the bar" through ongoing criteria development and revisions. It must be the weather or the water in Canada or the fact that our Office of Energy Efficiency of Natural Resources Canada understands the "brand" better than the EPA itself as is appears that the EPA is bent upon ruining the brand in this instance.
Unproductive actions by the EPA and the deficiencies in the management of Energy Star have not gone unnoticed by watchful eyes. In fact, the EPA’s own Office of Inspector General (OIG) thinks the same. A very critical report dated August 1, 2007 and entitled, "Energy Star Program Can Strengthen Controls Protecting the Integrity of the Label" can be found at http://www.epa.gov/oig/reports/2007/20070801-2007-P-00028.pdf.
The report says that the OIG found that "The criteria for revising specifications were unclear and not documented. It was not evident when or what factors would trigger a specification revision…The [EPA]'s verification testing also lacks a clear documented methodology governing products selected for verification tests and does not test for statistically valid results. Consequently, product efficiency and energy savings reported by manufacturers are, for the most part, unverified by EPA review…We [OIG] also found that manufacturers may label and sell products as Energy Star qualified prior to submitting test results to the Agency. Using the label on products that do not meet Energy Star requirements may weaken the value of the label and negatively impact the Energy Star program."
Lessons learned at The Post
Ironically, a Washington Post article on Sunday, June 8 entitled ‘Today, CFLs. Tomorrow, LEDs?" Eviana Hartman wrote about the future of LEDs in lighting, and how they will overtake CFLs for various reasons. With more media attention, there becomes an even greater interest in change, thus creating an immediacy and increased sense of urgency to purchase products. This can subject the potential buyer to exploitation by the unscrupulous supplier, either due to simple ignorance or absolute intention. This situation can, and will, result in disappointment. The last thing that we need is to put the Energy Star "Good Housekeeping Seal of Approval" on low quality LED lighting products due to the EPA’s misguided actions.
Returning to the article in The Post that compares CFLs to LEDs, the further irony is that it appears that the EPA hasn’t learned from the past. In September 2006, the DOE released a report entitled, "Compact Fluorescent Lighting in America: Lessons Learned on the Way to Market." Prepared by Pacific Northwest National Laboratory (PNNL), the report provides an analysis of the market introduction of CFLs in the US, with an emphasis on identifying lessons that could be applied to the market introduction of other new lighting technologies, such as solid-state lighting.
The report details marketing and technological considerations that ‘can’ be accomplished with respect to SSL and a path to avoid the avoidable blunders, gaffes and oversights experienced with CFL market introduction and technology. Issues ranging from consumer expectation to the technical, such as Power Factor, can be addressed correctly in the competent design and development of SSL. It appears that the Lighting Program staff at the EPA did not read or overlooked this great resource. It is hoped that it would not be necessary to commission Lessons Learned: Volume II - The SSL Story!
The price of poaching
In its efforts to grab turf in the SSL space, it is evident that the EPA has not realized the consequences or impact of their actions. Over the last 2 years, many industry representatives, manufacturers, governments, utilities and energy efficiency organizations have invested money, time and other resources in a concerted effort to bring quality product to market. This has been virtually disregarded by the EPA. Not only does participation in the process cost money, but also developing product consistent with the higher DOE criteria has additional costs to assure quality.
Also, governments and utilities rely on Energy Star in the delivery of incentive and rebate programs employing quality and reliable technology. The last thing on which you wish to base a monetary program is a technology that will fail to meet expectations or simply just won’t last a reasonable time. Many fine energy efficiency, environmental and charitable or non-profit organizations that work with SSL technology, such as the Clinton Climate Initiative Lighting Program, the Light Up The World Foundation and Toronto’s own greenTbiz and LightSavers programs will have to reconsider the criteria language in their quest for suitable products.
LightSavers, through the City of Toronto, is about to issue a Global Expression of Interest for LED public space lighting and adaptive lighting technology. Current confusion may cause to not refer to Energy Star, thus be non-prescriptive to Energy Star itself, a total oxymoron. Many other partners in the ‘LED City’ program will also rely on strong Energy Star criteria in their quest for municipal lighting, especially when being accountable to the taxpayer.
Even the Office of Energy Efficiency of Natural Resources Canada will have to select which Energy Star criteria to support. Faced with the fact that RLF 4.2 also references products and technology other than SSL, this poses a great difficulty. Take other DOE programs into consideration, such as CALiPER and Gateway, as well as DOE sponsored activities, such as Lighting for Tomorrow and Next Generation Luminaires competition and the recently announced $20 million ‘L’ Prize competition investment that all defer to the DOE Energy Star criteria for evaluation, testing and verification and it is easy to see the extent of the impact.
By ‘low balling’ the quality, the EPA has failed the consumer or end-user reliance on Energy Star. The public equates Energy Star with ‘must be good’. This essentially has ‘broken the public trust’.
Comments from EPA
After the initial LEDs Magazine news announcement last week about the EPA's actions, we were able to speak with Alex Baker, Manager of the Energy Star Lighting Program, in an effort to take into consideration and attempt to understand the position of the EPA. Baker has experience in this field and is a graduate of the Lighting Research Center (LRC) with an MSc in lighting and a thesis relating to LEDs. He also holds the LC (Lighting Certified) designation from the NCQLP.
Giving some history of the program, Baker explained that, “the Energy Star Program takes a technology-neutral approach to specifications, attempting to not employ specifications that are technology specific” adding that “residential light fixture (RLF) manufacturers historically have been led by the lamp industry (light sources). The intent of the RLF program is to characterize the performance of the light sources used in the fixtures. RLF manufacturers will rarely if ever do goniometric photometry on their fixtures.”
“Using definitions in draft IESNA RP-16 language, LED light engines incorporate LED packages, LED drivers, heat sinks, and may include secondary optics” said Baker, adding, “This is a natural extension of our 11 year old program’s approach of evaluating and characterizing the performance of light sources used in qualified fixtures.”
Asked why the EPA added LED to the RLF 4.2, Baker responded that, “It was the result of fielding requests from RLF manufacturers and retailers.” He added “Manufacturers and retailers both feel confident that they have LED based products available that would meet the existing [pre RLF 4.2] performance criteria."
Baker further commented that, “Residential light fixture manufacturers are not willing to take a full fixture approach to testing their products” adding, “Residential lighting is driven by cost; these manufacturers simply cannot absorb the photometric testing costs to which commercial lighting manufacturers are accustomed”.
Asked about the testing procedure, Baker commented, “We believe that the Alliance for Solid-State Illumination Systems and Technologies (ASSIST) is an appropriate organization to develop and vet the procedure for testing LED light engines to put them on a level playing field with other technologies". Baker pointed out that, “The RLF 4.2 applies to non-directional LED residential lighting fixtures only”.
Baker commented that, “The EPA has been a long standing member of ASSIST and their test procedure for LED light engines is a strong addition to the body of ASSIST Recommendations.”
“This technical amendment complements Version 1.0 of the DOE Energy Star criteria for SSL” commented Baker. Ask if he thought that the RLF 4.2 criteria was strong enough, Baker responded, “I do”. When asked if he felt that both life and light output were adequately covered, he responded, “Yes, they are both addressed in the specifications and test procedures”.
Asked about the expedient process without public consultation, Baker responded, “It was felt that it was important to move it ahead quickly due to the volume of requests and confidence of the manufacturers and retailers, all being Energy Star Partners”.
Asked about whether he felt that the criteria would cause to deliver products that would satisfy the consumer, he responded, “Yes, the amendment will strengthen the brand name which we strive to maintain.”
Asked about the difference in opinion between the 2 agencies, both being co-managers of the brand, over the criteria, Baker responded, “With respect to the performance requirements, they are very much the same as that of the DOE, but there is a different approach to how it is evaluated”. When asked about the potential stain on the relationship with the DOE, Baker responded, “EPA wishes to continue to work with the DOE in a collaborative fashion to strengthen the Energy Star brand name”.
When asked to deliver a message to consumers and end-users as to the continued credibility and relevance of Energy Star, with respect to the RLF and SSL, Baker stated, “The Energy Star residential light fixture program has worked with ASSIST and has taken input from RLF manufacturer and Energy Star retail Partners, the ALA (American Lighting Association) and its members, and has created a technical amendment that allows consumers to know that qualified fixtures employing LED light engines will provide the same level of energy savings, quality and longevity as they have come to expect from other Energy Star qualified Residential Lighting Fixtures".
Fallout
Responses such as those above will be disappointing to many who have worked diligently on the development of sound SSL criteria for Energy Star.
In many presentations I extol the same adages repeatedly, such as “There is not shortage of inferior product and overstated claims” and “You cannot expect to purchase LED on price point today”. But Mr Baker says that the residential lighting market is “driven by cost”, which will surely be the ‘driver’ to inferior product that can only be justified by overstated claims. Open up the floodgates!
This ‘fast and dirty’ approach is reprehensible and unacceptable. It is time for everyone affected to weight in and voice their support for the DOE. In an LEDs Magazine opening report last Friday, Tim Whitaker urged, “In the coming days and weeks we will doubtless hear much more about this issue, but we urge the industry to treat the DOE's documentation as the definitive Energy Star criteria for solid-state lighting.”
Personally (and I am not a gambler), I would place my bet, my money, my efforts and my time on the DOE. The only gamble is not coming to the table, or giving any credence or support to the EPA.
Seeing Stars
Whether in the US or in Canada, the Energy Star brand is important to the consumer and the end-user, offering a form of quality assurance and product reliability. It is certain that the DOE knows this but it is uncertain as to the EPA’s experience and knowledge in this matter as well as to their understanding of the importance of their own brand.
What is certain is the confusion that will be created by the EPA and the uncertainty for the industry, the market and the consumer or end-user. Another certainty is that the EPA has just offered a license for inferior products to come to market, which could quite possibly give a big "black eye" to the technology.
As mentioned earlier, the gloves are off and the bell has rung. The next round in this match will likely see the delivery a one-two punch from the DOE, with the referee likely coming from the White House. Optimistically, let’s hope that the EPA "sees the light" before this escalates further.
