Stakeholders are encouraged to submit comments on this draft to EPA no later than Monday, June 21, 2010. Comments should be submitted to email@example.com with “ENERGY STAR Luminaires First Draft Comments” in the subject line.
The specification, a cover letter and notes from a recent LRC-NEMA-ALA Roundtable Meeting can be found on the Energy Star Luminaires page.
Although not explained explicity in this proposal, it is now clear that EPA intends to introduce two "technology neutral" specifications: Energy Star Luminaires, and Energy Star Lamps.
The draft Luminaires specification will eventually supersede both the Solid State Lighting Luminaires (version 1.1) specification, which was implemented by the DOE, and the Residential Light Fixtures (version 4.2), which was amended in June 2008 to include solid-state luminaires. These specifications remain in place.
The intended schedule for the Luminaires specification is as follows:
• Draft 1 release: May 7, 2010
• Webinar: June 8, 2010
• Draft 1 comment period close: June 21, 2010
• Draft 2 release: July 2010
• Draft 3 release: August 2010
• Final specification: September 2010
• Specification effective date: June 2011
The draft specification is highly detailed, but some of the main points are discussed below.
In the cover letter accompanying the draft Luminaires specification, Alex Baker, EPA Lighting Program Manager for Energy Star, said that "the Luminaires specification, to the greatest extent possible, is intended to be technology-neutral in terms of key criteria such as luminous efficacy and color performance. This approach allows manufacturers across various technologies to compete on a level playing field… Because consumers shop for light fixtures, rather than lighting technologies, it is important for the Energy Star label to mean the same thing in terms of energy savings, regardless of technology."
According to Baker's letter, "EPA believes the greatest near-term opportunity for efficiency gains and technological advances in the market is to propose that directional fixtures be subject to luminaire photometry, and non-directional fixtures be evaluated at the light-source level."
Baker's reasoning is that when consumers buy certain types of fixtures, the aesthetics are at least as important as overall energy efficiency of the luminaire. Here, if Energy Star forces manufacturers to focus on luminaire efficacy, it will result in designs that don’t compete well aesthetically, leading to reduced market impact and lower overall savings. So, the goal would be to have an energy-efficient source (lamp) inside an aesthetically-pleasing luminaire.
However, many applications are directional in nature (e.g. under cabinet, recessed downlights, track lights), and are designed and chosen with less emphasis on aesthetics. EPA believes these can and should be evaluated on the basis of luminaire photometry, measuring light delivered from the luminaire. Solid-state luminaires based on integrated components that cannot be replaced should also be subject to luminaire photometry.
Efficacy and minimum light output:
Efficacy requirements for non-directional luminaires have been increased to 70 lm/W, up 40% compared with the RLF spec. This applies to source photometry measurements of either an LED light engine or a lamp/ballast combination in the case of either fluorescent or HID lamps. Also for non-directional luminaires, each LED light engine or lamp/ballast combination must provide a minimum of 850 lumens. It's important to emphasize these values are the source values, not the luminaire values.
In many cases, the requirements for different types of directional luminaires have been carried over from the values in the SSL specification.
Correlated color temperature:
All indoor luminaire types, and all technologies, will be limited to 4100 K and below.
EPA proposes to require a minimum Ra value (“CRI”) of 80 for indoor luminaires, applying to all luminaire types, and all technologies. The requirements will also include evaluation of special index R9 performance.