Editorial:
EPA Plays Politics with Solid State Lighting, Repeats CFL Mistakes
... It was unconscionable. On June 2, 2008, a date that will live in infamy, the solid state lighting community was suddenly and deliberately attacked by the combined communication and policy forces of the Office of Air and Radiation the US Environmental Protection Agency... It will be recorded that the... Read the editorial...
(if it resists... go here)
June 17, 2008...The DOE has addresses SSL Guideline Confusion related to the EPA’s recently released SSL module standards, and several organizations and critics have come out against the guidelines.
The Department of Energy’s SSL Program and SSLITA and OIDA have responded to the latest solid state lighting guidelines published by the U.S. Environmental Protection Agency.
While the U.S. Department of Energy (DOE) has worked with industry insiders and researchers for over four years to arrive at its recommended standards for LED Luminaires and Fixtures, one part to the DOE’s recommendations was not formally published, the standards for LED modules which combine into luminaires and fixtures.
For this reason apparently, the EPA published a new set of guidelines specifically for LED modules. Unfortunately, the specifications outlined in the EPA guidelines remain unclear, and seem to have left many technical questions unanswered. Critics of the EPA’s new SSL guidelines have charged that they are inaccurate, difficult to implement, and most likely harmful to the long-term adoption of LED luminaires around the country.
Tom Griffiths, publisher of LIGHTimes and a critic of the EPA’s SSL guidelines, stated in his recent column that the EPA guidelines in fact make the same mistakes that were made with the early guidelines of CFL technology. Tom argues that the early guidlines of CFL technology allowed dim and harsh lighted CFLs to be sold to the public with government approval, and this led to the slowed adoption of CFL technology. He contends that the EPA's guidelines allow the same mistake with solid state lighting technology. (Ref: Column).
David Rodgers, Deputy Assistant Secretary for Energy Efficiency and Renewable Energy at the Department of Energy issued the following statement Friday regarding the release of the EPA’s LED module guidelines, "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."DOE News Release.
The Solid State Lighting Industry Trade Association, and the Optoelectronics Industry Development Association have also issued official statements regarding the guideline confusion. The Solid State Lighting Industry Trade Association (SSLITA) and the Optoelectronics Industry Development Association (OIDA) both of Washington D.C., announced their support for, “... a single minimum quality and performance requirement for Energy Star-approved solid state lighting (SSL).” SSLITA and OIDA acknowledged, “LEDs have the potential to be dramatically more effective at lighting spaces than current incandescent bulbs (standard bulbs) and even fluorescent and halogen bulbs.” However they explained that LED luminaires could also be made with unpleasant light qualities or could be made inefficient despite the high efficiency inherent in LED chips themselves. For this reason, the organizations, officially stated, “SSLITA and OIDA believe it is critical that high quality SSL products make it to market for U.S. consumers.”
SSLITA and OIDA said in a recent news release that “Numerous requirements appear to be in direct conflict between these two standards, which creates confusion in the marketplace In addition, the EPA version of these standards appears to have been developed without public comment or interaction with the SSL community.” SSLITA and OIDA also indicated that the EPA guidelines make the same mistakes that the CFL technology guidelines initially made CFLs were initially considered harsh, dim, and otherwise unappealing and thus consumers resisted adopting CFL technology. SSLITA and OIDA argued that, “As the CFL experience has taught us, if certain minimum expectations in the quality, reliability, apparent brightness, and directivity of the light produced are not met, the products will be considered of poor quality which has the potential of slowing adoption by the market of this critical energy-saving technology. With the critical impact SSL can have on both energy consumption and the production of green-house gasses, we consider this confusion a major detriment to the industry and to the nation.”SSLITA says it will support quality labeling, end-market promotion and education, and government initiatives to expand the use of SSL. SSLITA operates as a subsidiary of the OIDA.
SSLITA and OIDA News Release.
Other trade associations and organizations have taken note of the new EPA policies and have issued official statements. One such organization, Efficiency Vermont, has come out strongly against the current version of the EPA’s SSL module standards stating,
“As new solid-state lighting products come into the market, Efficiency Vermont is looking to use a comprehensive and rigorous specification that will maximize product quality and consumer satisfaction. With these objectives, Efficiency Vermont does not plan to use the currently proposed RLF 4.2 SSL specification developed by the EPA.”
Insight Media Predicts LED Backlights to Take Significant Market Share Soon LIGHTimes Staff
June 17, 2008...Insight Media a market analysis firm of Norwalk, Connecticut USA, has released its new backlight unit report that outlines the future of various types of LCD backlighting technologies. These including various CFL and LED configurations. Chris Chinnock, president of Insight Media said, “Which combinations offer the best price-performance? Which ones have clear paths to high volume production? Which combination is best for a particular product? These are the type of questions the LCD BLU Report seeks to answer.”
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June 17, 2008...Toshiba’s Digital Products Division has introduced what it claims is the world’s lightest laptop. Its biggest innovation is the 128 GB solid state drive, which weighs much less than conventional hard drives. Another important innovation that didn’t hurt in terms of its size is that it is backlit with LEDs. The company says that it offers the world’s first widescreen 12.1-inch transreflective LED backlit display, Conventional LCD monitors are difficult to read because of the glare in direct sunlight. However, Toshiba says that the new laptop has what it calls a transreflective screen that lets the sun’s light pass through. Then the light is reflected out to bring the images to life so users can switch off the LED backlighting while outdoors.
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Philips Receives Recognition for Championing Energy Efficiency SSLDesign News Staff
June 13, 2008...In December 2007, in an unprecedented move, the U.S. government passed an energy bill that will change the way our homes are lit. It officially gave the Edison light bulb makers, notice that the days of its dominance are numbered by banning incandescent bulbs for most applications by 2014. To reach that point, many organizations, and businesses exerted significant influence in first proposing and then passing the legislation that put the future ban into effect. One organization that had considerable influence over the legislation was the Alliance to Save Energy.
The Alliance to Save Energy has given an award to Philips in recognition for its service in promoting energy efficient technology. The Alliance to Save Energy has selected Philips Electronics for is 2008 “Stars of Energy Efficiency” Chairman’s Award. The award was established to give recognition to the nation’s most proactive energy efficiency advocates. This year’s Chairman’s Award was chosen by Alliance Board Honorary Chair Sen. Mark Pryor (D-Ark.), who indicated he chose Philips for its formation and outstanding leadership of the Lighting Efficiency Coalition. The Lighting Efficiency Coalition was an unprecedented collaboration among environmental groups, members of the lighting industry, environmental groups, and legislators to establish efficiency standards for and the phase out of inefficient lighting technologies. The Philips and the Lighting Efficiency Coalition spearheaded the Energy Independence and Security Act (EISA) of 2007.
EISA establishes technology-neutral, performance-based lighting efficiency standards as well as government incentives to accelerate the use of compact fluorescent light bulbs (CFLs), light-emitting diodes (LEDs), and energy-efficient halogen lamps.
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New White LED Driver from TI Brightens LED Backlit LCD Notebook Displays LIGHTimes Staff
June 12, 2008...Texas Instruments Inc. of Dallas, Texas USA, has introduced a six-channel, 40-V white light emitting diode (LED) driver with a built-in, high-efficiency boost regulator and 1.5-A FET. TI boasts that the TPS61181 is the smallest LED driver to manage up to 60 white LEDs at once. According to TI, it provides high power efficiency and accurate current regulation for medium-sized displays for notebooks, portable GPS, industrial, and medical applications. The company points out that conventional notebook and other LCD displays have relied on CCFL (cold cathode fluorescent lamps) technology to backlight the display, but many portable electronics makers have switched from CCFL to white LEDs for backlighting. TI says that LED backlighting allows for greater power savings and thinner panels compared to CCFL backlighting. TI explains that such conversion has already taken place in most smaller LCD applications including mobile phones and portable media players.
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Daktronics Introduces the 12 mm Valo OT Digital LED Billboard LIGHTimes Staff
June 12, 2008...Daktronics of Brookings, South Dakota USA , a top digital billboard manufacturer, unveiled its 12 mm Valo Optimized Technology digital billboard. The company touts the billboard’s wide viewing angles, enhanced contrast, and a high-density pixel configuration for close-up viewing. Daktronics says its 12 mm Valo OT delivers sharp images for outdoor advertising. The company notes that the 12 mm Valo OT builds on the success of the popular 16 mm Valo OT. It also reportedly uses the same innovative design as the 16 mm Valo OT and the latest in LED technology. The company explains that the 12 mm Valo OT provides vivid picture quality while optimizing light output and energy use.
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Strategies Unlimited Predicts Continued Strong Growth in HB LEDs for Lighting LIGHTimes Staff
June 12, 2008...Strategies Unlimited (SU), the premiere market analysis firm covering the LED industry, has begun accepting orders for its annual high brightness LED market review and forecast. Strategies Unlimited reports that the market for HB LEDs used for lighting applications is one of the fastest growing segments of the HB LED market. The company revealed that the market for HB LED lighting used in lighting applications has grown at a rate of 60 percent per year since 2006. According to SU, the report will provide an LED industry overview, and a listing of the companies involved in the HB LED industry. SU says its report will include market data and forecasts through 2012 broken out by material type, color, and package type.
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Osram Launches Ostar Projection SMT LED for Pico Projection Applications LIGHTimes Staff
June 10, 2008...Osram Opto Semiconductors has introduced the Ostar Projection SMT LED, which the company says is designed to be integrated into pico projection applications. Osram says that the packaged surface mountable LED measures just 5.8 x 4.7 x 1.5 mm. Its small size makes it ideal for ultra miniature pico projection applications such as those that might be integrated into cell phones and other mobile devices in the future.
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HP Introduces LED-based Color-critical Display LIGHTimes Staff
June 10, 2008...Hewlett-Packard (HP) has introduced its new color-critical computer professional display. The company boasts that the display is available for less than a quarter of the cost of displays with competitive performance. The HP DreamColor Display features a new liquid crystal display (LCD). While LED backlit LCD displays have been around for a while, color reproducibility has been a concern for graphics professionals, digital movie makers, and animators.
Instead of the 24-bit graphics offered by most LED- based LCD computer display screens, the new HP display provides a range of more than 1 billion colors in a 30-bit, LED-backlit display. 30 bits of color has 64 times the number of colors on conventional LCD displays with 24 bits of color. The display is now shipping worldwide for a U.S. list price of $3,499. HP points out that the display is the result of a technology collaboration with DreamWorks Animation SKG Inc.
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Seoul Semiconductor Korean Design Patents Declared Invalid in Nichia Dispute LIGHTimes Staff
June 10, 2008...Nichia has won the latest IP dispute round with Seoul Semiconductor. Nichia announced that on May 22, 2008, the Korean Intellectual Property Tribunal (IPT) ruled that Seoul Semiconductor’s design registration (No. 364186) is invalid. The tribunal found that the registration was similar to the prior art design registration of Nichia Corporation (Design Publication; Similar Design Registration No. 294490-2). The IPT reportedly rendered the decision against Seoul Semiconductor in relation to the patent invalidation suit filed by Nichia on July 24, 2007. The two companies have butted heads over intellectual property rights around the world for several years. The ruling of the Korean Intellectual Property Tribunal ends only one chapter of the ongoing dispute. Nichia News Release
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Commentary & Perspective...
EPA Plays Politics with Solid State Lighting, Repeats CFL Mistakes Tom Griffiths - Publisher
June 12, 2008...It
was unconscionable. On June 2, 2008, a date that will live in infamy, the solid
state lighting community was suddenly and deliberately attacked by the combined
communication and policy forces of the Office of Air and Radiation the US Environmental
Protection Agency... It will be recorded that the distance from a government-inspired
concept to an actual policy makes it obvious that the attack was deliberately
planned many days or even weeks ago. During the intervening time the EPA has deliberately
sought to deceive the solid state lighting community by their cooperative approach
and expressions of hope for continued peace. (Ref FDR Pearl
Harbor speech for relevant inspiration.)
So what form did this sneak
attack take? In a June
2 letter to lighting "manufacturers and other interested parties"
the EPA announced a "technical amendment", version 4.2, to the Energy
Star residential light fixture (RLF), ceiling fan and vent fan specifications
that is of immediate effect in allowing LED light fixtures to achieve the Energy
Star mark. It does that by allowing qualification to "new testing procedures"
that are somewhat useful but unproven, unqualified at the fixture level and without
quantitative history to substantiate their predictive reliability. In addition,
the spec itself is directly contrary to the SSL and lighting industry consensus
that agreed that the "dim and harsh" factor was a major consumer turn-off
with regard to CFL technology at its introduction. Unappealing and ineffective
CFL lamps introduced into the residential market caused a general rejection of
that technology and set back the pace of adoption on the order of a decade.
The
EPA's answer is apparently to repeat the mistake by allowing residential luminaires
throwing out as little as 0 (zero, zip, nada) lumens to qualify as long as the
light engine inside generates 40 lumens/watt with a CCT that can be as harsh as
6500K (like lighting your house with an arc welder that's malfunctioning). Oh,
and you have to label it with wording such as "This fixture produces light
equivalent to a 6 watt incandescent bulb" in accordance with a handy reference
chart. If your integral light engine produces 40 to 69 lumens, you simply need
to label it as "equivalent to a 6 watt incandescent bulb". For reference,
my wife and son use those leftover 40 lumen bulbs in their tabletop snow village
display each Christmas because they're too dim for use as decent nightlights!
The EPA figures that qualifying the LED light engine (to whatever minimal standard)
inside the fixture is sufficient. So, you can grab your Energy Star mark, push
a grand 10 lumens out of a crummy LED "reading light" and claim it is
as bright a 40-watt bulb because your "LED light engine" inside the
fixture produces between 450 and 799 lumens that are going who knows where. That will
get them flocking to the stores to buy one for every room in the house! (Relevant
4 pages of the RLF spec here,
or full spec here,
with SSL amendment starting on page 35 of the actual doc which is page 45 of the
PDF. Note that we have to invest our bandwidth in providing it to you as the EPA
hasn't yet posted it anywhere... still trying to keep anyone from noticing?).
So
is the EPA unaware that consumers eventually buy these products? Heck no. They
are confident that consumers are so varied (or ignorant?) with their opinions
that they can simply try it and decide if they like it or not, as is made clear
by their notation at the end of the spec: "Note: EPA seeks to ensure that
qualified fixtures meet consumer expectations for light output. Consumer preference
for light output varies widely, and the same is true for fixture design intent.
Therefore it is impractical to prescribe lumen values for various residential
lighting fixture applications. This consumer awareness requirement is intended
to help consumers understand the limitations of LED light engines producing less
than 800 lumens (equivalent to 60 watts incandescent)." No reason to
accept the lighting industry and market consensus that consumers may actually
have an interest in the amount of light that actually comes out of the fixture,
and certainly, what does the lighting industry know about an acceptable level
of brightness for different types of residential fixtures? And there doesn't seem
to be any reason to recognize the directional nature of LED lighting, or that
it is inherently different from any of the predecessor illumination sources. They
are probably great people over there at the EPA, but somebody has made some very
bad decisions.
Given that IESNA has just completed LM-79 “IESNA Approved
Method for the Electrical and Photometric Measurements of Solid-State Lighting
Products” and that the Department of Energy (DOE, you know, the ones actually
charged with responsibility for generating and implementing energy policy and
regulation in the USA) has taken their legislatively mandated SSL responsibilities
and developed and honed the qualification testing procedures over the last several
years with 5 rounds of the CALiPER testing, it seems perfectly reasonable for
the EPA to simply assign their own way of testing these. At least they did notice
that the Illumination Engineering Society (note key words, all of which imply,
what's that word... oh, "expertise" maybe) was working on something.
A footnote on page 35 of the document reads, "IESNA LM-79... may in the future
incorporate LED light engine test procedures; as such EPA may reference LM-79
in future revisions of this specification." Those pesky illumination engineers,
they left out the part about LED light engines when describing how to characterize
a luminaire. Why would they do that? Maybe because it's useless to characterize
"the LED bulb" and then use it to describe the characteristics of the
finished system. My computer has a 1.4 GHz Pentium, isn't that specific enough
to know whether it will work as the fly-by-wire system on an airliner? Oh, well
it only has 64K of RAM, a floppy disk, a weak power supply and no operating system,
but what difference would the system performance make in that application while
I fly over your town?
So here are the interesting questions: With the DOE-
and SSL-community driven Energy Star criteria completed back on Sept. 12, 2007,
and set with an effectivity date of Sept. 30, 2008, why would EPA make this pre-emptive
move now? Why would they do it in secret without any public comment or constituent
input? Why wouldn't they even reveal to anyone they were working on this, much
less work in coordination with either the broader industry or the DOE (who received
the mandate to oversee the SSL program back in 2005, under Section 912 of the
2005 Energy Independence and Security Act)? Why would they make this "technical
revision" of "immediate effect"? Are they just enthusiastic (albeit
a bit naive)? I wanted to ask those questions of the EPA program manager, but
my two messages yesterday and the day before using the words "I'm under a
tight deadline" have remained unanswered so far. In fairness, he may simply
be on vacation or out of touch for a few days, and if we get those answers later,
we'll let everyone know. Meanwhile, we get to form our own opinion, as you should
also form your own.
Our Theory: The EPA has no significant reason to be
involved with the Energy Star program at all, they know it, they lost any mandate
for involvement with SSL and this is a desperate "land grab" to try
and retain a stake in something they have no business in. Frankly, justifying
EPA co-control of Energy Star on the basis that lower energy consumption reduces
energy-production related pollution is analogous to the Treasury Department claiming
a stake in Energy Star because an emphasis on energy efficient products can have
an effect on the distribution of tax revenues in various manufacturing sectors.
Their claim to co-control is more historical, since the EPA generated the Energy
Star moniker in the mid-1990s to apply to computers that had a sleep mode capability.
The DOE had created an "Energy Saver" label with a full range of products,
but clearly someone in the EPA had some pull at the time and while the DOE and
EPA programs were merged, the Energy Star label won out and the EPA kept its stake
(read "money") in the energy efficiency programs. Once again, we prove
that when something is given to, or taken by, a government agency, they are generally
loathe to give it up later on.
Our suggestions: A) If you are a luminaire
manufacturer, ignore the technical addendum to the RLF Energy Star spec; B) If
you are a specifier, don't depend on our opinion. Contact the EPA yourself and
have them explain to you how the technical addendum to section 4.2 of the RLF
will assure you of high quality luminaires that meet customer expectations, and
how it will aid adoption of SSL technology rather than harm it (US tax dollars
are paying their salaries, so they work for you... they are civil servantsnot civil supervisors); C) If the audience at large becomes aware
of an LED-based luminaire or fixture provider that applies the Energy Star mark
based on qualification under RLF Version 4.2, forward them to us here at Solid
State Lighting Design and we'll post a list of those manufacturers on a special
page dedicated to, "Products that may have been qualified to a less rigid
Energy Star specification that could compromise the consumer perception of, and
satisfaction with the LED-based lighting product that results... We recommend
that you contact the manufacturer for luminaire-level test result data before
making any purchase decision regarding this product. D) Pass the "permalink"
to this editorial along to anyone and everyone that you think
might have an stake in the success of solid state lighting (for permalink, right click here and choose 'copy shortcut' or 'copy link location' and then paste into any document or email). Let's get some
buzz going before this nonsense gets out of hand and inferior products hurt us
all.
If you have questions about
the solid state lighting and compound semiconductor industries or
have
news or views to share, we want to hear from you! Feel free to contact
us anytime. The main office line is +1
(512) 257-9888
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