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November 13, 2008...So the EPA's battle to separate the consumer and commercial Energy Star LED lighting specifications continue, and paraphrasing one insightful industry participant, "With the top EPA and DOE agency folks likely packing bags and looking for jobs, don't expect it to get resolved until next year." We recently spotted some commentary that gave a good overview of the US Environmental Protection Agency's position on why it was correct to have one Energy Star criteria set for the residential market (known as "the technical amendment to version 4.2 of the Residential Lighting Fixture specification, or 'RLF v4.2') and another for the commercial/industrial markets, which is the US Department of Energy's SSL 1.0 (DOE SSL has recently been expanded to residential fixtures, as planned and announced in advance). I don't think the commentary came down in favor of splitting the specs and believe the intention was to add some clarity to the EPA's side of the story. Nonetheless, I'm concerned it might have been perceived as a endorsement of the approach "because the consumer market is different". At least the EPA answered them... I'm still waiting for my promised call back. On the heels of that article, the DOE responded in one of its regular newsletters by fairly effectively tearing the EPA's argument to technical shreds (we've reposted Jim Brodrick's note here). My objective here is to hopefully boil it down into even simpler terms which will hopefully result in a consumer and lighting-manufacturer uprising against the EPA's involvement with Energy Star. I acknowledge that this may further delay the EPA getting back to me, and appreciate everyone letting me know if you see a news that a toxic wasted containment zone has suddenly been declared surrounding a certain suburban home northwest of Austin. (Maybe DOE will come to my defense and subsequently buy it up for some kind of alternative energy research site). While there are a number of rational-sounding points in the EPA's defense of RLF 4.2, they all seem to built on two key assumptions, and if those assumptions are proven false, the rest of the points become irrelevant.

False assumption #1: Consumer lighting is mostly about aesthetics and preferences, so the overall light output doesn't really matter. An efficient source is the most you can reasonably ask for without harming the market for "decorative home lighting". Remember what we are talking about here... This is about manufacturers being able to apply an Energy Star label to their light fixture so that consumers who purchase them have an assurance that the fixture (luminaire really), will save them money through its energy savings, will be eligible for local rebate programs, and in the case of builders, will support the criteria for green building, include LEED or other certifications. All of that is the value of the Energy Star label. None of that is assured with the EPA's RLF 4.2 Energy Star label.

Here is an illustrating example that might make the point clear. Imagine three similar fixtures of any type (chandelier, table lamp, "Tiffany's style", whatever). One has an LED source in it, another a compact fluorescent bulb and the third has a basic 30-watt halogen, but they are designed differently. The halogen version incorporates materials that transmit light effectively, and has been thought through with regard to its geometries to let the light out, plus there are no ballast or driver losses. 30 watts in gets, say, 400 lumens out. The other two are "cheaply designed" without much thought to light transmission or output. You can see the light, the fixtures look pretty in the bright showroom, and they have the EPA's Energy Star label based on the efficiency of their bulbs. In reality, due to the poor optical design and materials, the CFL-equipped version uses 15 watts, but might only give you only 200 lumens out. It's source met the RLF 4.2 specification, but where's your savings? Now to make it worse, let's say the LED version has had its source (lamp, driver and control circuit) certified to the RLF 4.2 required 40 lumens/watt. It was designed with a driver spec'd to operate at nice high temperatures to help the lighting manufacturer eliminate any concerns about the driver's reliability in whatever fixture they happen to install the LED engine into. The fixture provides very little airflow, since the lighting manufacturer is "old school", and is used to heat being dissipated through the bulb (big surface area) and in the beam, neither of which work for LED light engines. Result: A hot "in-situ" environment which results in 30 lumens per watt from the LED engine. Now factor in the inefficient fixture design that in our example only lets out 40% of those lumens (since it wasn't really designed for the highly directional LED source, but tries to bounce the light around to get it out 360-degrees) and do the math. True, it only uses 15 watts, but add the source drop from 600 lumens to 450 lumens due to heat, and the 40% optical efficiency and we have a final output of less than 200 lumens. The halogen, that is categorically unable to get any Energy Star label for its inefficiency, powers the light fixture that produces the most lumens per watt.

Some of the largest US energy program providers such as California's Pacific Gas and Electric, have made it clear that fixtures "certified" to RLF 4.2 will not be eligible to participate in their rebate programs. It's not a stretch to see their ineligibility for LEED participation and California's Title 42 coming as soon as those entities figure out the flaws in the EPA approach. So in our example, the consumer takes it home and sends in the online generic rebate form like they did for their other Energy Star lights and then gets no check back because that fixture isn't one that's qualified under a useful Energy Star program. Shocking? Hopefully not, considering the totally non-public development of this "revision" that bypassed all the real stakeholders. EPA chalks it all up to "consumer preference". I call it "doing whatever it takes to stake some SSL-turf inside an agency that has no place being involved at all." (I'm pretty sure I'll never get that call back...)

False assumption #2: The source-based approach worked for compact fluorescent lighting, so it will work for LED-based lighting as well. This one is really simple. CFL and other fluorescent sources had already experienced the tragedy of missed consumer expectations, and made their corrections to provide a quality "light engine". CFL twist-style bulbs, for a specific example, are designed to go where an incandescent bulb already fit, so if the fixture manufacturer replaced the incandescent 360-degree light source with another of the same general lumen output, you do reap more fixture efficiency from the more efficient source. Fluorescents dissipate the vast majority of their heat on the bulb surface, so airflow and fixture cooling aren't really a big issue, and don't effect the light output. From the market-side, poor quality sources can't be hidden by the fixture. Fluorescents are designed with a replaceable bulb, so the bulb manufacturers are held accountable to the consumers by the variety of fixtures they find themselves in. Poor quality bulbs will be snubbed and eventually the manufacturer is weeded out.

Perhaps most importantly, the earlier versions of RLF do a disservice to the consumer because they never let them compare apples-to-apples for different fixtures, just for incandescent versus fluorescent sources in the same fixture. Consumers were never given access to the total light output from a fixture. Commercial operators demanded it because it really matters a lot to them. It matters less so to consumers, but that isn't an excuse to provide misleading information in an attempt to make them "feel good" about supposed energy savings. The RLF has been a tool for lighting manufacturers to fool the consumer into thinking they are getting "more light for their money" in order to falsely differentiate their product and increase their sales or profits. EPA went along with it because it helped with the incandescent to fluorescent transition, but once you break from that one instance, there is no value in the RLF for comparing one type of source to another. The continuation of a poor approach that was applied to a technology that was at a different state of its market development does not make sense. Clearly the EPA knows this or they would have put this through a public process in which this fundamental flaw would have been exposed.

Here's where we get to the "consumers aren't stupid" argument. Would it, just maybe, be possible to give the consumers a little credit for being able to factor in the quality and efficiency of the light? Right there on the label they could see that product X provides a total output of 350 lumens for its 10 watts, while product Y provides 300 lumens and uses 15 watts. Right there on the label, just like on the washer or refrigerator, it could say: At 15-cents per kilowatt hour, and a typical usage of 4 hours per night, this 350 lumen fixture will cost $2.19 to operate for a year. The label for fixture Y tells us it will cost $3.28 to run for the same year for its 300 lumens. (Yes, the math is correct...). The consumer thinks about it (rather than letting the government think about it for them) and decides that even with 50 less lumens, they like fixture Y better and aren't too worried about the extra $1.09. Is it just possible that the consumers can still exercise their preferences when presented with the whole truth instead of a series of false assumptions presented by a government bureaucracy that put its need to hold onto some regulatory turf above actually serving their constituency?

If the incoming US administration doesn't resolve this by forcing the EPA to rescind its nonsense spec, and the inspector general's continuing investigation into the complaint of EPA waste and lack of open process filed by the SSL Industry Trade Association doesn't find them wasteful and fraudulent enough, then I'd suggest it is up to the LED and lighting industries to look out for themselves. Sharp lighting manufacturers will choose the DOE version and be bold in their labeling. I would suggest something like: "Conforms to DOE SSL 1.0, which reports the actual light output from this luminaire and is eligible for all applicable rebate programs. Be aware that products certified under EPA RLF 4.2 do not report actual light output and are often not eligible for rebate programs." Be one of the sharp ones...
The perma-link to this article is www.solidstatelightingdesign.com/documents/view/news.php?id=11133#editorial. Always feel free to pass it on or post a link to it.

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