Solid State Lighting Net

Postings: from the
desk of Jim Brodrick

I received a phone call last week from a colleague in the lighting industry. He said he was surprised to read that a decision had been made to divide the ENERGY STAR SSL Program between the U.S. Department of Energy (DOE) and the U.S. Environmental Protection Agency (EPA). DOE would be responsible for commercial products and EPA for residential products. This being total news to me, I asked him to forward the article. To my surprise, the article written by an EPA staffer does imply that the DOE criteria are not suited for the residential market. While I understand EPA's need to make a public case for its own criteria, I'm disappointed that the article skirted around some basic facts in an attempt to sway readers.

First, to my colleague that brought the article to my attention, there has been no decision to divide the two programs into commercial and residential components. This article is an apparent attempt to alter the thinking of those in the lighting industry despite the overwhelming support that the DOE ENERGY STAR criteria have received from industry and other stakeholders. The writer indicates that "larger programmatic issues" will be worked out in the near future. This is also news to me.

Several points in the article require discussion.

"The simplicity of using these off-the-shelf components to earn the Energy Star is what has kept residential fixture manufacturers engaged with the program for the past eleven years..."

The basic problem with the EPA criteria is that it treats solid-state lighting as "just another light bulb." It is the industry's consensus that LED lighting cannot be assessed in the same manner as traditional technologies. Contrary to the statement above, there is no simplicity in using off-the-shelf components in traditional fixtures. Unlike traditional lighting, SSL products, whether they are luminaires or replacement lamps, are a combination of several components, including an array of light-emitting diodes (LEDs), an electronic driver that modulates power input and a heat sink that helps dissipate heat from the light source. Lighting quality is also a product of the optical properties that are part of the overall product engineering. This is a matter of fact; not supposition.

IESNA LM-79 was developed by the industry for this very reason. To properly employ LED components in lighting fixtures, whether traditional fixtures or new designs specifically for SSLs, all the components have to be correctly engineered and integrated into the housing to ensure the desired quality. Simply marrying an LED array to a fixture originally designed for another lighting technology does not produce the type of product that consumers have come to associate with the ENERGY STAR label. Six rounds of CALiPER testing have proven beyond a shadow of the doubt that quality lighting is a product of high performing LED arrays coupled with the careful engineering of the optics, driver, and heat sink. An abundance of traditional lighting manufacturers are recognizing this to be true and are spending more time resolving overall product design issues rather than treating LEDs as any other light source. This phenom enon is not just true for the commercial market.

"For residential fixtures, data resulting from these tests is of dubious value..."

The residential market should not be considered any differently from the commercial when it comes to quality. If one agrees with the premise that LEDs are not interchangeable with other light sources, as most of the industry does, then testing to a procedure that encompasses the entire luminaire or replacement lamp should not be at issue. While the ASSIST test procedure may have its merits, it only tests the source and not the entire package. Why should residential lighting buyers receive less assurance as to the attributes and the quality of the product they are purchasing?

"...the residential segment of the market has never conducted full fixture photometry; this type of testing is inappropriate and overly burdensome for decorative residential fixture manufacturers..."

I don't think it is accurate to say that the residential market has never conducted full fixture photometry. The more accurate statement would be that the industry has never been subjected to such testing. In fact, IESNA has a luminaire efficacy test procedure for hard-wired compact fluorescent fixtures on it books; however, it is rarely used. In my October 7th Posting, I presented results from the recent CALiPER testing of sixteen hard-wired CFL fixtures, fourteen of which qualified for the EPA ENERGY STAR label. You may remember that we found that a comparison of source and luminaire efficacy indicated quite a difference. Of the 14 ENERGY STAR-qualified compact fluorescent and linear residential light fixtures tested, the actual lumen output of the fixture was anywhere from 23-67 percent lower than the manufacturer's published figures for lamp output.

"The (EPA) RLF V4.2 specification is equally as stringent as the (DOE) SSL V1.0 specification..."

I am not in agreement that the EPA RLF V4.2 criteria are as stringent as the DOE SSL V1.0. I think the CALiPER testing bears that out. One has to remember that ENERGY STAR is not about the number of products that qualify; it is about the quality of those products and a means of differentiating between the top tier of energy efficient products and those that do not meet strict criteria. ENERGY STAR is not and should not be about being all-inclusive; it is about reducing energy demand. Lighting buyers are seeking consistency and the existence of two ENERGY STAR criteria, which are conflicting from a technical standpoint, serves no purpose.

"The ASSIST Recommends test procedure referenced in RLF V4.2 was developed by LED manufacturers, and is currently under review for IESNA standardization, similar to the development of LM-79 or LM-80. EPA, working with the Lighting Research Center (LRC), has trained several labs to perform the testing procedure; a list of labs is available upon request."

Finally, I must say something about the ASSIST Recommends test procedure. I'm sure the Lighting Research Center at Rensselaer Polytechnic Institute does fine work. However, to imply that the ASSIST test procedure has the backing of the lighting industry is very misleading. If it had the backing of industry it would be an IESNA product, not something that was created without broad input. To my knowledge, it was announced without any public vetting. Why has it been kept such a secret? Where is the list of LED manufacturers that were responsible for its development? Which laboratories have been trained and certified to use the procedure? Solid-state lighting technology is potentially a huge step forward not only for the lighting industry but for the nation as a whole.

Transparency is needed, not sleight of hand.

As always, if you have questions or comments, you can reach me at postings@lighting-facts.com