This week's big story in the LED world is the announcement that the U.S. Environmental Protection Agency (EPA) has issued a new set of Energy Star requirements for LED-based residential lighting fixtures. However, EPA's criteria overlap with and contradict Energy Star for Solid State Lighting documentation already published, after industry-wide consulation, by the Department of Energy (DOE).
Read the full story on the LEDs Magazine website, then let us know what you think.
- Should the EPA have issued the RLF 4.2 document?
- Should they have made greater efforts to coordinate with DOE?
- Does this help or hinder the development of the solid-state lighting industry?
18 comments:
Right now there's a couple of things I want to know:
If the EPA were responding to manufacturer's requests who were these companies, and what SSL product are they pimping?
The companies are the ASSIST companies.
http://www.lrc.rpi.edu/programs/solidstate/assist/index.asp
ASSIST at the LRC is the little man behind the curtain pulling the strings. You have to look no further than the multiple references the EPA E* program manager made to ASSIST in defending their pathetic requirements.
These are large conglomerates some of which produce tens of thousands of new fixtures a year. These companies are publicly traded. While they are concerned about the future, the real importance is the next quarter cycle. Many also balance LED sources with other technologies in their portfolio. There are multiple agendas and layers that make this not just a bad decision but a conspiracy in as much as the EPA is ready to take a hit, further erode the energy star brand (for all consumer products--not just lighting) to satisfy the wishes of a few company executives.
You have to look no further than the level of experience of the EPA team vs the DOE team to decide who is doing the right thing and who is a tool of larger forces.
My primary concern with the DOE SSL version is only in one area "Outdoor Path Lights". If this is meant to refer to the garden low voltage path lights typically sold, these are typically 11 watt lamps with a shell.
Net lumens for these fixtures is typically 30-50 lumens MAX. However, the DOE standard is requiring 100 lumens net, double or even more than what the market staple products yield. This is the one noticeable section where the EPA version makes more sense in that the fixture is not required to be BRIGHTER than conventional fixtures of its type, only more efficient.
Oh... and by the way... Alex Baker is an LRC graduate now running EPA lighting. Follow the money! This whole thing is absolutely disgusting and people should be fired.
that may be true but why must the DOE standard require replacement technology to actual outproduce incumbent by a factor of 100% or more in total output?
Seems to me that you simply want to reduce energy consumption.
This should include "decorative" lighting as well.
anonymous said:
"you simply want to reduce energy consumption".
Um, no. ENERGY STAR is not an energy conservation brand, it is an energy efficiency brand. The point of the brand is to provide the same performance with less energy.
EPA's spec doesn't require same performance, it allows any shoddy, slip-shod LED product to qualify. Therein lies the problem.
PS
Is that you Ed?
I am not a proponent of the EPA version....as a matter of fact, I prefer the DOE version with exception to the Outdoor Path Lighting.
Virtually ALL path lights sold at retail do not meet the 100 lumen net requirement. I simply feel it is silly to require SSL units to do so if the bulk of the others do not.
I believe improved efficiency is what most of us are targeting, but in decorative lighting, there is no legitimate reasoning to require MORE light than incumbents. The market should be able to have decorative (limited function) accent lighting that still meets Energy Star criteria. Keep in mind this isnt egress lighting, this is PATH lighting, which in retail is almost exclusively decorative in a residential application. That is my only point.
I have been in lighting product development, specializing in energy efficiency for nearly 20 yrs. I understand the goals, I am simply questioning one section. Outside of that, I have no issues with the DOE as it is much more specific and "testable".
That is an interesting point in the DOE version. They insist on absolute photometry and system efficiency for LED fixtures, while other technologies are free to sling their relative photometry propaganda.
Between the bloggers though: how hard is it to crank out 100 lumens? What is the average that you are referring to for these retail fixtures? Do you have any data to back up the claim that almost all don't do 100 lumens? If you are correct, then you have a legitimate beef.
From what I have seen from Caliper, however, there are benchmark tests done on all fixture types for different technologies. They are not just pulling numbers out of mid air. There is much in the DOE version that is annoying, ill conceived, even pandering to big business (CRI exemptions for color tuning white light sources--Merry XMas Philips).
Like everything, there is a give and take though and there is so much more good in the DOE version than bad. We have always been told never to say that one technology can do it all. LEDs do, however, have the potential to radically change general lighting if given the chance. Who is going to lead us though in Energy Star is what this blog really is about--not bitching about the details. If it is the EPA, we can go right down the same path as the CFL. If it is the DOE, we will take some hard knocks at first. Some things might not even be fair. The end result, however, is a technology the public arrives at that is well vetted. The program requirements are robust and defensible. Finally there will be cutsheets that you can trust, a technology you can trust,an industry no longer shamed by systemic over reporting. As in any business, there should be transparency. While that might not be realistic, it certainly isn't the government's job to help big business create a smoke screen. Energy Star was developed to protect the consumer. The brand is supposed to mean something. People are busier than ever. They live in a world that is much more technical and complex. They don't have time to learn about semiconductors and LEDs and all the esoteric nooks and crannies of our craft. Energy Star is there to make that easy. The thought process should be: I can trust that. It will work. It means quality (through testing) and efficiency. While the DOE version represents this ethic, the EPA puts trust and quality in the balance, which just means a bunch of wasted money and effort. And for what: some bureaucratic tug of war?
I'm not going to comment on the politics or who's right or wrong as I was involved in the development of the DOE criteria and so I'm biased. :-)
I will however answer any questions you may have. In particular there were several commments about pathway lights. First of all recognize that DOE's spec. is both residential and commercial. With that said pathway lighting also includes commercial bollards. Also when we looked at establishing minimum light output we benchmarked to the incumbent technology as much as possible. (By the way it is entirely possible to have high efficacy and very little light hence why we specified minimum light levels!) With landscape lights there simply wasn't any photometry available and products we had seen had up to 20W incandescent lamps so at the time 100 lumens seemed reasonable. Also the current LED-based products in the market are little more than runway markers rather than providing useful illuminance for a path. We will revist this in the future based on your comments.
As for CRI... DOE remains silent only on outdoor, non critical applciations. What's the CRI of HPS ~ 0! CRI is flawed metric to begin with and is only exacerbated by LEDs. NIST is currenly working on a new metric but we felt we had to keep the existing metric until the industry comes up with a better one.
The CRI as false metric argument doesn't work as a rationale for tunable white light sources.
White light is white light no matter how it is arrived at, no matter what source is used. 3200K is the same for CMH as a phosphor converted die as a 3200 preset dial on a tunable RGB source. They need to be measured against one another. No matter how false the metric, there needs to be a bench mark.
Young companies trying to compete, trying to create viable LED fixtures, balance output, CRI, power factor--among other things. Energy Star has forced them into the position to consider licensing to Philips to avoid the CRI hit and concentrate on other features in development. The false metric argument doesn't answers this uncomfortable proposition. That is one of the only problems I have with the Energy Star requirements: the disconnect between decisions arrived at in round table discussions and real world business. Until you can systemically come out and get behind the NIST metric, CRI is here. By giving Philips a pass, you are helping no one but Philips.
anonymous wrote:
I have been in lighting product development, specializing in energy efficiency for nearly 20 yrs. I understand the goals, I am simply questioning one section. Outside of that, I have no issues with the DOE as it is much more specific and "testable".
if this is the case, your initial post makes less sense b/c EPA's path to address this one section severely undercuts the ENTIRE Energy Star program by essentially qualifying anything.
I should have been more specific in my original post in that I was specifically referring to one particular case in which "decorative lighting" doesnt require minimum photometric performance whereas functional and task lighting does.
IMHO the DOE version should have a section for decorative or residential, non-task oriented lighting in which the minimum flux may be only 10-20 lumens or so.
I figured there were no benchmarks to go from for the DOE's version and I also realize that this applies to both residential and commerical. But just as power factor has dual ratings of 70+ for resi and 90+ for comm, it seems a few of these categories could have that as well.
Just a thought.
As a veteran lighting product designer, the primary issue is that the items in this particular case, we are attempting to replace 7-11 watt incandescant fixtures, that have essentially no optics and are typically only 40-50% efficient, with higher efficiency products. We are talking about the kind of lights you buy at Home Depot, Lowes, Target etc.
The minimum lumen requirements, in THIS PARTICULAR CASE, make it not only difficult from a cost perspective, but also probably overkill. As stated above by KaptianKW, some of these are "runway lights" or just decorative, so while a minimum light level is useful, it should be quite low.
In retrospect, can you imagine the the wasted energy (even with better sources) and light pollution if American household has 16 pathlights emitting 100-150 lumens each? Thats 1600-2400 lumens of additional light in each yard.
Frankly, thats more light than I would want in my yard.
There is a bigger picture here....its not only about efficiency, it IS about how much light is truly needed. There are hybrid lighting studies, and dark room studies etc....the standard to encompass more than task lighting. That is all I am saying. Consumers not only want Energy Star on their AC units and Refrigerators, but they would also like them on coffee makers, Televisions, and Toasters.
[i]There is a bigger picture here....its not only about efficiency, it IS about how much light is truly needed.[\i]
sorry, to me efficiency trumps "how much light is truly needed".
I won't debate you on the merits of the outdoor lighting spec, but EPA's response to this "problem" is overkill. It calls into question the entire efficacy of the ENERGY STAR program which is of far more value than decorative lighting.
This goes beyond throwing the baby out with the bathwater and for that reason I think the personal motives of some at EPA need to be examined. Alex is the visible one, but he seems to be getting scapegoated here.
Who does Alex work for?
Throwing the baby out with the bath water indeed. How did this discussion get drug into a parsing of path lighting? There are larger issues/questions here?
The EPA spec is garbage. It is crude. It is heavy handed. It obviously will hurt the technology in the long run. The question is why? Perhaps the DOE wonk who chimed in earlier would care to speak to some of the dynamics at play here. Is the EPA the ugly stepchild to the DOE and just trying to take a stand? Is there a history that explains this move? Are larger forces--ASSIST--really in charge of this?
Let's be done with pathway and try to talk about how this happened please.
Tell me: which LED mfr can meet DOE's version of CCT requirements? I think DOE created a standard nobody can meet, at least in the foreseeable future. By the same token, the EPA version is too loose! I think some coordination between the two is needed!
The manufacturer that can meet the DOE CCT requirements is the exception to the rule. That being said, they said it was going to be amended periodically. Better to start out strict however than lenient. Once the genie is out of the bottle, you can't put her back.
A number of utility partners have sent letters to EPA telling them that they won't promote EPA qualified LED's.
The Consortium for Energy Efficiency is rumored to be staking out a position that asks EPA to rescind its position.
It looks like the marketplace is rejecting EPA's poorly thought-out attempt at an LED coup.
Post a Comment