What are your thoughts on the EPA’s Residential Light Fixture “Technical Amendment,” and their attempts to remove a “competitive disadvantage” for legacy technologies?
Peter Resca, Astrodyne, www.astrodyne.com
There are two substantial issues regarding the EPA’s approach to Residential Lighting Fixtures (RLF) and recent “technical amendment”. The primary issue is that there is confusion in the marketplace regarding Energy Star qualification for solid state lighting (SSL). The Department of Energy (DOE) has recently issued its own criteria for Solid State Lighting Luminaires. One of the elements in crafting the criteria was to examine the failure of compact fluorescent lights (CFL’s) to penetrate the market despite certain advantages. The examination of the failure pointed to confusion in the marketplace and lack of common standards. The EPA RLF document threatens to repeat this past mistake.
A secondary concern is the lack of initiative to raise the technology bar. Solid state lighting is an emerging technology with much promise including reduced energy consumption. It is the goal of the Energy Star Program to help drive technology through market desire and acceptance. The recent amendment from the EPA defeats this goal by allowing older technologies to carry the same Energy Star recognition.
Without getting into my thoughts on the turf wars currently being fought between the EPA and DOE, there is a positive outcome that will result from this amendment. In particular, "Table 2B: Outdoor Fixtures: Compliance Through Reduced Operating Time," which states in a nutshell: The fixture must contain an integrated motion sensor that employs infrared sensing technology.
I have heard some criticisms that this is just a crutch to keep an old, inefficient technology alive. Perhaps. However, this is too technically-focused a criticism and misses many of the real world benefits of this amendment. My focus has always been night sky preservation; as such, I'd rather see an inefficient light that is only on 1% or 2% of the night as compared to a more efficient light that is one from dusk to dawn.
Light pollution is a global problem with a wide range of associated problems. Energy consumption is just one piece of the puzzle. Sleep disruption, wildlife habitat destruction, and loss of the night sky are a few others. By requiring that energy star certified exterior lights have motion sensors, we are basically ensuring that these lights will only be turned on when necessary. This will result in less light shining into neighboring windows, less light shining up into the night sky, and less light polluting our nights. These are all significant benefits to our society provided by this "crutch" to an older technology. Sure, many of these same light fixtures could use motion sensors along with compact fluorescent bulbs and achieve greater savings. However, as motion sensors are not required for CF-based fixtures, most will not employ them. As such, they'll be turned on for many more hours each night. They'll be consuming energy at a lesser pace, but impacting the environment in many other negative ways.
The EPA was established to protect the environment and, ultimately, the consumer. In its recent response justifying issuing the RLF technical amendment, the EPA claims to answer many requests from “stakeholders” (lighting manufacturers).
The Energy Star Rating designation applies to appliances and products that exceed federal energy efficiency standards. This label helps consumers identify products that will save energy and money. However, the RLF amendment would add products that would share one common characteristic: “their design is not driven by performance goals as found in commercial and industrial fixtures, but by aesthetic value”. Energy Star, as the name implies, deals with energy consumption, and aesthetic value should have no place in the program.
Energy Star is a strong brand. Accepting products that do not meet the standards will undermine the program and de-value the brand. Stakeholders that want to include their products in Energy Star must be subjected to testing. The testing fees should be reasonable and amortized in the product cost. In turn, these products would get a premium in the price, and this could differentiate the higher quality products from the cheaper knockoffs.
The EPA and DOE are spending US tax dollars to protect consumers and the nation by improving energy efficiencies. These agencies need to collaborate and deliver one message and one standard, with input from the market and the stakeholders. This will ensure that the reputation of the government is preserved, and is working “for the people”.