Soraa filed comments on the EPA's recent Energy Star draft. The LED developer reiterating the need for an upper tier in the standard to address higher-quality light sources.
As we discussed last week, the US Environmental Protection Agency has issued the fourth draft (out of a planned set of five) of its specifications for Energy Star certification for LED lamps (i.e., light bulbs).
Soraa, representing a coalition of interests, including the International Association of Lighting Designers, had filed a comment on the third draft. These interested parties called for a two-tier regime in which LED lamps with a color rendering index (CRI) above 90 would be considered separately and would get a break on the luminous efficacy required to qualify for Energy Star certification. Efficacy inevitably trades off against color fidelity. Soraa and its allies argued that a higher-quality tier would expand the universe of products available to consumers.
In releasing draft 4, the EPA showed it did not buy these arguments. No second tier was offered. This decision may have been influenced by what we can term a tactical error by Soraa and its partners. They asked that the proposed efficacy standards apply to devices offering a CRI between 80 and 90, while standards for those with a CRI above 90 would be eased by 5 to 10 lumen per Watt.
It's no use suggesting to the EPA that it lower an energy efficiency requirement. Its job is to maximize such numbers.
In the comments filed after the fourth draft, Soraa corrected the earlier miscue by reworking the proposed efficacies for LED lamps of moderate and high light quality. In the new proposal, lamps with a CRI higher than 90 would be assigned the EPA's current efficacy numbers, while the standards for those with a CRI of 80-90 would be 5-10lm/W higher.
Color quality matters
This time, the company bolstered its argument that light quality is an important factor in lighting choices by reproducing a table from a 2011 McKinsey study. The table shows that, when a survey asked for the most important criterion in new fixture installations, light quality was the most popular choice for respondents in five of the seven categories, including commercial and architectural. Light quality tied for first among respondents in a sixth category (outdoor) and came in second among respondents in the final category (residential).
And Soraa hit hard on the EPA's fear of repeating the mistakes of the era of compact fluorescents. The company displayed the figure below to show that essentially all the products on the Energy Star Qualified Lamps Product List under the current standard, whether LED or CFL, cluster at the low end of the CRI scale. The argument is that, if all you ask for is a CRI of 80, then the market will not deliver a CRI much higher than that. Consumers rejected the poor quality of CFL light in droves.
On page 3 of the fourth draft of its proposed specification, the EPA lists color quality as a possible area of consideration for future revisions. What chances do you give Soraa and its allies of prevailing in the fifth and final draft, due out in the summer?
— Keith Dawson , Editor-in-Chief, All LED Lighting