to specify different qualification criteria for specific lighting technologies, EPA has stated a goal of moving toward specification integration in which one set of technology-neutral specifications would apply to all lighting technologies. To that end, EPA has recently merged the SSL luminaire and non-SSL residential luminaire specifications into a single specification (EPA, 2011b) and has also proposed to merge the CFL and SSL lamp specifications. However, the lighting industry has expressed concern that recent EPA actions do not fully implement a technology-neutral approach. The current specification has different performance requirements for CFL and LED products with respect to many performance characteristics (life rating, color maintenance requirement, color angular uniformity requirements, lumen maintenance requirements, and power factor requirements, to mention a few) and does not appear to support the inclusion of any other technologies (such as halogen or metal halide), no matter how significant any improvements that were made in them, given that test measurement methods are typically only given for fluorescent and SSL technologies.
FINDING: A technology-neutral specification for lighting would “raise the bar” for energy efficiency without putting the government in the position of picking and choosing which technologies should be included in ENERGY STAR®.Rather, those technologies that meet the specified criteria (e.g., luminous efficacy, color temperature, color rendering) would qualify for ENERGY STAR® labeling.
RECOMMENDATION 2-5: The Environmental Protection Agency should develop technology-neutral specifications for lighting that are based on performance rather than the type of lamp to provide the most objective and even-handed standards for energy efficiency.
While ENERGY STAR® applies to more than 70 product categories, lighting is one of the few product categories in which the ENERGY STAR® qualification is dependent not only on energy efficiency, but also on lighting quality. The ENERGY STAR® lamp specification contains an extensive list of performance requirements (e.g., requirements relating to color consistency, color rendering, turn-on time, run-up time) unrelated to energy efficiency, which are intended to ensure that ENERGY STAR® lighting products have a high level of quality and are acceptable to consumers. EPA recently published a vision document in which it justifies the inclusion of non-energy related requirements in ENERGY STAR® specifications (EPA, 2012). For its part, industry has expressed concerns about the inclusion of non-energy related factors in the ENERGY STAR® lighting criteria, citing the potential for duplicative, inconsistent, or unnecessary requirements, given that other standards and regulations may include similar provisions.
The ENERGY STAR® labeling program for individual lighting products primarily applies to federal procurement and residential applications and generally not to commercial or industrial products. ENERGY STAR® applies to commercial and industrial facilities, but the standards are for overall building energy efficiency (which includes lighting) rather than efficiency of individual components such as lighting (other than those luminaires in commercial buildings subject to federal procurement). The ENERGY STAR® buildings program evolved in the 1990s out of the Green Lights Program to focus not only on technologies but also on the interaction of the various building systems. EPA awarded the first ENERGY STAR® to a building in 1999 (EPA, 2009).
Installation of more energy efficient lighting may help a commercial or industrial facility to meet the ENERGY STAR® criteria, but other energy sources must also be considered. The Design Lights Consortium, a collaboration of utility companies and regional energy efficiency organizations, is attempting to supplement the existing ENERGY STAR® approach by providing awareness of efficient lighting products for commercial buildings.6
Additionally, the Consortium for Energy Efficiency provides model incentive programs for utilities to adopt, and commercial lighting products are already included in its programs. Finally, the DOE Municipal SSL Street Light Consortium addresses the energy efficiency of street and roadway lighting and assists cities and municipalities in their energy efficiency needs. However, this program is primarily a listing of products without the certification and labeling requirements of ENERGY STAR® and is not as high-profile as ENERGY STAR®.
FINDING: The ENERGY STAR® program provides useful information to residential consumers on energy efficient lighting products. While the ENERGY STAR® program also has a commercial and industrial segment, that program focuses on overall building efficiency rather than the certification and labeling of individual products (with the exception of luminaires in commercial buildings subject to federal procurement). Many other government and industry organizations address lighting product standards for the commercial sector.
States have been active in promoting energy conservation and efficiency by adopting a variety of regulatory, policy, and incentive programs, many of which will directly or indirectly encourage more energy efficient lighting (DSIRE, 2011). In addition to these general provisions for energy efficiency, some states have adopted specific regulations for lighting. Although EPCA (75) generally preempts state energy efficiency regulations for lighting that is regulated by the federal government, EISA 2007 provides an exception for California and Nevada to adopt the EISA energy efficiency standards