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June 25, 2010...How do you describe an LED "lightbulb", of any style or type, that delivers the equivalent light output "on the target" as would a 60-, 75- or 100-watt incandescent lamp for the use that it is intended, but which doesn't put out the total lumens or the distribution that those "old bulbs" do? If you want it to be part of the Energy Star program, you pretty much have to simply steer clear of the topic. It's leading me to believe that the current Energy Star program, as it applies to omnidirectional replacement lamps, is going to flop. Some might argue, I think incorrectly, that in 2 or 3 years, it will be a moot point anyway, since it won't really be a tough technical challenge to put out the equivalent number of lumens, in an equivalent package, in an equivalent distribution. While it may be true that it can be done, the better question is, "Should it be done?" I mean, the whole point of solid state lighting is that it can do the job of lighting our world better in a whole lot of ways, mainly by delivering the right light, only where it's needed, using less energy.

It's probably important to veer off and share some perspective for a few paragraphs. Make no mistake on what we're saying here. The intentions of the Energy Star program are good, and the US Department of Energy, with its congressional mandate to promote solid state lighting, has done a spectacular job overall of helping to support the industry in developing some very useful metrics and methodologies that will help lay the groundwork for more success sooner. And the DOE-crafted version of the Energy Star SSL specifications will be very useful to set a series of benchmarks that manufacturers will strive to meet and exceed to maximize their credibility. At the same time, I'm predicting that it won't take long to screw it all up if Energy Star is left fully in the hands of the EPA for very long. That won't necessarily be the fault of the individuals involved, but simply the natural result of the differing missions of the two agencies.

The DOE's related mission is fairly clear (from its website): The Department of Energy's overarching mission is to advance the national, economic, and energy security of the United States [and] to promote scientific and technological innovation in support of that mission. The Environmental Protection Agency, on the other hand, has a far different mission (also from its website): The mission of EPA is to protect human health and to safeguard the natural environment -- air, water and land -- upon which life depends. Anything about economic considerations? Anything about energy? Anything about technology? Not that those should necessarily be part of the agency's mission, as long as there are counterbalances built into the overall structure. Someone has to start with the simple idea of "let's make all the water clean and all the air pure". Picking up "some of the trash here and there" shouldn't be the goal. Go after all of it. From that starting point, the broad discussion needs to expand to balancing what we want to do, what we need to do, and what we can afford to do. Zero carbon emissions. Fine, whatever, but we kind of still need to produce and transport food and goods, and be fairly free to pursue that "life, liberty and pursuit of happiness". Runners expel far more CO2 than walkers do, so we should outlaw running? I think not. It's a balance and the EPA is charged with starting at the "stop" end of the scale. Again, nothing wrong with that, I just don't think it bodes well for Energy Star to depend on getting a balanced approach from an agency that doesn't have the balance as part of its most basic mission. "Energy Star" becomes a defacto "Environment Star" certification. "Emit less carbon and live in the dark... mission accomplished!"

So let's right turn back into the LED lighting realm, setting aside any predictions of colossal screw-ups to come and just considering the specs as they stand today. People don't typically want light in the air, we want it "on" things. Sometimes it's our books, or our workspace, or a counter, or sometimes it's our wall or ceiling in order to create that level of ambient light that makes us comfortable, or productive, or both. We get light from fixtures of different types (or most properly "luminaires", which are the sum of the structure that holds the light source, feeds it electricity, and the light source itself... but I've mostly given up the semantic fight and use fixture and luminaire synonymously to satisfy the search engines). We screw or plug bulbs (aka "lamps") into the variety of fixtures that we've created, and those fixtures have been built around the characteristics of the bulbs we've had access to. Some direct light fairly well, either by depending on the design of the bulb to shape the light internally (R's, PAR's and MR's) or by using the structure of the fixture to reflect light out from the non-directional source (the strategy that high efficiency fluorescent fixtures employ). The more directional, the more you pay for it, since it requires more engineering, better materials and more precise the manufacturing required. If "not wasting the lumens", and therefore the energy, is important to you, you'll pay extra for that, which commercial and industrial operators understand.

LEDs do that directionality thing quite naturally. You actually have the reverse challenge, which is that you have to pay more to make the light omnidirectional. That's the basis of the "LEDs are most competitive when you purpose-build complete luminaires to do specific jobs" argument, and it is absolutely true. And the vast-vast majority of tasks we want our lights to do are directional. Sometimes broadly so, but still aimed at some subset of "everywhere". The problem is, we have a whole bunch of fixtures in this world that have been designed to make the best of the omnidirectional nature of our existing sources. We're not tossing the majority of those sockets out. They're attached to fixtures that great-grandma owned, or that are attached to our ceiling, so we're keeping them. So should we try to fill those billions of existing sockets with something that simply mimics the older, less efficient solutions, or with something that does the job better? Obviously, we want to do the job better, and are really only limited by certain practicalities of dealing with a manageable number of product models, and clearly communicating to the customer what it's suited for. Of course, more informed/educated customers are easier to communicate that to. "Zonal lumens" make sense to lighting professionals, but not to the average consumer.

So that's where the whole equivalence thing comes in. We've got a collective chore ahead of us to simply get the concept shifted from watts, in incandescent parlance, to lumens (with a big raspberry to the CFL producers, who did pretty much nothing to help that cause over the last few decades...). The need to describe things LED lighting, for a while, in terms of equivalence will be important to aid consumer adoption. Thanks again go to the DOE for kicking off the Lighting Facts label, which has created a model that the FTC is adopting as part of new lightbulb labeling guidelines that have just been announced, which are aimed squarely at that transition.

Unfortunately, Energy Star for integral replacement lamps requires a product to pretty much "mimic" the zonal lumen performance of the lamp it's claiming to replace. Fine for the more omnidirectional reflectors, but a real, and I would submit, somewhat pointless challenge for the A19 style of "Edison" lightbulb. I believe it will take something like minutes for commercial operators to realize that they don't want screw-in lamps that replace the badly arranged lumens of the old technology. If it's going in a recessed can, they want the light down, with enough sideways so the source inside is pretty much invisible. Instead of 10 watts to distribute the light "everywhere" a hotel would prefer to invest 4 watts in a bedside lamp to shoot a little light up for ambiance, a little sideways and the rest towards the bed where the occupant is reading. Light where it belongs, so you need less lumens to do the job. It's the successful premise of dedicated LED fixtures, and the buyers will figure that out pretty quickly at the commercial level, and eventually for our homes.

That's where the current Energy Star requirement for omnidirectional replacements gets in the way now, and based on EPA's handling of the Residential Light Fixtures spec (with its "who cares that most of the light is lost in the fixture, as long as the wasted light is created efficiently" approach), I expect it to be more useless in the future. If you want to have products in Energy Star, their equivalency claims are severely limited, throwing the more informed commercial operators under the bus in the interest of not disappointing our consumers (apparently consumers are a little behind in class, so rather than give them extra tutoring, we've just going to bring everyone down to their level). Meanwhile, SSL market growth is going to come soonest, and most importantly, from that more informed commercial/industrial operator who knows they want lumens where the want them, not replacement lamps, which will force many LED "lightbulb" producers to opt-out of Energy Star, simply so they can address the commercial market in the simplest way, by presenting common sense equivalency claims such as "performs equivalent to a 60 watt A19 incandescent in downlight applications". As long as those are made with integrity, and not with an intent to deceive based on some technicality, it's going to be a good approach. It will also be self-policing, as word of the less integrity-based claims will get out and those companies will lose future business.

Fortunately, the FTC has declined to tackle the watt-equivalency claims, for some good reasons, although not for the reasons outlined here. You can jump straight to page 21-22 to see the discussion on that topic in the FTC's full write up of the labeling initiative at http://www.ftc.gov/os/2010/06/P084206lamplabeling.pdf. So what's the impact of companies opting out of Energy Star? As long as the utilities and energy efficiency organizations continue their common sense approaches that have not made Energy Star the sole criteria to qualify for energy saving incentives, it's really not that much. While Energy Star brand awareness is high, the actual penetration of Energy Star in lighting is pretty low. Based on the current good specs (the DOE-driven ones outside of the A19 type), that will likely grow well until energy efficiency organizations see that EPA attempts to merge the specs will likely water them down to the point of uselessness in the future. And for the omnidirectional ones... I'll predict that any company with eyes on the commercial market will steer clear so they can market their product most effectively.

Tying together the big picture of LED lighting is what the 2010-2011 SSL Summit series is all about. Replacement lamp and retrofit market opportunities will be in the highlighted in both New York, September 14-15, as well as next January in LA. Speakers, sponsors and showcase participants are vetted to assure their "truth in advertising" as well as "specs match the tests" criteria, so you know you won't be wasting your high-level networking time with pretenders. A quality event for quality participants -- www.SSLsummit.com

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