somebody has made some very bad decisions

EPA seeks to ensure that qualified fixtures meet consumer expectations for light output. Consumer preference for light output varies widely, and the same is true for fixture design intent. Therefore it is impractical to prescribe lumen values for various residential lighting fixture applications. This consumer awareness requirement is intended to help consumers understand the limitations of LED light engines producing less than 800 lumens (equivalent to 60 watts incandescent)." No reason to accept the lighting industry and market consensus that consumers may actually have an interest in the amount of led high bay light that actually comes out of the fixture, and certainly, what does the lighting industry know about an acceptable level of brightness for different types of residential fixtures? And there doesn't seem to be any reason to recognize the directional nature of LED lighting, or that it is inherently different from any of the predecessor illumination sources. They are probably great people over there at the EPA, but somebody has made some very bad decisions.

The EPA has no significant reason to be involved with the Energy Star program at all, they know it, they lost any mandate for involvement with SSL and this is a desperate "land grab" to try and retain a stake in something they have no business in. Frankly, justifying EPA co-control of Energy Star on the basis that lower energy consumption reduces energy-production related pollution is analogous to the Treasury Department claiming a stake in Energy Star because an emphasis on energy efficient products can have an effect on the distribution of tax revenues in various manufacturing sectors. Their claim to co-control is more historical, since the EPA generated the Energy Star moniker in the mid-1990s to apply to computers that had a sleep mode capability. The DOE had created an "Energy Saver" label with a full range of products, but clearly someone in the EPA had some pull at the time and while the DOE and EPA programs were merged, the Energy Star label won out and the EPA kept its stake in the energy efficiency programs. Once again, we prove that when something is given to, or taken by, a government agency, they are generally loathe to give it up later on.

If you are a luminaire manufacturer, ignore the technical addendum to the RLF Energy Star spec; If you are a specifier, don't depend on our opinion. Contact the EPA yourself and have them explain to you how the technical addendum to section 4.2 of the RLF will assure you of high quality luminaires that meet customer expectations, and how it will aid adoption of SSL technology rather than harm it.If the audience at large becomes aware of an LED-based luminaire or fixture provider that applies the Energy Star mark based on qualification under RLF Version 4.2, forward them to us here at Solid State Lighting Design and we'll post a list of those manufacturers on a special page dedicated to, "Products that may have been qualified to a less rigid led flood light specification that could compromise the consumer perception of, and satisfaction with the LED-based lighting product that results... We recommend that you contact the manufacturer for luminaire-level test result data before making any purchase decision regarding this product. Pass the "permalink" to this editorial along to anyone and everyone that you think might have an stake in the success of solid state lighting. Let's get some buzz going before this nonsense gets out of hand and inferior products hurt us all.