1 | Building Technologies Programeere.energy.govTest Procedures for LightEmitting Diode Lamps Noticeof Proposed RulemakingLucy deButtsBUILDING TECHNOLOGIES PROGRAMDepartment of EnergyEnergy Efficiency & Renewable EnergyDocket Number: EERE-2011-BT-TP-0071LEDLamps-2011-TP-0071@ee.doe.govMay 3, 20122 | Building Technologies Programeere.energy.gov• Introductions (around the room)• Role of the Facilitator• Ground Rules- Listen as an ally- Focus on issues- Use short, succinct statements/keep to the point- Hold sidebar conversations outside the room- One person speaks at a time (raise hand to be recognized; state yourname for the record)- Set cell phones to silent/vibrate• Housekeeping Items• Agenda Review• Opening RemarksWelcome3 | Building Technologies Programeere.energy.gov9:00 – 9:15 amWelcome, Introductions, Opening Statements9:15 – 9:30 amRulemaking Process and Scope9:30 – 10:15 amTest Procedure for Input Power, Lumen Output,and Correlated Color Temperature (CCT)10:15 – 10:30 amBreak10:30 – 12:15 pmTest Procedure for Rated Lifetime12:15 – 12:30 pmQuestions and Closing RemarksAgenda4 | Building Technologies Programeere.energy.gov• The Department is broadcasting thismeeting live over the Internet.• DOE is providing the webcast to accommodate stakeholders thatare unable to attend the public meeting in person.• The web broadcast allows stakeholders to listen in and view theslides.• All stakeholders are encouraged to submit written comments afterthe public meeting.Listening Via the Webcast5 | Building Technologies Programeere.energy.gov• Present DOE’s proposed test procedures for light-emitting diode(LED) lamps.• Invite comment on the test procedure notice of proposed rulemaking(NOPR) document.• Discuss next steps in the rulemaking.• Invite participants to provide summary comments or statements andraise additional issues for discussion.Purpose of the Public Meeting6 | Building Technologies Programeere.energy.govIssue box numbering corresponds to the list of issues published at the endof the NOPR document, available at:http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/led_tp_nopr_frnotice.pdfThe deadline for submitting comments isJune 25, 2012.Issue Box:DOE welcomes comments, data, and informationconcerning its proposed test procedures for LED lamps. Issuesthat correspond to those raised in DOE’s published materialwill be numbered in accordance with that material. Whetherinvited by an issue box or not, comments are welcome on anypart of DOE’s analysis.Issues for Discussion7 | Building Technologies Programeere.energy.govOpening RemarksMeeting participants are invited to provide openingremarks or statements at this time.8 | Building Technologies Programeere.energy.gov3Test Procedure for Rated LifetimePublic Meeting Slides Topics1Rulemaking Process and Scope2Test Procedure for Input Power, Lumen Output, and CCT9 | Building Technologies Programeere.energy.govTest Procedure Rulemaking ProcessMilestone DateNotice of Proposed Rulemaking (NOPR) PublicationApril 9, 2012NOPR Public MeetingMay 3, 2012Comment Period EndsJune 25, 2012Final Rule Publication (projected)November 2012NOPRTodayFinalRule10 | Building Technologies Programeere.energy.gov• This rulemaking is applicable tointegrated LED lamps as defined byANSI/IESNA RP-16-2010.• Anintegrated LED lampis composed ofan LED source, such as LED packages orLED arrays, LED driver, ANSI standardbase, and other optical, thermal,mechanical, and electrical components.• AnLED sourceis the light producingcomponent within an LED lamp. It is theassembly of components or dies,including electrical connections, printedon a circuit board or substrate.Scope of ApplicabilityIntegrated LEDLampSource: PhilipsLED SourceSource: JournéeLEDSource: Cree11 | Building Technologies Programeere.energy.govIssue 1:DOE requests comment on both proposed scope and thedefinition of LED lamps.Issues for Discussion12 | Building Technologies Programeere.energy.gov3Test Procedure for Rated LifetimePublic Meeting Slides Topics1Rulemaking Process and Scope2Test Procedure for Input Power, Lumen Output, and CCT13 | Building Technologies Programeere.energy.gov• DOE proposes to adopt IES LM-79-2008, “Approved Method:Electrical and Photometric Measurements of Solid-State LightingProducts” with some modifications.– Industry accepted standard for determining input power, lumen output,and CCT.– Referenced by ENERGY STAR’s Integral LED Lamps specification.– Recommended by FTC for testing LED lamps.– Required for voluntary participation in DOE’s Lighting Facts® program.Proposed Test Procedure Overview14 | Building Technologies Programeere.energy.gov• The following test conditions, test setup, and test measurementrequirements are adopted without modification from IES LM-79-2008:– Air temperature and air movement– Power supply and voltage regulation– Lamp mounting– Electrical instrumentation and electrical settings– Lumen output measurement using an integrating sphere system orgoniophotometer system– Method of measuring CCTIES LM-79-2008 SummaryIssue 2:DOE requests comment on the proposed incorporation ofIES LM-79-2008 for determining lumen output, input power, andCCT.15 | Building Technologies Programeere.energy.gov• IES LM-79-2008 specifies that air flow around the LED lamp shouldbe such that lumen output measurement is not affected.• IES LM-9-2009 provides additional specification for air movement. Itspecifies a single-ply tissue paper should be held in place of thelamp and visual observations be made of air-draft.Air MovementIssue 3:DOE requests comment on whether air movement shouldbe specified in more detail thanthat provided by IES LM-79-2008.16 | Building Technologies Programeere.energy.gov• Lamp orientation is known to affect thermal conditions within thelamp, which may affect lumen output.• IES LM-79-2008 specifies that the lamp should be tested in theoperating orientation recommended by the manufacturer for theintended use of the LED lamp.• However, manufacturers typically do not specify the operatingorientation in product literature.• DOE proposes that an equal number of lamps be operated in thebase up, base down, and horizontal orientations for testing.Lamp OrientationIssue 4:DOE requests comment on operating an equal number oflamps in the base up, base down,and horizontal orientationsthroughout testing.17 | Building Technologies Programeere.energy.gov• DOE proposes that LED lamps should be tested at the rated voltageas specified in IES LM-79-2008.• DOE proposes that LED lamps with multiple operating voltagesshould be tested at 120 volts, if the lamp is rated at 120 volts,because this is the most common operating voltage of availablelamps.• If the lamp is not rated at 120 volts, DOE proposes that it should betested at the highest rated voltage.• For dimmable lamps, DOE proposes that the lamp should be testedat the maximum input power asspecified in IES LM-79-2008.Electrical Settings: InputCharacteristics18 | Building Technologies Programeere.energy.gov• IES LM-79-2008 specifies that lamps with multiple modes ofoperation, such as variable CCT, should be tested in each mode ofoperation.• DOE has not identified any lamps that function at multiple modes ofoperation and requests information on these products.Electrical Settings: Multiple Modes ofOperationIssue 5:• DOE requests comment on testing LED lamps at the rated voltagefor single voltage lamps and testing lamps with dimming capabilityat the maximum input power.• Further, DOE requests comment about testing LED lamps that arerated to operate at multiple voltages at 120 volts or the highestrated voltage.• Finally, DOE requests comment on whether LED lamps withmultiple modes of operation areavailable and the CCT value atwhich these lamps should be tested.19 | Building Technologies Programeere.energy.gov• IES LM-79-2008 specifies noseasoning requirement.• DOE proposes that LED lamps beseasoned for 1,000 hours prior tolamp stabilization and lumen outputmeasurement.• Industry has observed an increase inlumen output during the first 1,000hours of operation of an LED source.Lamp SeasoningSource: Richman, Eric. “Understanding LED Tests:IES LM-79,LM-80, and TM-21.” DOESSL Workshop, July 2011.Issue 6:DOE requests comment on seasoning the LED lamp for1,000 hours before collecting lumen output data.20 | Building Technologies Programeere.energy.gov• DOE proposes that an LED lamp reaches stability when thevariation of at least 3 readingsof input power and lumen outputtaken 15 minutes apart is less than 0.5% as specified in IES LM-79-2008.• The variation should be calculated as follows:• The equation clarifies the method specified in IES LM-79-2008.Lamp StabilizationminimumminimummaximumreadingsthreeleastatofVariation21 | Building Technologies Programeere.energy.govIssue 7:DOE requests comment on stabilizing the lamp until thevariation of at least 3 readingsof the lumen output and electricalpower, taken 15 minutes apart, is less than 0.5 percent. DOE alsorequests comment on its clarificationof the variation calculation tobe the difference of the maximum and minimum values divided bythe minimum value.Issues for Discussion22 | Building Technologies Programeere.energy.gov• DOE proposes that either a sphere-spectroradiometer, spherephotometer, or a goniophotometer be used to measure lumen outputas specified in IES LM-79-2008.Lumen Output Measurement: AllLampsIssue 8:DOE requests comment on measuring the lumen output ofthe LED lamp using a sphere-spectroradiometer system, spherephotometer system, and goniophotometer system. In particular,DOE requests comment on whetherthe measurements from eachmethod are similar and consistent.23 | Building Technologies Programeere.energy.gov• DOE proposes that the total lumen output be measured fordirectional LED lamps rather than the beam lumens (or zonallumens).– Other directional lamp technologies measure total lumen output forreporting ‘brightness’ on FTC’s Lighting Facts label.– Different directional lamp technologies cannot be compared if directionalLED lamps measure beam lumens while other technologies measuretotal lumens.Lumen Output Measurement:Directional LampsIssue 9:DOE requests comment on measuring total lumens fordirectional LED lamps instead of beam lumens.24 | Building Technologies Programeere.energy.gov• DOE proposes that a minimum of 21 LED lamps should be tested.• A minimum of 3 lamps should be selected per month for 7 months ofproduction out of a 12 month period.• If production occurs in fewer than 7months of the year, 3 or morelamps should be selected evenly for each month of production.• Sample sizes greater than 21 should be multiples of 3 to test anequal number of lamps in each orientation.Sampling PlanIssue 21:DOE requests comment on the proposed sample sizerequirements for testing LED lamps.25 | Building Technologies Programeere.energy.gov• DOE proposes that the input powerof all test units be averaged andthe average value be rounded to the nearest tenths digit.• DOE proposes that the lumenoutput and CCT of all units beaveraged and the average values be rounded to the nearest tensdigit.• DOE proposes that the estimated annual energy cost ($/yr) becalculated as the product of the average input power (kW), electricitycost rate ($/kWh), and estimated average use (hrs/day). Theresulting value should be rounded to the nearest cent.Rounding RequirementsIssue 10:DOE requests comment on the proposed calculation androunding requirement for lumen output, input power, CCT, andestimated annual energy cost.26 | Building Technologies Programeere.energy.gov3Test Procedure for Rated LifetimePublic Meeting Slides Topics1Rulemaking Process and Scope2Test Procedure for Input Power, Lumen Output, and CCT27 | Building Technologies Programeere.energy.govApproaches Considered toDetermine Rated LifetimeApproach 1:L70of LEDLampLumen outputof the LEDlamp ismeasuredusing IES LM79-2008 untilhalf the samplesize is below70% of initiallumen output.Approach 2:ENERGYSTAR LifetimeProjectionLumenmaintenance ofLED lamp ismeasured for6,000 hoursusing IES LM79-2008.Maximum ratedlifetime claimis dependenton minimumlumenmaintenance at6,000 hours.Approach 3:Projection ofIES LM-79-2008DataLumen outputof the LEDlamp ismeasured for6,000 hoursminimumusing IES LM79-2008 andprojected toL70life of thelamp.Approach 4:Projection ofLED SourceData using IESTM-21-2011Lumenmaintenance ofLED source ismeasuredusing IES LM80-2008 andprojected toL70using IESTM-21-2011.Maximum ratedlifetime cannotexceed 25,000hours.28 | Building Technologies Programeere.energy.gov• Advantages:– LED lamp, rather than LED source is tested to determine rated lifetime.– The reported value of rated lifetime is the observed value when lumenoutput reaches 70% of initial lumen output (L70). That is, this approachdoes not require projecting the rated lifetime.• Disadvantages:– Testing the LED lamp until the lumen output reaches 70% of initiallumen output can take a very long time (almost 3 years for 25,000hours).– Because LED lamps are an emerging technology and evolving quickly,the product may be obsolete by the time testing is completed.Approach 1: Measuring L70of LEDLamp29 | Building Technologies Programeere.energy.gov• Advantages:– LED lamp, rather than LED source, is tested for 6,000 hours to projectrated lifetime.– Lumen maintenance is projected using minimum 6,000 hours of data,therefore, testing is not as time consuming as Approach 1(approximately 9 months compared to 3 years).• Disadvantages:– LED lamp failure mechanisms, other than lumen depreciation, are notaccounted for.– Cycling is not a proven source of failure for LED lamps.Approach 2: ENERGY STAR LifetimeProjection30 | Building Technologies Programeere.energy.gov• Advantages:– Projects rated lifetime using LED lamp performance data rather thanLED source performance data.– Projection of rated lifetime isbased on minimum 6,000 hours of data,which is not as time consuming as Approach 1.• Disadvantages:– Standard method to make a projection using IES LM-79-2008 data hasnot yet been developed.– It may not be feasible to develop a method for projecting IES LM-79-2008 data in a timely manner for the FTC Lighting Facts label.Approach 3: Projecting IES LM-79-2008 Data31 | Building Technologies Programeere.energy.govApproach 4: Projecting LED SourceData using IES TM-21-2011• Advantages:– Uses accepted industry standard IES TM-21-2011 to project lumenoutput of LED sources as determined by IES LM-80-2008.– Maximum allowable projection cannot exceed 25,000 hours.• Ensures exceedingly large projectionsare not made solely on LED sourcedata.• Currently unknown how long the LED driver may last or how the systemeffects may impact LED lamp lifetime.– Less burdensome than testing the lamp for 6,000 hours according toLM-79 because lumen maintenance data of LED sources is oftenavailable from LED source manufacturers.32 | Building Technologies Programeere.energy.gov• Disadvantages:– Projects LED source data rather than LED lamp data.– Proposed approach does not account for LED driver degradation andfailure, or effect of interactions among LED sources and between LEDsources and other components within the lamp.• Standardized test methods to determine the impact of these components onrated lifetime have not yet been established• Therefore, DOE proposes approach 4 because it uses astandardized test and projection method and has minimal testburden.Approach 4: Projecting LED SourceData using IES TM-21-2011Issue 11:DOE requests comment on the relative costs and benefitsof the 4 approaches considered inthe NOPR to determine ratedlifetime of an LED lamp.33 | Building Technologies Programeere.energy.gov• DOE proposes to define the ratedlifetime of an LED lamp as thetime at which the lumen output ofthe LED source within the lampfalls below 70% of initial light output (L70).Definition of LED Lamp RatedLifetimeIssue 12:DOE requests comment on the proposed definition of therated lifetime of an LED lamp.34 | Building Technologies Programeere.energy.govSteps to Determine Rated LifetimeDetermine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata•Perform an in-situ temperature measurement test (ISTMT) todetermine the case temperature of the LED source at whichlumen maintenance data should be used.•Directly from LED source manufacturers.•By interpolating the data available at 2 other casetemperatures that bound the in-situ temperature.•By measuring the lumen maintenance at the in-situ casetemperature.•Use the method described in IES TM-21-2011 to project LEDsource lumen maintenance data.•Maximum allowable rated lifetime projection is 25,000 hours.35 | Building Technologies Programeere.energy.gov• DOE proposes that the test setup, conditions, testequipment, instrumentation, and test box materialand construction specified in UL 1993-2009 be usedfor performing the ISTMT.• DOE proposes a thermocouple should be attachedto the temperature measurement point (TMP)described by the LED source manufacturer asspecified in Appendix D of the ENERGY STARspecification.– The temporary hole for inserting the thermocoupleshould be tightly sealed during testing.– The ENERGY STAR specification provides guidelinesto attach the thermocouple in the LED lamp.In-situ Temperature MeasurementTestDetermine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata36 | Building Technologies Programeere.energy.govIssue 17:DOE requests comment on adopting section 8.5, 8.13,8.14, 8.15, and 9 of UL 1993-2009and the practicality of thethermocouple attachment requirements for performing the ISTMT.Issues for Discussion37 | Building Technologies Programeere.energy.gov• DOE proposes the test conditions to be as specifiedin IES LM-80-2008.• DOE proposes to test the LED source only at the insitu case temperature, instead of the 3 temperaturesspecified in IES LM-80-2008.• DOE proposes the drive current passing through theLED source should be equal to or greater than thedrive current passing through the LED source in theLED lamp.Test Conditions: Case Temperatureand Drive CurrentDetermine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata38 | Building Technologies Programeere.energy.gov• DOE proposes the temperature of the surroundingair during testing should be maintained between thecast temperature and 5°C below the casetemperature as specified in IES LM-80-2008.• DOE proposes the air movement to be such thatthermal stratification is avoided as specified in IESLM-80-2008.Test Conditions: Air Temperature andAir MovementIssue 13:DOE requests comment on operating theLED sources at the in-situ case temperature and drivecurrent as well as the ambient conditions for testing.DOE also requests comment on whether themeasurement location for air temperature near theLED source and airflow around the LED sourceshould be further specified.Determine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata39 | Building Technologies Programeere.energy.gov• DOE proposes that LED sources should beoperated in the orientation specified by the sourcemanufacturer and spaced to allow airflow aroundeach unit as stated in IES LM-80-2008.• DOE is not proposing a specific operatingorientation for LED sources because the casetemperature is controlled during testing, therebyminimizing the effect of orientation on lumen output.Operating OrientationIssue 14:DOE requests comment on whether theoperating orientation of LED sources affects thelumen depreciation over time.Determine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata40 | Building Technologies Programeere.energy.gov• DOE proposes that an external driver compliant withmanufacturer’s guidance be used to drive the LEDsource as specified in IES LM-80-2008.External DriverIssue 15:DOE requests comment on whether therequirement that the external driver used for testingLED sources be as specified by the manufacturerneeds further clarification.Determine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata41 | Building Technologies Programeere.energy.gov• IES LM-80-2008 specifies that the lumen output ofthe LED source be measured using aspectroradiometer.• Instead, DOE proposes that a spherespectroradiometer system, sphere-photometersystem, or a goniophotometer should be used formeasuring the lumen output of the LED source.Instrumentation to Measure LumenOutputIssue 16:DOE requests comment on using a spherephotometer system or a goniophotometer formeasuring the lumen output of LED sources inaddition to the sphere-spectroradiometer systemspecified in section 6.2 of IES LM-80-2008.Determine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata42 | Building Technologies Programeere.energy.gov• DOE proposes that lumen maintenance bemeasured as specified in IES LM-80-2008 and IESTM-21-2011.• DOE proposes that the following guidelines from theENERGY STAR guidance document should beadopted:– All LED source units should be of the same CCT.– Guidance on testing LED sources of a lamp that hasthe following types of sources:• Both phosphor-converted white and single-color LEDpackages.• LED arrays with either a common phosphor layer orphosphor layers over individual dies.• LED array that is an assembly of LED packages eachwith its own phosphor layer.Lumen Maintenance MeasurementDetermine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata43 | Building Technologies Programeere.energy.govIssue 18:DOE requests comment on adopting relevant guidelinesfrom the ENERGY STAR® guidance document for measuring lumenmaintenance.Issues for Discussion44 | Building Technologies Programeere.energy.gov• DOE proposes that the rated lifetime should beprojected as specified in IES TM-21-2011.• If the projected rated lifetime is greater than 25,000hours, the maximum rated lifetime should be 25,000hours.• If the projected rated lifetime is less than 25,000hours, the rated lifetime should be the projectedvalue.• The rated lifetime should be calculated in number ofyears based on 3 hours per day of operation. Theresulting value should be rounded to the nearesttenth of a year.Projected Rated Lifetime andRounding RequirementsDetermine insitutemperatureObtain lumenmaintenancedataProject lumenmaintenancedata45 | Building Technologies Programeere.energy.govIssue 19:DOE requests comment on adopting section 5.0 of IESTM-21-2011 for projecting the lifetime of the LED sources with amaximum projection of 25,000 hours.Issue 20:DOE requests comment on the proposed roundingrequirement for rated lifetime.Issues for DiscussionIssue 11:DOE requests comment on the proposed approach fordetermining rated lifetime of LED lamps including the proposedincorporation of specificationsoutlined in IES standards LM-80-2008and TM-21-2011 and UL standard 1993-2009.46 | Building Technologies Programeere.energy.gov• DOE proposes that the sample size be as specified in IES TM-21-2011.• At a given case temperature and drive current, at least 10 unitsshould be tested.– The method of projection specified in IES TM-21-2011 cannot be usedfor less than 10 units.Sample Size RequirementsIssue 21:DOE requests comment on the proposed sample sizerequirements for testing LED sources for determining the ratedlifetime of an LED lamp.47 | Building Technologies Programeere.energy.gov• DOE estimated that this rulemaking will impact 17 potential smallbusiness manufacturers of LED lamps from a total of about 32manufacturers.• DOE estimated that each small business manufacturer typicallymanufactures 17 basic models.• The cost for testing 17 basic models for each manufacturer is:– Initial setup: $12,000– Labor cost for testing: $68,000• The cost for changing package and product labeling as well as retailcatalogs should not impose a significant burden.Estimate Burden to SmallBusinesses48 | Building Technologies Programeere.energy.govIssue 22:DOE requests comment on its estimated number of smallbusinesses impacted by this rulemaking as well as its estimatedcost and associated burden to small businesses.Issues for Discussion49 | Building Technologies Programeere.energy.gov• In all correspondence, include all of the following:– Test Procedures for Light-Emitting Diode Lamps– Docket Number: EERE-2011-BT-TP-0071– Regulatory Identification Number (RIN): 1904-AC67• Contact information:– Email:LEDLamps-2011-TP-0071@ee.doe.gov– URL:http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/led_tp_nopr_frnotice.pdf• Comment period closes:June 25, 2012, 11:59 PM EDTDOE Seeks Comment on itsProposed Test ProcedurePostal Mail:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies ProgramMailstop EE-2J1000 Independence Avenue, SWWashington, DC 20585-0121Courier:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program950 L’Enfant Plaza, SW, Suite 600Washington, DC 20024Telephone: (202) 586-294550 | Building Technologies Programeere.energy.govQuestions?