The ENERGY STAR Launchpad

May 7, 2012: An Open Letter to the Lighting Industry

Charlie Szoradi is the Chairman and CEO of Independence LED, a Pennsylvania-based commercial lighting company that has developed an LED replacement for fluorescent tubes. The Company has recently moved its manufacturing from China to America.

The leadership of the Federal government’s ENERGY STAR programs must work with the Lighting Industry to further the adoption of American-Made advanced lighting technologies. Currently, ENERGY STAR is a barrier to the adoption of key technologies, such as new LED fluorescent tube replacements, because there is no available listing criteria. LED tube technologies have been left out even though the most recent ones provide reliable, sustainable, low cost energy efficiency retrofits for commercial and industrial customers. With ENERGY STAR certification, American companies can more easily implement lighting efficiency retrofits that will create jobs, lower operating costs, limit disposal and overall environmental impact, and support a more robust and efficient American economy.

LOOK UP. Fluorescent tubes are most likely in your office ceiling. The tubes have dominated commercial lighting since the 1950s1, and lighting now accounts for 30%-35% of all commercial electricity use, according to the Electric Power Research Institute. (EPRI) 2.  Unfortunately, fluorescent lighting is inefficient relative to LEDs, less durable, more maintenance intensive, and creates serious environmental disposal issues given the toxic mercury vapor. New cost-effective LED linear “tube” technologies cut lighting operating costs by more than half and save tens of billions of dollars for U.S. companies. After many years of research effort, ENERGY STAR still has not even published listing criteria for these important new technologies. They simply need to test the most recent linear LED products with dramatically more robust thermal management than the predecessors.

The fact that LED Tubes are currently not on the ENERGY STAR list, even for American manufacturers, seems to be a contradiction to National policy, given that President Obama has spoken so passionately about energy efficiency and clean tech jobs. Fortunately, the fix is quick – ENERGY STAR’s leadership could rapidly implement new listing criteria and facilitate technology adoption without any legislative friction.

ENERGY STAR remains the primary gate keeper to energy efficiency rebates, since U.S. Utility Companies often rely on the label to determine incentive “Rebate” qualifications. ENERGY STAR branding also serves as an objective “Seal of Approval” that complements the financial rebate advantage. Without ENERGY STAR, this efficient and sustainable technology is significantly handicapped. The result is that massive energy and environmental waste continues to burden government facilities and business that unnecessarily pay higher monthly operating costs for electricity.

Looking at the Public Sector, the calculation on the potential savings by replacing fluorescent tubes with LEDs is eye opening.  With over 1.25 million buildings, 3.87 billion sq. ft. and 120 million tubes in Federal government property portfolio, the Annual Savings with LEDs would be over $600 million3. According to the U.S. Department of Energy (DOE), the national fluorescent tube count is in excess of 2.3 billion tubes4. Americans throw away over 600 Million fluorescent tubes each year. At this scale, new efficient LED technologies can achieve significant efficiency and environmental benefits.

With a clear path to an ENERGY STAR listing for LED Tube products, America can thrive:

  • The Private Sector Lighting Retrofit market for Commercial and Industrial facilities grows even if the government property retrofits lag behind.
  • Equipment lease and financing companies step up to support the energy retrofits for the LED tubes that meet the ENERGY STAR criteria.
  • A significant portion of the 70 billion sq. ft. (US Census) of Commercial and Industrial properties change from fluorescent to LEDs and create domestic job opportunities for auditing and installations.
  • America moves closer to Energy Independence and Energy Security.

So why are we where we are today?

Several years ago, the DOE conducted studies that determined that certain early LED tubes, primarily imported from China, did not meet minimum performance criteria. Over the last two years, there have been dramatic improvements in technology, durability, thermal management, and overall quality of light for the latest imported and domestic products. But the industry does not have a clear path forward, since ENERGY STAR has not released any performance criteria for a listing. ENERGY STAR works in concert with the DOE, and the DOE is influenced by third party “experts” some of whom may work for lighting companies that make…fluorescent tubes. The fluorescent tube manufacturers are major brands and multi-nationals that continue to have a powerful influence to protect their billions of fluorescent tube sales worldwide.

The Lighting Industry, as a whole, needs to take a more proactive approach with ENERGY STAR, the DOE, the EPA and other government and regulatory bodies to develop an efficient and rapid certification process to study and set approval standards for new lighting technologies to earn ENERGY STAR listings. New LED tube technologies would be a great first step. Displacing the status quo is always a difficult process, but enabling innovation and progress in lighting technology will yield substantial rewards across the country.


Research Support info:

#1: Dominance of Fluorescent Tubes

“By 1951 more light was produced in the United States by fluorescent lamps than by incandescent lamps.” –


#2: Ratio of Commercial Electricity on Lighting

“lighting accounts for 30% -35% of all commercial electricity use” – Electric Power Research Institute.


#3: The Waste / Savings Potential

Formula: (Savings per Tube per Year with LEDs ) X (# of Federal government Tubes) = Annual Savings with LEDs across the Federal government real estate footprint.

Data on Savings per Tube


Avg. Annual Hours of

Illumination (50 per week): 2,600

Avg. Cost / kWh: $.12

kW Factor for Calculations: 1,000


Annual kWh = Watt / 1,000 X Annual Hours

Annual Cost = Annual kWh X Cost / kWh


4’ Fluorescent Tube:

Watts / Tube: 32

Annual kWh: 83.2

Annual Cost to Operate: $9.98


4’ LED Tube:

Watts / Tube: 15

Annual kWh: 39

Annual Cost to Operate: $4.68


Annual Savings with LEDs on each Tube: $5.30

(Note: The Savings is almost three times higher in 24/7 areas like Exit Stairs, and it is also significantly higher in States like California and across New England where the cost per kWh is higher than the U.S. average. Given the massive footprint of Department of Defense (DOD) real estate overseas, the savings is dramatic given that the cost per kWh in many European and other countries is more than twice the U.S. Average.)

Across the Fed Gov Real Estate

# of Buildings: 1,250,000

# of Square Feet: 3,870,000,000

# of Avg Watts per Sq. Ft.: 1

# of Watts per Avg. Fluorescent Tube: 32

# of Fluorescent Tubes: 120,937,500

(# of Square Feet) X (# of Avg. Watts per Sq. Ft.) /

(# of Watts per Avg. Fluorescent Tube)


SAVINGS Potential: Annual operating costs for all Fed Gov Tubes

Fluorescent Tubes: $1,207,440,000

LED Tubes: $565,987,500


Annual Savings with LEDs:  $641,452,500

Lifetime Savings with LEDs: $14,802,750,000

Support Info: The Watts / sq. ft. for offices comes from the ASHRAE benchmarks:

The Federal Real Property Profile (FRPP) is the single comprehensive inventory system that contains data on all federal real property assets within and outside the United States, including improvements on federal land.

The government’s portfolio of building assets totals approximately 3.87 billion sq. ft of space. In all, the government had a total of 1.25 million building, land, and structure assets with a total replacement value of $1.53 trillion.

Of the total Federal properties more than half is the Department of Defense, “DoD occupies a reported 300,658 buildings throughout the world, valued at over $575 billion comprising over 2.2 billion sq. ft.”  Source: Page #12: Military Report:

The lifetime savings factors 60,000 hours of life for the LEDs but does not include the added benefits of savings on bulb replacement, maintenance labor, or air conditioning reduction.

#4: Number of Fluorescent Tubes

Department of Energy Report: January 2012

2010 U.S. Lighting Market Characterization

See Page #35 for the Tube Breakdown.