what form did this sneak attack take

It will be recorded that the distance from a government-inspired concept to an actual policy makes it obvious that the attack was deliberately planned many days or even weeks ago. During the intervening time the led flood light has deliberately sought to deceive the solid state lighting community by their cooperative approach and expressions of hope for continued peace.

So what form did this sneak attack take? In a June 2 letter to lighting "manufacturers and other interested parties" the EPA announced a "technical amendment", version 4.2, to the Energy Star residential light fixture (RLF), ceiling fan and vent fan specifications that is of immediate effect in allowing LED light fixtures to achieve the Energy Star mark. It does that by allowing qualification to "new testing procedures" that are somewhat useful but unproven, unqualified at the fixture level and without quantitative history to substantiate their predictive reliability. In addition, the spec itself is directly contrary to the SSL and lighting industry consensus that agreed that the "dim and harsh" factor was a major consumer turn-off with regard to CFL technology at its introduction. Unappealing and ineffective CFL lamps introduced into the residential market caused a general rejection of that technology and set back the pace of adoption on the order of a decade.

The EPA's answer is apparently to repeat the mistake by allowing residential luminaires throwing out as little as lumens to qualify as long as the light engine inside generates 40 lumens/watt with a CCT that can be as harsh as 6500K. Oh, and you have to label it with wording such as "This fixture produces light equivalent to a 6 watt incandescent bulb" in accordance with a handy reference chart. If your integral light engine produces 40 to 69 lumens, you simply need to label it as "equivalent to a 6 watt incandescent bulb". For reference, my wife and son use those leftover 40 lumen bulbs in their tabletop snow village display each Christmas because they're too dim for use as decent nightlights! The EPA figures that qualifying the led high bay light engine inside the fixture is sufficient. So, you can grab your Energy Star mark, push a grand 10 lumens out of a crummy LED "reading light" and claim it is as bright a 40-watt bulb because your "LED light engine" inside the fixture produces between 450 and 799 lumens that are going who knows where. That will get them flocking to the stores to buy one for every room in the house!