[Federal Register Volume 79, Number 82 (Tuesday, April 29, 2014)]
[Proposed Rules]
[Pages 24068-24190]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-08740]
[[Page 24067]]
Vol. 79
Tuesday,
No. 82
April 29, 2014
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for General
Service Fluorescent Lamps and Incandescent Reflector Lamps; Proposed
Rule
Federal Register / Vol. 79, No. 82 / Tuesday, April 29, 2014 /
Proposed Rules
[[Page 24068]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2011-BT-STD-0006]
RIN 1904-AC43
Energy Conservation Program: Energy Conservation Standards for
General Service Fluorescent Lamps and Incandescent Reflector Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of proposed rulemaking (NOPR) and public meeting.
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SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, prescribes energy conservation standards for various
commercial and industrial equipment and certain consumer products,
including general service fluorescent lamps (GSFLs) and incandescent
reflector lamps (IRLs). EPCA also requires the U.S. Department of
Energy (DOE) to determine whether more-stringent, amended standards
would be technologically feasible and economically justified, and would
save a significant amount of energy. In this notice, DOE proposes
amended energy conservation standards for GSFLs and IRLs. The notice
also announces a public meeting to receive comment on these proposed
standards and associated analyses and results.
DATES: DOE will hold a public meeting on Thursday, May 1, 2014, from 9
a.m. to 4 p.m., in Washington, DC. The meeting will also be broadcast
as a webinar. See section IX Public Participation for webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants.
DOE will accept comments, data, and information regarding this NOPR
before and after the public meeting, but no later than June 30, 2014.
See section IX Public Participation for details.
ADDRESSES: The public meeting will be held at the U.S. Department of
Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue SW.,
Washington, DC 20585. To attend, please notify Ms. Brenda Edwards at
(202) 586-2945. Please note that foreign nationals visiting DOE
Headquarters are subject to advance security screening procedures. Any
foreign national wishing to participate in the meeting should advise
DOE as soon as possible by contacting Ms. Edwards to initiate the
necessary procedures. Please also note that those wishing to bring
laptops into the Forrestal Building will be required to obtain a
property pass. Visitors should avoid bringing laptops, or allow an
extra 45 minutes. Persons can attend the public meeting via webinar.
For more information, refer to the Public Participation section near
the end of this notice.
Any comments submitted must identify the NOPR for Energy
Conservation Standards for general service fluorescent lamps and
incandescent reflector lamps and provide docket number EE-2011-BT-STD-
0006 and/or regulatory information number (RIN) number 1904-AC43.
Comments may be submitted using any of the following methods:
1. Federal eRulemaking Portal: www.regulations.gov. Follow the
instructions for submitting comments.
2. Email:[email protected]. Include the docket
number and/or RIN in the subject line of the message.
3. Mail: Ms. Brenda Edwards, U.S. Department of Energy, Building
Technologies Program, Mailstop EE-2J, 1000 Independence Avenue SW.,
Washington, DC 20585-0121. If possible, please submit all items on a
CD. It is not necessary to include printed copies.
4. Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department of
Energy, Building Technologies Program, 950 L'Enfant Plaza SW., Suite
600, Washington, DC 20024. Telephone: (202) 586-2945. If possible,
please submit all items on a CD, in which case it is not necessary to
include printed copies.
Written comments regarding the burden-hour estimates or other
aspects of the collection-of-information requirements contained in this
proposed rule may be submitted to Office of Energy Efficiency and
Renewable Energy through the methods listed above and by email to
[email protected].
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section IX of this document
(Public Participation).
Docket: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at regulations.gov. All
documents in the docket are listed in the regulations.gov index.
However, some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24. This Web page contains a link to the docket for this notice
on the regulations.gov site. The regulations.gov Web page contains
instructions on how to access all documents, including public comments,
in the docket. See section IX for further information on how to submit
comments through www.regulations.gov.
For further information on how to submit a comment, review other
public comments and the docket, or participate in the public meeting,
contact Ms. Brenda Edwards at (202) 586-2945 or by email:
[email protected].
FOR FURTHER INFORMATION CONTACT:
Ms. Lucy deButts, U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Building Technologies Program, EE-2J,
1000 Independence Avenue SW., Washington, DC 20585-0121. Telephone:
(202) 287-1604. Email: [email protected].
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC 20585-
0121. Telephone: (202) 586-7796. Email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Proposed Rule
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
II. Introduction
A. Authority
B. Background
1. Current Standards
2. Corrections to Codified Standards
3. History of Standards Rulemaking for General Service
Fluorescent Lamps and Incandescent Reflector Lamps
4. Test Procedure Standby and Off Mode Energy Consumption
III. General Discussion
A. Product Classes and Scope of Coverage
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
[[Page 24069]]
g. Other Factors
2. Rebuttable Presumption
IV. Issues Affecting Rulemaking Schedule
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
2. Additional General Service Fluorescent Lamp Wattages
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
2. Incandescent Reflector Lamp Wattages
D. Summary of Scope of Coverage
VI. Methodology and Discussion
A. Market and Technology Assessment
1. General Service Fluorescent Lamp Technology Options
2. Incandescent Reflector Lamp Technology Options
B. Screening Analysis
1. General Service Fluorescent Lamp Design Options
2. Incandescent Reflector Lamp Design Options
C. Product Classes
1. General Service Fluorescent Lamp Product Classes
2. Incandescent Reflector Lamp Product Classes
D. Engineering Analysis
1. General Approach
2. General Service Fluorescent Lamp Engineering
a. Data Approach
b. Representative Product Classes
c. Baseline Lamps
d. More Efficacious Substitutes
e. General Service Fluorescent Lamp Systems
f. Maximum Technologically Feasible
g. Efficacy Levels
h. Scaling to Other Product Classes
i. Rare Earth Phosphors
3. Incandescent Reflector Lamp Engineering
a. Metric
b. Representative Product Classes
c. Baseline Lamps
d. More Efficacious Substitutes
e. Maximum Technologically Feasible
f. Efficacy Levels
g. Scaling to Other Product Classes
h. Xenon
i. Proposed Standard
E. Product Pricing Determination
F. Energy Use
1. Operating Hours
2. Lighting Controls
a. General Service Fluorescent Lamp Lighting Controls
b. Incandescent Reflector Lamp Lighting Controls
G. Life-Cycle Cost Analysis and Payback Period Analysis
1. Consumer Product Price
2. Sales Tax
3. Installation Cost
4. Annual Energy Use
5. Product Energy Consumption Rate
6. Electricity Prices
7. Electricity Price Projections
8. Replacement and Disposal Costs
9. Lamp Purchase Events
10. Product Lifetime
a. Lamp Lifetime
b. Ballast Lifetime
11. Discount Rates
12. Analysis Period
13. Compliance Date of Standards
14. General Service Fluorescent Lamp Life-Cycle Cost Results in
the Preliminary Analysis
15. Incandescent Reflector Lamp Life-Cycle Cost Results in the
Preliminary Analysis
H. Consumer Subgroup Analysis
I. Shipments Analysis
J. National Impact Analysis-National Energy Savings and Net
Present Value Analysis
1. National Energy Savings
2. Net Present Value of Consumer Benefit
a. Total Annual Installed Cost
b. Total Annual Operating Cost Savings
K. Manufacturer Impact Analysis
1. Overview
2. GRIM Analysis and Key Inputs
a. Capital and Product Conversion Costs
b. Manufacturer Production Costs
c. Shipment Scenarios
d. Markup Scenarios
3. Discussion of Comments
a. Potential Shift to Other Lighting Technologies
b. Cumulative Regulatory Burden
c. Potential Decrease in Competition
4. Manufacturer Interviews
a. Rare Earth Oxides in General Service Fluorescent Lamps
b. Unknown Impacts of the 2009 Lamps Rule
c. Technology Shift
d. Impact on Residential Sector
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
N. Utility Impact Analysis
O. Employment Impact Analysis
P. Other Comments
VII. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Sub-Groups of Manufacturers
e. Cumulative Regulatory Burden
3. Shipments Analysis and National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Impact of Product Class Switching
d. Alternative Scenario Analyses
e. Indirect Impacts on Employment
4. Impact on Utility or Performance
5. Impact of Any Lessening of Competition
6. Need of the Nation To Conserve Energy
7. Summary of National Economic Impacts
8. Other Factors
C. Proposed Standards
1. Benefits and Burdens of Trial Standard Levels Considered for
General Service Fluorescent Lamps
2. Summary of Benefits and Costs (Annualized) of the Proposed
Standards for General Service Fluorescent Lamps
3. Benefits and Burdens of Trial Standard Levels Considered for
Incandescent Reflector Lamps
4. Summary of Benefits and Costs (Annualized) of the Proposed
Standards for Incandescent Reflector Lamps
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. General Service Fluorescent Lamp and Incandescent Reflector
Lamp Industry Structures and Nature of Competition
d. Comparison Between Large and Small Entities
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and
Regulations
4. Significant Alternatives to the Proposed Rule
5. Significant Issues Raised by Public Comments
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
IX. Public Participation
A. Attendance at the Public Meeting
B. Procedure for Submitting Prepared General Statements for
Distribution
C. Conduct of the Public Meeting
D. Submission of Comments
E. Issues on Which DOE Seeks Comment
X. Approval of the Office of the Secretary
I. Summary of the Proposed Rule
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as
codified), established the
[[Page 24070]]
Energy Conservation Program for Consumer Products Other Than
Automobiles. Pursuant to EPCA, any new or amended energy conservation
standard that DOE prescribes for certain products, such as GSFLs and
IRLs, must be designed to achieve the maximum improvement in energy
efficiency that is technologically feasible and economically justified.
(42 U.S.C. 6295(o)(2)(A)). Furthermore, the new or amended standard
must result in a significant conservation of energy. (42 U.S.C.
6295(o)(3)(B)). In accordance with these and other statutory provisions
discussed in this notice, DOE proposes amended energy conservation
standards for GSFLs and IRLs. The proposed standards, which are the
minimum lumen output per watt of a lamp, are shown in Table I.1 and
Table I.2. These proposed standards, if adopted, would apply to all
products listed in Table I.1 and manufactured in, or imported into, the
United States on or after the date three years after the publication of
the final rule for this rulemaking.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
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With the exception of certain IRLs, these proposed standards, if
adopted, would apply to all products listed in Table I.2 and
manufactured in, or imported into, the United States on or after the
date three years after the publication of the final rule for this
rulemaking. The Consolidated Appropriations Act, 2014 (Public Law 113-
76, Jan. 17, 2014), in relevant part, restricts the use of appropriated
funds in connection with several aspects of DOE's incandescent lamps
program. Specifically, section 322 states that none of the funds made
available by the Act may be used to implement or enforce standards for
BPAR incandescent reflector lamps, BR incandescent reflector lamps, and
ER incandescent reflector lamps. The majority of IRLs in this
rulemaking are PAR IRLs and therefore do not fall into category of
lamps prohibited by section 322. The small number of lamps that are
BPAR, ER, and BR IRLs are not included in this rulemaking pursuant to
section 322. DOE had initiated a separate rulemaking for lamps rated 50
watts or less that are ER30, BR30, BR40, or ER40; lamps rated 65 watts
that are BR30, BR40, or ER40 lamps; and R20 IRLs rated 45 watts or
less, but has suspended activity on this rulemaking as a result of
section 322 of Public Law 113-76. (See section II.B.3 for further
details.)
Table I.1--Proposed Energy Conservation Standards for General Service Fluorescent Lamps
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Percent
Correlated increase over
Lamp type color Proposed level current
temperature lm/W standards or
baseline
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4-Foot Medium Bipin............................................. <=4,500 K 92.4 3.8
>4,500 K 90.6 3.0
2-Foot U-Shaped................................................. <=4,500 K 86.9 3.5
>4,500 K 84.3 4.1
8-Foot Slimline................................................. <=4,500 K 99.0 2.1
>4,500 K 94.1 1.2
8-Foot Recessed Double Contact High Output...................... <=4,500 K 97.6 6.1
>4,500 K 95.6 8.6
4-Foot Miniature Bipin Standard Output.......................... <=4,500 K 97.1 12.9
>4,500 K 91.3 12.7
4-Foot Miniature Bipin High Output.............................. <=4,500 K 82.7 8.8
>4,500 K 78.6 9.2
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Table I.2--Proposed Energy Conservation Standards for Incandescent Reflector Lamps
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Percentage
increase over
Lamp type Diameter Voltage V Proposed level current
inches * lm/W standards or
baseline %
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Standard Spectrum 40 W--205 W................... >2.5 >=125 7.1P\0.27\ 4.4
.............. <125 6.2P\0.27\ 5.1
<=2.5 >=125 6.0P\0.27\ 5.3
.............. <125 5.2P\0.27\ 4.0
Modified Spectrum 40 W--205 W................... >2.5 >=125 6.0P\0.27\ 3.4
.............. <125 5.2P\0.27\ 4.0
<=2.5 >=125 5.1P\0.27\ 4.1
.............. <125 4.4P\0.27\ 4.8
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* P = lamp rated wattage.
Note 1: BPAR, ER, and BR IRLs and R20 IRLs rated 45 watts or less are not subject to the proposed standards for
IRLs.
A. Benefits and Costs to Consumers
DOE calculates a range of life-cycle cost (LCC) savings and mean
payback period (PBP) results for various purchasing events and sectors.
These results are presented in section VII.B.1 and chapter 8 of the
NOPR TSD. Table I.3 presents DOE's evaluation of the economic impacts
of the proposed standards on consumers of GSFLs, as measured by the
weighted average LCC savings and the weighted average mean PBP. The
weighted average LCC savings are positive for all product classes with
the exception of the 8-foot recessed double contact high output (HO)
product class. Table I.4 presents DOE's evaluation of economic impacts
of the proposed standards on consumers of IRLs, as measured by the
weighted average LCC and mean PBP. The weighted average LCC savings are
positive for all product classes.
[[Page 24071]]
Table I.3--Impacts of Proposed Standards on Consumers of General Service
Fluorescent Lamps
------------------------------------------------------------------------
Weighted
Weighted average mean
Product class average LCC payback
savings 2012$ period *
years
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4-foot medium bipin <=4,500 K........... 3.14 3.6
4-foot T5 miniature bipin standard 2.76 4.3
output <=4,500 K.......................
4-foot T5 miniature bipin high output 2.28 3.0
<=4,500 K..............................
8-foot single pin slimline <=4,500 K.... 2.08 4.5
8-foot recessed double contact HO -16.76 NER
<=4,500 K..............................
------------------------------------------------------------------------
* Does not include weighting for ``NER'' Scenarios. ``NER'' indicates
standard levels that do not reduce operating costs, which prevents the
consumer from recovering the increased purchase cost.
Table I.4--Impacts of Proposed Standards on Consumers of Incandescent
Reflector Lamps
------------------------------------------------------------------------
Weighted
Weighted average mean
Product class average LCC payback period
savings 2012$ years
------------------------------------------------------------------------
Standard spectrum, >2.5 inches, <125 V.. 2.95 5.4
------------------------------------------------------------------------
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2013 to 2046). Using a real discount rate of 9.2
percent, DOE estimates that the INPV for manufacturers of GSFLs is
$1,542.5 million in 2012$. Under the proposed standards, DOE expects
that manufacturers may lose up to 2.6 percent of their INPV, which is
approximately $39.9 million in 2012$. Additionally, based on DOE's
interviews with the manufacturers of GSFLs, DOE does not expect any
plant closings or significant loss of employment based on the energy
conservation standards proposed for GSFLs.
For IRLs, DOE estimates that the INPV for manufacturers of IRLs is
$176.0 million in 2012$ using a real discount rate of 9.2 percent.
Under the proposed standards, DOE expects that manufacturers may lose
up to 29.5 percent of their INPV, which is approximately $51.8 million
in 2012$. Additionally, manufacturers of IRLs stated in interviews with
DOE that there is the potential for IRL manufacturers to close existing
U.S. manufacturing plants or for a potential loss of domestic IRL
manufacturing employment based on the energy conservation standards
proposed for IRLs.
C. National Benefits \2\
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\2\ All monetary values in this section are expressed in 2012$
and are discounted to 2013.
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DOE's analyses indicate that the proposed standards for GSFLs would
save a significant amount of energy. The lifetime savings for GSFLs
purchased in the 30-year period that begins in the year of compliance
with amended standards (2017-2046) amount to 3.5 quads.
DOE's analyses indicate that the proposed standards for IRLs would
save a significant amount of energy. The lifetime savings for IRLs
purchased in the 30-year period that begins in the year of compliance
with amended standards (2017-2046) amount to 0.013 quads.
The cumulative net present value (NPV) of total consumer costs and
savings of the proposed standards for GSFLs ranges from $3.1 billion
(at a 7-percent discount rate) to $8.1 billion (at a 3-percent discount
rate). This NPV expresses the estimated total value of future
operating-cost savings minus the estimated increased product costs for
products purchased in 2017-2046.
The NPV of total consumer costs and savings of the proposed
standards for IRLs ranges from $0.18 billion (at a 7-percent discount
rate) to $0.28 billion (at a 3-percent discount rate). This NPV
expresses the estimated total value of future operating-cost savings
minus the estimated increased product costs for products purchased in
2017-2046.
In addition, the proposed standards for GSFLs would have
significant environmental benefits. The energy savings would result in
cumulative emission reductions of 170 million metric tons (Mt) \3\ of
carbon dioxide (CO2), 730 thousand tons of methane, 250
thousand tons of sulfur dioxide (SO2), 210 thousand tons of
nitrogen oxides (NOX), 2.8 thousand tons of nitrous oxide
(N2O), and 0.32 tons of mercury (Hg). The energy savings
would result in cumulative emission reductions of 98 Mt of
CO2 through 2030.
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\3\ A metric ton is equivalent to 1.1 short tons. Results for
NOX and Hg are presented in short tons.
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The proposed standards for IRL would also have significant
environmental benefits. The energy savings would result in cumulative
emission reductions of 0.70 Mt of CO2, 2.7 thousand tons of
methane, 0.69 thousand tons of SO2, 0.79 thousand tons of
NOX, 0.01 thousand tons of N2O, and 0.001 tons of
Hg. The energy savings would result in cumulative emission reductions
of 1 Mt of CO2 through 2030.
The value of the CO2 reductions for the proposed
standards for GSFLs is calculated using a range of values per metric
ton of CO2 (otherwise known as the Social Cost of Carbon, or
SCC) developed by an interagency process. The derivation of the SCC
values is discussed in section VI.M. Using discount rates appropriate
for each set of SCC values, DOE estimates the present monetary value of
the CO2 emissions reduction is between $1.3 billion and $17
billion. DOE also estimates the present monetary value of the
NOX emissions reduction, is $200 million at a 7-percent
discount rate and $340 million at a 3-percent discount rate.\4\
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\4\ DOE is currently investigating monetary valuation of avoided
Hg and SO2 emissions.
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The value of the CO2 reductions for the proposed
standards of IRL is calculated using the same SCC values and discount
rates used for GSFLs. DOE
[[Page 24072]]
estimates the present monetary value of the CO2 emissions
reduction is between $0.0062 billion and $0.076 billion. DOE also
estimates the present monetary value of the NOX emissions
reduction, is $1.1 million at a 7-percent discount rate and $1.6
million at a 3-percent discount rate.\4\
Table I.5 and Table I.6 summarize the national economic costs and
benefits expected to result from the proposed standards for GSFLs and
IRLs.
Table I.5--Summary of National Economic Benefits and Costs of Proposed
Energy Conservation Standards for General Service Fluorescent Lamps *
------------------------------------------------------------------------
Present value Discount rate
Category Billion 2012$ (percent)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Operating Cost Savings............ 12 7
22 3
CO2 Reduction Monetized Value 1.3 5
($11.8/t case) **................
CO2 Reduction Monetized Value 5.6 3
($39.7/t case) **................
CO2 Reduction Monetized Value 8.9 2.5
($61.2/t case) **................
CO2 Reduction Monetized Value 17 3
($117/t case) **.................
NOX Reduction Monetized Value (at 0.2 7
$2,639/ton) **...................
0.3 3
Total Benefits [dagger]........... 18 7
28 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Incremental Installed Costs....... 8.8 7
13 3
------------------------------------------------------------------------
Total Net Benefits
------------------------------------------------------------------------
Including Emissions Reduction 9.0 7
Monetized Value [dagger].........
14 3
------------------------------------------------------------------------
* This table presents the costs and benefits associated with GSFL
shipped in 2017-2046. These results include benefits to consumers
which accrue after 2046 from the products purchased in 2017-2046. The
results account for the incremental variable and fixed costs incurred
by manufacturers due to the standard, some of which may be incurred in
preparation for the rule.
** The CO2 values represent global monetized values of the SCC, in
2012$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5%, 3%, and 2.5% discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated
using a 3% discount rate. The SCC time series used by DOE incorporate
an escalation factor. The value for NOX is the average of the low and
high values used in DOE's analysis.
[dagger] Total Benefits for both the 3% and 7% cases are derived using
the series corresponding to average SCC with 3-percent discount rate.
Table I.6--Summary of National Economic Benefits and Costs of Proposed
Energy Conservation Standards for Incandescent Reflector Lamps
------------------------------------------------------------------------
Present value Discount rate
Category Billion 2012$ (Percent)
------------------------------------------------------------------------
Benefits
------------------------------------------------------------------------
Operating Cost Savings............ 0.07 7
0.11 3
CO2 Reduction Monetized Value 0.006 5
($11.8/t case) **................
CO2 Reduction Monetized Value 0.03 3
($39.7/t case) **................
CO2 Reduction Monetized Value 0.04 2.5
($61.2/t case) **................
CO2 Reduction Monetized Value $117/ 0.08 3
t case) *........................
NOX Reduction Monetized Value (at 0.001 7
$2,639/ton) **...................
0.002 3
Total Benefits[dagger]............ 0.10 7
0.13 3
------------------------------------------------------------------------
Costs
------------------------------------------------------------------------
Incremental Installed -0.11 7
Costs[Dagger]....................
-0.17 3
------------------------------------------------------------------------
Total Net Benefits
------------------------------------------------------------------------
Including Emissions Reduction 0.20 7
Monetized Value[dagger]..........
0.31 3
------------------------------------------------------------------------
* This table presents the costs and benefits associated with IRLs
shipped in 2017-2046. These results include benefits to consumers
which accrue after 2046 from the products purchased in 2017-2046. The
results account for the incremental variable and fixed costs incurred
by manufacturers due to the standard, some of which may be incurred in
preparation for the rule.
[[Page 24073]]
** The CO2 values represent global monetized values of the SCC, in
2012$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5%, 3%, and 2.5% discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated
using a 3% discount rate. The SCC time series used by DOE incorporate
an escalation factor. The value for NOX is the average of the low and
high values used in DOE's analysis.
[dagger] Total Benefits for both the 3% and 7% cases are derived using
the series corresponding to average SCC with 3-percent discount rate.
[Dagger] This reduction in product costs occurs because the more
efficacious products have substantially longer lifetimes than the
products that would be eliminated by the proposed standard.
The benefits and costs of today's proposed standards, for products
sold in 2017-2046, can also be expressed in terms of annualized values.
The annualized monetary values are the sum of (1) the annualized
national economic value of the benefits from consumer operation of
products that meet the proposed standards (consisting primarily of
operating cost savings from using less energy, minus increases in
product purchase and installation costs, which is another way of
representing consumer NPV), and (2) the annualized monetary value of
the benefits of emission reductions, including CO2 emission
reductions.\5\
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\5\ DOE used a two-step calculation process to convert the time-
series of costs and benefits into annualized values. First, DOE
calculated a present value in 2013, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of three and seven percent
for all costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates, as
shown in Table I.5 and Table I.6. From the present value, DOE then
calculated the fixed annual payment over a 30-year period (2017
through 2046) that yields the same present value. The fixed annual
payment is the annualized value. Although DOE calculated annualized
values, this does not imply that the time-series of cost and
benefits from which the annualized values were determined is a
steady stream of payments.
---------------------------------------------------------------------------
Although combining the values of operating savings and
CO2 emission reductions provides a useful perspective, two
issues should be considered. First, the national operating savings are
domestic U.S. consumer monetary savings that occur as a result of
market transactions while the value of CO2 reductions is
based on a global value. Second, the assessments of operating cost
savings and CO2 savings are performed with different methods
that use different time frames for analysis. The national operating
cost savings is measured for the lifetime of GSFLs and IRLs shipped in
2017-2046. The SCC values, on the other hand, reflect the present value
of some future climate-related impacts resulting from the emission of
one ton of CO2 in each year. These impacts continue well
beyond 2100.
Estimates of annualized benefits and costs of the proposed
standards for GSFLs are shown in Table I.7. The results under the
primary estimate are as follows. Using a 7-percent discount rate for
benefits and costs other than CO2 reduction, for which DOE
used a 3-percent discount rate along with the average SCC series that
uses a 3-percent discount rate, the cost of the standards proposed in
today's rule is $873 million per year in increased product costs; while
the estimated benefits are $1,180 million per year in reduced product
operating costs, $314 million per year in CO2 reductions,
and $19.3 million per year in reduced NOX emissions. In this
case, the net benefit would amount to $642 million per year. Using a 3-
percent discount rate for all benefits and costs and the average SCC
series, the estimated cost of the standards proposed in today's rule is
$751 million per year in increased product costs; while the estimated
benefits are $1,200 million per year in reduced operating costs, $314
million per year in CO2 reductions, and $18.9 million per
year in reduced NOX emissions. In this case, the net benefit
would amount to approximately $783 million per year.
Estimates of annualized benefits and costs of the proposed
standards for IRLs are shown in Table I.8. The results under the
primary estimate are as follows. Using a 7-percent discount rate for
benefits and costs other than CO2 reduction, for which DOE
used a 3-percent discount rate along with the average SCC series that
uses a 3-percent discount rate, the annualized cost of today's proposed
standards is negative $10.4 million per year in reduced product
costs,\6\ and the annualized benefits are $7.2 million per year in
reduced product operating costs, $1.4 million per year in
CO2 reductions, and $0.11 million per year in reduced
NOX emissions. In this case, the net benefit would amount to
$19 million per year. Using a 3-percent discount rate for all benefits
and costs and the average SCC series, the estimated annualized cost of
the standards proposed in today's rule is negative $9.7 million per
year in reduced product costs, and the annualized benefits of the
standards proposed in today's rule are $5.9 million per year in reduced
operating costs, $1.4 million per year in CO2 reductions,
and $0.09 million per year in reduced NOX emissions. In this
case, the net benefit would amount to approximately $17 million per
year.
---------------------------------------------------------------------------
\6\ This negative cost represents a reduction in product costs
compared to the base case, because the more efficacious products
have substantially longer lifetimes than the products that would be
eliminated by the proposed standard.
Table I.7--Annualized Benefits and Costs of Proposed Energy Conservation Standards for General Service
Fluorescent Lamps
----------------------------------------------------------------------------------------------------------------
Primary estimate Low net benefits High net benefits
Discount rate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
million 2012$/year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings........... 7%.................. 1,180 1,160 1,220
3%.................. 1,200 1,170 1,250
CO2 Reduction Monetized Value 5%.................. 98 98 98
($11.8/t case) **.
CO2 Reduction Monetized Value 3%.................. 314 314 314
($39.7/t case) **.
CO2 Reduction Monetized Value 2.5%................ 456 456 456
($61.2/t case) **.
CO2 Reduction Monetized Value 3%.................. 968 968 968
($117/t case) **.
NOX Reduction Monetized Value (at 7%.................. 19.3 19.3 19.3
$2,639/ton) **.
3%.................. 18.9 18.9 18.9
Total Benefits[dagger]........... 7% plus CO2 range... 1,300 to 2,160 1,280 to 2,140 1,340 to 2,210
7%.................. 1,520 1,490 1,560
[[Page 24074]]
3% plus CO2 range... 1,320 to 2,180 1,290 to 2,160 1,370 to 2,230
3%.................. 1,530 1,510 1,580
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Product Costs........ 7%.................. 873 910 873
3%.................. 751 785 751
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger]................... 7% plus CO2 range... 426 to 1,291 367 to 1,232 469 to 1,330
7%.................. 642 583 685
3% plus CO2 range... 567 to 1,432 505 to 1,370 615 to 1,480
3%.................. 783 722 831
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with GSFLs shipped in 2017-2046. These
results include benefits to consumers which accrue after 2046 from the products purchased in 2017-2046. The
results account for the incremental variable and fixed costs incurred by manufacturers due to the standard,
some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central
energy prices from AEO 2013 and a decreasing incremental product cost, due to price learning. The Low Benefits
Estimate assumes the low estimate of energy prices from AEO 2013 and constant real product prices. The High
Benefits Estimate assumes the high energy price estimates from AEO 2013 and decreasing incremental product
costs, due to price learning.
** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
Table I.8--Annualized Benefits and Costs of Proposed Energy Conservation Standards for Incandescent Reflector
Lamps
----------------------------------------------------------------------------------------------------------------
Primary estimate Low net benefits High net benefits
Discount rate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
million 2012$/year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings........... 7%.................. 7.2 7.1 10
3%.................. 5.9 5.8 5.8
CO2 Reduction Monetized Value 5%.................. 0.5 0.5 0.5
($11.8/t case) **.
CO2 Reduction Monetized Value 3%.................. 1.4 1.4 1.4
($39.7/t case) **.
CO2 Reduction Monetized Value 2.5%................ 2.0 2.0 2.0
($61.2/t case) **.
CO2 Reduction Monetized Value 3%.................. 4.2 4.2 4.2
($117/t case) *.
NOX Reduction Monetized Value (at 7%.................. 0.11 0.11 0.16
$2,639/ton) **.
3%.................. 0.09 0.09 0.09
Total Benefits [dagger].......... 7% plus CO2 range... 7.8 to 12 7.7 to 11 7.8 to 12
7%.................. 8.7 8.6 8.7
3% plus CO2 range... 6.4 to 10 6.4 to 10 6.4 to 10
3%.................. 7.4 7.3 7.3
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Product Costs 7%.................. -10.4 -10.5 -10.4
[Dagger].
3%.................. -9.7 -9.8 -9.7
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger]................... 7% plus CO2 range... 18 to 22 18 to 22 18 to 22
7%.................. 19 19 19
3% plus CO2 range... 16 to 20 16 to 20 16 to 20
3%.................. 17 17 17
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with IRLs shipped in 2017-2046. These results
include benefits to consumers which accrue after 2046 from the products purchased in 2017-2046. The results
account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of
which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy
prices from AEO 2013 and a decreasing incremental product cost, due to price learning. The Low Benefits
Estimate assumes the low estimate of energy prices from AEO 2013 and constant real product prices. The High
Benefits Estimate assumes the high energy price estimates from AEO 2013 and decreasing incremental product
costs, due to price learning.
[[Page 24075]]
** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
[Dagger] This reduction in product costs occurs because the more efficacious products have substantially longer
lifetimes than the products that would be eliminated by the proposed standard.
DOE has tentatively concluded that the proposed standards represent
the maximum improvement in energy efficiency that is technologically
feasible and economically justified, and would result in the
significant conservation of energy. DOE further notes that products
achieving these standard levels are already commercially available.
Based on the analyses described above, DOE has tentatively concluded
that the benefits of the proposed standards to the nation (energy
savings, positive NPV of consumer benefits, consumer LCC savings, and
emission reductions) would outweigh the burdens (loss of INPV for
manufacturers and LCC increases for some consumers).
Based on consideration of the public comments DOE receives in
response to this notice and related information collected and analyzed
during the course of this rulemaking effort, DOE may adopt energy
efficiency levels presented in this notice that differ from the
proposed standards, or some combination of level(s) that incorporate
the proposed standards in part.
II. Introduction
The following section briefly discusses the statutory authority
underlying today's proposal, as well as some of the relevant historical
background related to the establishment of standards for GSFLs and
IRLs.
A. Authority
Title III, Part B of the EPCA, Public Law 94-163 (42 U.S.C. 6291-
6309, as codified) established the Energy Conservation Program for
Consumer Products Other Than Automobiles,\7\ a program covering most
major household appliances (collectively referred to as ``covered
products''), which includes the types of GSFLs and IRLs that are the
subject of this rulemaking. (42 U.S.C. 6292(a)(14)) EPCA prescribed
energy conservation standards for these products (42 U.S.C.
6295(i)(1)), and directed DOE to conduct two cycles of rulemakings to
determine whether to amend these standards. (42 U.S.C. 6295(i)(3)-(5))
On July 14, 2009, DOE published a final rule in the Federal Register,
which completed the first rulemaking cycle to amend energy conservation
standards for GSFLs and IRLs (hereafter the ``2009 Lamps Rule''). 74 FR
34080. That rule adopted standards for additional GSFLs, amended the
definition of ``colored fluorescent lamp'' and ``rated wattage,'' and
also adopted test procedures applicable to the newly covered GSFLs.
Information regarding the 2009 Lamps Rule can be found on
regulations.gov, docket number EERE-2006-STD-0131 at
www.regulations.gov/#!docketDetail;D=EERE-2006-STD-0131.
---------------------------------------------------------------------------
\7\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
---------------------------------------------------------------------------
This rulemaking encompasses DOE's second cycle of review to
determine whether the standards in effect for GSFLs and IRLs should be
amended, including whether the standards should be applicable to
additional GSFLs.
Pursuant to EPCA, DOE's energy conservation program for covered
products consists essentially of four parts: (1) testing; (2) labeling;
(3) the establishment of Federal energy conservation standards; and (4)
certification and enforcement procedures. The Federal Trade Commission
(FTC) is primarily responsible for labeling, and DOE implements the
remainder of the program. Subject to certain criteria and conditions,
DOE is required to develop test procedures to measure the energy
efficiency, energy use, or estimated annual operating cost of each
covered product. (42 U.S.C. 6293) Manufacturers of covered products
must use the prescribed DOE test procedure as the basis for certifying
to DOE that their products comply with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use
these test procedures to determine whether the products comply with
standards adopted pursuant to EPCA. Id. The DOE test procedures for
GSFLs and IRLs currently appear at title 10 of the Code of Federal
Regulations (CFR) part 430, subpart B, appendix R.
DOE must follow specific statutory criteria for prescribing amended
standards for covered products. As indicated above, any amended
standard for a covered product must be designed to achieve the maximum
improvement in energy efficiency that is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may
not adopt any standard that would not result in the significant
conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not
prescribe a standard: (1) for certain products, including GSFLs and
IRLs, if no test procedure has been established for the product, or (2)
if DOE determines by rule that the proposed standard is not
technologically feasible or economically justified. (42 U.S.C.
6295(o)(3)(A)-(B)) In deciding whether a proposed standard is
economically justified, DOE must determine whether the benefits of the
standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make
this determination after receiving comments on the proposed standard,
and by considering, to the greatest extent practicable, the following
seven factors:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the imposition of the
standard;
3. The total projected amount of energy, or as applicable, water,
savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any amended standard that either increases the maximum
[[Page 24076]]
allowable energy use or decreases the minimum required energy
efficiency of a covered product. (42 U.S.C. 6295(o)(1)) Also, the
Secretary may not prescribe an amended or new standard if interested
persons have established by a preponderance of the evidence that the
standard is likely to result in the unavailability in the United States
of any covered product type (or class) of performance characteristics
(including reliability), features, sizes, capacities, and volumes that
are substantially the same as those generally available in the United
States. (42 U.S.C. 6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption
that a standard is economically justified if the Secretary finds that
the additional cost to the consumer of purchasing a product complying
with an energy conservation standard level will be less than three
times the value of the energy savings during the first year that the
consumer will receive as a result of the standard, as calculated under
the applicable test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii).
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when
promulgating a standard for a type or class of covered product that has
two or more subcategories. DOE must specify a different standard level
than that which applies generally to such type or class of products for
any group of covered products that have the same function or intended
use if DOE determines that products within such group (A) consume a
different kind of energy from that consumed by other covered products
within such type (or class); or (B) have a capacity or other
performance-related feature which other products within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6294(q)(1)) In determining whether a performance-
related feature justifies a different standard for a group of products,
DOE must consider such factors as the utility to the consumer of the
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C.
6295(q)(2))
Federal energy conservation requirements generally supersede state
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers
of federal preemption for particular state laws or regulations, in
accordance with the procedures and other provisions set forth under 42
U.S.C. 6297(d)).
Any final rule for new or amended energy conservation standards
promulgated after July 1, 2010, must also address standby mode and off
mode energy use. (42 U.S.C. 6295(gg)(3)) Specifically, when DOE adopts
a standard for a covered product after that date, it must, if justified
by the criteria for adoption of standards under EPCA (42 U.S.C.
6295(o)), incorporate standby mode and off mode energy use into the
standard, or, if that is not feasible, adopt a separate standard for
such energy use for that product. (42 U.S.C. 6295(gg)(3)(A)-(B)) DOE
has determined that standby mode and off mode do not apply to GSFLs and
IRLs and that their energy use is accounted for entirely in the active
mode. Therefore, DOE is not addressing standby and off modes, and will
only address active mode in this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011. 76 FR 3281 (Jan. 21, 2011). EO 13563
is supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation only upon a
reasoned determination that its benefits justify its costs (recognizing
that some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, the Office of Information and Regulatory Affairs has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
DOE believes that today's NOPR is consistent with these principles,
including the requirement that, to the extent permitted by law,
benefits justify costs and that net benefits are maximized. Consistent
with EO 13563, and the range of impacts analyzed in this rulemaking,
the energy efficiency standard proposed herein by DOE achieves maximum
net benefits.
B. Background
1. Current Standards
In the 2009 Lamps Rule, DOE prescribed the current energy
conservation standards for GSFLs and IRLs manufactured on or after July
14, 2012 (hereafter the ``July 2012 standards''). 74 FR 34080. The
current standards are set forth in Table II.1 and Table II.2.
Table II.1--July 2012 Standards for General Service Fluorescent Lamps
------------------------------------------------------------------------
Minimum
Lamp type Correlated color average lamp
temperature efficacy lm/W
------------------------------------------------------------------------
Four-Foot Medium Bipin............ <=4,500 K........... 89
>4,500 K and <=7,000 88
K.
Two-Foot U-Shaped................. <=4,500 K........... 84
>4,500 K and <=7,000 81
K.
Eight-Foot Slimline............... <=4,500 K........... 97
>4,500 K and <=7,000 93
K.
Eight-Foot High Output............ <=4,500 K........... 92
[[Page 24077]]
>4,500 K and <=7,000 88
K.
Four-Foot Miniature Bipin Standard <=4,500 K........... 86
Output.
>4,500 K and <=7,000 81
K.
Four-Foot Miniature Bipin High <=4,500 K........... 76
Output.
>4,500 K and <=7,000 72
K.
------------------------------------------------------------------------
Table II.2--July 2012 Standards for Incandescent Reflector Lamps
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy lm/
inches W
----------------------------------------------------------------------------------------------------------------
40-205..................... Standard Spectrum......... >2.5 >=125 V 6.8*P\0.27\
<125 V 5.9*P\0.27\
<=2.5 >=125 V 5.7*P\0.27\
<125 V 5.0*P\0.27\
----------------------------------------------------------------------------------------------------------------
40-205..................... Modified Spectrum......... >2.5 \8\ >=125 V 5.8*P\0.27\
<125 V 5.0*P\0.27\
<=2.5 >=125 V 4.9*P\0.27\
<125 V 4.2*P\0.27\
----------------------------------------------------------------------------------------------------------------
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified
spectrum in 430.2.
2. Corrections to Codified Standards
In this rulemaking, DOE is proposing to correct errors in the
codified standards for GSFLs and IRLs. In particular, DOE is proposing
to correct the typographical errors in the sections of the CFR that lay
out the GSFL standards specified in EPCA and the IRL standards
established by the 2009 Lamps Rule. Specifically, for the GSFL
standards codified at 10 CFR 430.32(n)(1), the ``less than or equal to
35 W'' associated with the 8-foot single pin (SP) slimline lamp type
should instead be associated with the 2-foot U-shaped lamp type. For 8-
foot SP slimline product class with a minimum color rendering index
(CRI) of 45 and a minimum average lamp efficacy of 80.0 lumens per watt
(lm/W), the rated wattage should be less than or equal to 65 W, not
greater than 65 W. The revised table should read as follows:
---------------------------------------------------------------------------
\8\ Shown correctly in this table; erroneously written as
``<=125V'' in the CFR.
Table II.3--GSFL Standards Prescribed by EPAct
----------------------------------------------------------------------------------------------------------------
Minimum
Lamp type Nominal lamp wattage Minimum CRI average lamp Effective date
efficacy lm/W
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin................... >35 W................... 69 75.0 Nov. 1, 1995.
<=35 W.................. 45 75.0 Nov. 1, 1995.
2-foot U-shaped....................... >35 W................... 69 68.0 Nov. 1, 1995.
<=35 W.................. 45 64.0 Nov. 1, 1995.
8-foot slimline....................... >65 W................... 69 80.0 May 1, 1994.
<=65 W.................. 45 80.0 May 1, 1994.
8-foot high output.................... >100 W.................. 69 80.0 May 1, 1994.
<=100 W................. 45 80.0 May 1, 1994.
----------------------------------------------------------------------------------------------------------------
For the IRL standards adopted by the 2009 Lamps Rule that are
codified in 10 CFR 430.32(n)(5), the minimum lamp efficacy of
5.8P\0.27\ is for lamps with a rated wattage of 40-205 W, modified
spectrum, diameter greater than 2.5 inches, and rated voltage of
``greater than or equal to 125 V'' rather than ``less than or equal to
125 V.'' The revised table should read as follows:
[[Page 24078]]
Table II.4--IRL Standards Adopted by the 2009 Lamps Rule
----------------------------------------------------------------------------------------------------------------
Minimum
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage average lamp
inches efficacy lm/W
----------------------------------------------------------------------------------------------------------------
40-205.......................... Standard Spectrum............. >2.5 >=125 V 6.8*P\0.27\
<125 V 5.9*P\0.27\
<=2.5 >=125 V 5.7*P\0.27\
<125 V 5.0*P\0.27\
40-205.......................... Modified Spectrum............. >2 .5 >=125 V 5.8*P\0.27\
<125 V 5.0*P\0.27\
<=2.5 >=125 V 4.9*P\0.27\
<125 V 4.2*P\0.27\
----------------------------------------------------------------------------------------------------------------
3. History of Standards Rulemaking for General Service Fluorescent
Lamps and Incandescent Reflector Lamps
As mentioned in the previous section, EPCA, as amended, established
energy conservation standards for certain classes of GSFLs and IRLs,
and required DOE to conduct two rulemaking cycles to determine whether
these standards should be amended. (42 U.S.C. 6291(1), 6295(i)(1) and
(3)-(4)) EPCA also authorized DOE to adopt standards for additional
GSFLs if such standards were warranted. (42 U.S.C. 6295(i)(5))
DOE completed the first cycle of amendments by publishing a final
rule in the Federal Register in July 2009. 74 FR 34080 (July 14, 2009).
The 2009 Lamps Rule amended existing GSFL and IRL energy conservation
standards and adopted standards for additional GSFLs. That rule also
amended the definition of ``colored fluorescent lamp'' and ``rated
wattage,'' and adopted test procedures applicable to the newly covered
GSFLs.
The Energy Policy Act of 1992 (EPAct 1992, Pub. L. 102-486)
amendments to EPCA added as covered products IRLs with wattages of 40
watts (W) or higher. In defining the term ``incandescent reflector
lamp,'' EPAct 1992 excluded lamps with elliptical reflector (ER) and
bulged reflector (BR) bulb shapes, and with diameters of 2.75 inches or
less. Therefore, such IRLs were neither included as covered products
nor subject to EPCA's standards for IRLs.
Section 322(a)(1) of the Energy Independence and Security Act of
2007 (EISA 2007) subsequently amended EPCA to expand the Act's
definition of ``incandescent reflector lamp'' to include lamps with a
diameter between 2.25 and 2.75 inches, as well as lamps with ER, BR,
bulged parabolic aluminized reflector (BPAR), or similar bulb shapes.
(42 U.S.C. 6291(30)(C)(ii) and (F)) Section 322(b) of EISA 2007, in
amending EPCA to set forth revised standards for IRLs in new section
325(i)(1)(C), exempted from these standards the following categories of
IRLs: (1) lamps rated 50 W or less that are ER30, BR30, BR40, or ER40;
(2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20
IRLs rated 45 W or less. (42 U.S.C. 6295(i)(C)) DOE refers to these
three categories of lamps collectively as certain R, ER, and BR IRLs.
DOE has concluded, for the reasons that follow, that it has the
authority under EPCA to adopt standards for these R, ER, and BR IRLs,
and that these lamps are covered by the directive in 42 U.S.C.
6295(i)(3) to amend EPCA's standards for IRLs. First, by amending the
definition of ``incandescent reflector lamp'' (42 U.S.C.
6291(30)(C)(ii) and (F)), EISA 2007 effectively brought these R, ER,
and BR IRLs into the federal energy conservation standards program as
covered products, thereby subjecting them to DOE's regulatory
authority. Second, although 42 U.S.C. 6295(i)(1)(C) exempts these R,
ER, and BR IRLs from the standards specified in 42 U.S.C.
6295(i)(1)(B), EPCA directs that DOE amend the standards laid out in 42
U.S.C. 6295(i)(1), which includes subparagraph (C). As a result, the
statutory text exempted these bulbs only from the standards specified
in 42 U.S.C. 6295(i)(1), not from future regulation. Consequently, DOE
began considering energy conservation standards for these R, ER, and BR
IRLs. DOE initiated a new rulemaking for these products by completing a
framework document and publishing a notice announcing its availability.
75 FR 23191 (May 3, 2010). DOE held a public meeting on May 26, 2010 to
seek input from interested parties on its methodologies, assumptions,
and data sources.\9\
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\9\ DOE has suspended activity on this rulemaking as a result of
section 315 of Public Law (Pub. L.) 112-74 (Dec. 23, 2011), which
prohibits DOE from using appropriated funds to implement or enforce
standards for ER, BR, and bulged parabolic reflector IRLs.
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To initiate the second rulemaking cycle to consider amended energy
conservation standards for GSFLs and IRLs (other than the certain R,
ER, and BR IRLs discussed in the preceding paragraphs), on September
14, 2011, DOE published a notice announcing the availability of the
framework document, ``Energy Conservation Standards Rulemaking
Framework Document for General Service Fluorescent Lamps and
Incandescent Reflector Lamps,'' and a public meeting to discuss the
proposed analytical framework for the rulemaking. 76 FR 56678. DOE also
posted the framework document on its Web site, in which DOE described
the procedural and analytical approaches DOE anticipated using to
evaluate the establishment of energy conservation standards for GSFLs
and IRLs.
DOE held the public meeting for the framework document on October
4, 2011,\10\ to present the framework document, describe the analyses
it planned to conduct during the rulemaking, seek comments from
stakeholders on these subjects, and inform stakeholders about and
facilitate their involvement in the rulemaking. At the public meeting,
and during the comment period, DOE received many comments that both
addressed issues raised in the framework document and identified
additional issues relevant to this rulemaking.
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\10\ The framework document and public meeting information are
available at regulations.gov under docket number EERE-2011-BT-STD-
0006.
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DOE issued the preliminary analysis for this rulemaking on February
20, 2013 and published it in the Federal Register on February 28, 2013.
78 FR 13563 (February 28, 2013). DOE posted the preliminary analysis,
as well as the complete preliminary technical support document (TSD),
on its Web site.\11\ The preliminary TSD includes the results of the
following DOE preliminary analyses: (1) market and technology
assessment; (2) screening analysis; (3) engineering analysis; (4)
energy use characterization;
[[Page 24079]]
(5) product price determinations; (6) LCC and PBP analyses; (7)
shipments analysis; and (8) national impact analysis (NIA).
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\11\ The preliminary analysis, preliminary TSD, and preliminary
analysis public meeting information are available at regulations.gov
under docket number EERE-2011-BT-STD-0006.
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In the preliminary analysis, DOE described and sought comment on
the analytical framework, models, and tools (e.g., LCC and national
energy savings [NES] spreadsheets) DOE used to analyze the impacts of
energy conservation standards for GSFLs and IRLs. Specifically, DOE
invited comment on the following issues: (1) consideration of
additional GSFLs; (2) amended definitions; (3) market trends; (4)
technology options; (5) product classes; (6) market and technology
assessment methodology; (7) screening of design options; (8)
representative product classes; (9) baseline lamps; (10) more
efficacious substitutes; (11) lamp-and-ballast systems; (12) 4-foot T5
miniature bipin (MiniBP) HO model lamp; (13) candidate standard levels
(CSLs); (14) compliance requirements; (15) scaling to product classes
not analyzed; (16) engineering analysis methodology; (17) product price
determination; (18) GSFL ballast prices; (19) dimmed GSFL systems; (20)
lighting controls market penetration; (21) lighting controls
performance characteristics; (22) operating profiles for energy use
characterization; (23) residential GSFL LCC analysis; (24) sales tax in
the LCC analysis; (25) spacing adjustments in the LCC analysis; (26)
LCC analysis overall methodology and results; (27) T5s in the
residential market; (28) the shipments and national impact analyses;
(29) LCC subgroups; (30) small businesses that manufacture GSFLs and
IRLs; (31) manufacturer subgroup analysis; (32) key issues and data for
the manufacturer impact analysis (MIA); (33) valuing airborne emission
reductions; (34) data and programs for the regulatory impact analysis
(RIA); and (35) TSLs. (See executive summary and chapter 2 of the
preliminary TSD.)
DOE held a public meeting on April 9, 2013, to present the
methodologies and results for the preliminary analyses. Manufacturers,
trade associations, and environmental advocates attended the meeting.
The participants discussed multiple issues, including the methodology
and results of the market and technology assessment, screening
analysis, engineering analysis, product price determination, energy
use, LCC analysis, shipments analysis, and NIA. Other issues brought up
during the public meeting included regulatory authority and rulemaking
schedule. Finally, the MIA and additional analyses that are undertaken
during the NOPR stage were discussed. The comments received during the
public meeting, along with the written comments submitted to DOE since
publication of the preliminary analysis, have contributed to DOE's
proposed resolution of the issues in this rulemaking. This NOPR
responds to the issues raised in these public comments.
4. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with EPCA energy
conservation standards and to quantify the efficiency of their product.
Similarly, DOE uses the test procedure to determine compliance with
energy conservation standards. DOE's test procedures for fluorescent
and incandescent reflector lamps are set forth in title 10 of the CFR,
part 430, subpart B, appendix R. These test procedures provide
instructions for measuring GSFL and IRL performance, largely by
incorporating industry standards. The test procedures were updated in a
final rule published in July 2009. 74 FR 31829 (July 6, 2009). The rule
updated citations to industry standards and made several other
modifications. DOE further amended the test procedures to update
references to industry standards for GSFLs in a final rule published in
January 2012. 77 FR 4203 (January 27, 2012).
Standby and Off Mode Energy Consumption
EPCA requires energy conservation standards adopted for a covered
product after July 1, 2010 to address standby mode and off mode energy
use. (42 U.S.C. 6295(gg)(3)) EPCA defines active mode as the condition
in which an energy-using piece of equipment is connected to a main
power source, has been activated, and provides one or more main
functions. (42 U.S.C. 6295)(gg)(1)(A)) Standby mode is defined as the
condition in which an energy-using piece of equipment is connected to a
main power source and offers one or more of the following user-oriented
or protective functions: facilitating the activation or deactivation of
other functions (including active mode) by remote switch (including
remote control), internal sensor, or timer; or providing continuous
functions, including information or status displays (including clocks)
or sensor-based functions. Id. Off mode is defined as the condition in
which an energy-using piece of equipment is connected to a main power
source, and is not providing any standby or active mode function. Id.
To satisfy the EPCA definitions of standby mode and off mode (42
U.S.C. 6295(gg)(1)), the lamp must not be providing any active mode
function (i.e., emitting light). However, to reach such a state, the
lamp must be entirely disconnected from the main power source (i.e.,
switched off), thereby not satisfying the requirements of operating in
off mode or standby mode. Further, neither GSFLs nor IRLs covered under
this rulemaking provide any secondary user-oriented or protection
functions or continuous standby mode functions. Thus, these lamps do
not satisfy the EPCA definition of standby mode. While EPCA allows DOE
to amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes
that the energy use of GSFLs and IRLs is accounted for entirely in the
active mode. Therefore, DOE is not addressing lamp operation in the
standby and off modes in this rulemaking.
III. General Discussion
A. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that
justifies a different standard. In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility to the consumer of the feature and
other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For
further details on the scope of coverage for this rulemaking, see
section V. For further details on product classes, see section VI.C and
chapter 3 of the NOPR TSD.
B. Technological Feasibility
1. General
In each standards rulemaking, DOE conducts a screening analysis
based on information gathered on all current technology options and
prototype designs that could improve the efficiency of the products or
equipment that are the subject of the rulemaking. As the first step in
such an analysis, DOE develops a list of technology options for
consideration in consultation with manufacturers, design engineers, and
other interested parties. DOE then determines which of those means for
improving efficiency are technologically feasible. DOE considers
technologies incorporated in commercially available products or in
working prototypes to be
[[Page 24080]]
technologically feasible. 10 CFR 430, subpart C, appendix A, section
4(a)(4)(i)
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
practicability to manufacture, install, or service; (2) adverse impacts
on product utility or availability; and (3) adverse impacts on health
or safety. Section VI.B of this notice discusses the results of the
screening analysis for GSFLs and IRLs, particularly the designs DOE
considered, those it screened out, and those that are the basis for the
TSLs in this rulemaking. For further details on the screening analysis
for this rulemaking, see chapter 4 of the NOPR TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max tech'') improvements in energy efficiency for GSFLs and
IRLs, using the design parameters for the most efficient products
available on the market or in working prototypes. (See chapter 5 of the
NOPR TSD.) The max tech levels that DOE determined for this rulemaking
are described in section VI.D.2.f for GFSLs and VI.D.3.e for IRLs of
this proposed rule.
C. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that
are the subject of this rulemaking purchased in the 30-year period that
begins in the year of compliance with any amended standards (2017-
2046). The savings are measured over the entire lifetime of products
purchased in the 30-year period.\12\ DOE quantified the energy savings
attributable to each TSL as the difference in energy consumption
between each standards case and the base case. The base case represents
a projection of energy consumption in the absence of amended mandatory
efficiency standards, and considers market forces and policies that
affect demand for more efficient products.
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\12\ DOE previously presented energy savings results for the 30-
year period that begins in the year of compliance. In the
calculation of economic impacts, however, DOE considered operating
cost savings measured over the entire lifetime of products purchased
in the 30-year period. DOE has modified its presentation of NES to
be consistent with the approach used for its national economic
analysis.
---------------------------------------------------------------------------
DOE used its NIA spreadsheet model to estimate energy savings from
amended standards for the products that are the subject of this
rulemaking. The NIA spreadsheet model (described in section VI.J of
this notice) calculates energy savings in site energy, which is the
energy directly consumed by products at the locations where they are
used. For electricity, DOE reports NES in terms of the savings in the
energy that is used to generate and transmit the site electricity. To
calculate this quantity, DOE derives annual conversion factors from the
model used to prepare the U.S. Energy Information Administration's
(EIA's) Annual Energy Outlook (AEO).
DOE also estimates full-fuel-cycle (FFC) energy savings. 76 FR
51282 (Aug. 18, 2011), as amended at 77 FR 49701 (August 17, 2012). The
FFC metric includes the energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas, petroleum fuels),
and thus presents a more complete picture of the impacts of energy
efficiency standards. DOE's approach is based on calculation of an FFC
multiplier for each of the energy types used by covered products. For
more information on FFC energy savings, see section VI.J.
2. Significance of Savings
As noted above, 42 U.S.C. 6295(o)(3)(B) prevents DOE from adopting
a standard for a covered product unless such standard would result in
``significant'' energy savings. Although the term ``significant'' is
not defined in the Act, the U.S. Court of Appeals, in Natural Resources
Defense Council v. Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985),
indicated that Congress intended ``significant'' energy savings in this
context to be savings that were not ``genuinely trivial.'' The energy
savings for all of the TSLs considered in this rulemaking (presented in
section VII.A) are nontrivial, and, therefore, DOE considers them
``significant'' within the meaning of section 325 of EPCA.
D. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether
a potential energy conservation standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has
addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of an amended standard on manufacturers,
DOE first uses an annual cash-flow approach to determine the
quantitative impacts. This step includes both a short-term assessment--
based on the cost and capital requirements during the period between
when a regulation is issued and when entities must comply with the
regulation--and a long-term assessment over a 30-year period. The
industry-wide impacts analyzed include INPV, which values the industry
on the basis of expected future cash flows; cash flows by year; changes
in revenue and income; and other measures of impact, as appropriate.
Second, DOE analyzes and reports the impacts on different types of
manufacturers, including impacts on small manufacturers. Third, DOE
considers the impact of standards on domestic manufacturer employment
and manufacturing capacity, as well as the potential for standards to
result in plant closures and loss of capital investment. Finally, DOE
takes into account cumulative impacts of various DOE regulations and
other regulatory requirements on manufacturers. For this rulemaking,
these impacts include those resulting from the 2009 Lamps Rule.
For individual consumers, measures of economic impact include the
changes in LCC and PBP associated with new or amended standards. These
measures are discussed further in the following section. For consumers
in the aggregate, DOE also calculates the national NPV of the economic
impacts applicable to a particular rulemaking. DOE also evaluates the
LCC impacts of potential standards on identifiable subgroups of
consumers that may be affected disproportionately by a national
standard.
b. Savings in Operating Costs Compared to Increase in Price
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product compared
to any increase in the price of the covered product that is likely to
result from the imposition of the standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis. The LCC is the sum of the purchase price of a product
(including its installation) and the operating expense (including
energy, maintenance, and repair expenditures) discounted over the
lifetime of the product. To account for uncertainty and variability in
specific inputs, such as product lifetime and discount rate, DOE uses a
[[Page 24081]]
distribution of values, with probabilities attached to each value. For
its analysis, DOE assumes that consumers will purchase the covered
products in the first year of compliance with amended standards.
The LCC savings and the PBP for the considered efficacy levels
(ELs) are calculated relative to a base case that reflects projected
market trends in the absence of amended standards. DOE identifies the
percentage of consumers estimated to receive LCC savings or experience
an LCC increase, in addition to the average LCC savings associated with
a particular standard level.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for imposing an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section VI.J, DOE uses the NIA spreadsheet to project NES.
d. Lessening of Utility or Performance of Products
In establishing classes of products, and in evaluating design
options and the impact of potential standard levels, DOE evaluates
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) The standards
proposed in today's notice will not reduce the utility or performance
of the products under consideration in this rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from the imposition of a standard. (42 U.S.C.
6295(o)(2)(B)(i)(V) It also directs the Attorney General to determine
the impact, if any, of any lessening of competition likely to result
from a proposed standard and to transmit such determination to the
Secretary, together with an analysis of the nature and extent of the
impact. (42 U.S.C. 6295(o)(2) (B)(ii)) DOE will transmit a copy of
today's proposed rule to the Attorney General with a request that the
U.S. Department of Justice (DOJ) provide its determination on this
issue. DOE will address the Attorney General's determination in the
final rule.
f. Need for National Energy Conservation
The energy savings from the proposed standards are likely to
provide improvements to the security and reliability of the nation's
energy system. Reductions in the demand for electricity also may result
in reduced costs for maintaining the reliability of the nation's
electricity system. DOE conducts a utility impact analysis to estimate
how standards may affect the nation's needed power generation capacity.
The proposed standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases (GHGs) associated with energy production. DOE reports
the emissions impacts from today's standards, and from each TSL it
considered, in section VI.L of this notice. DOE also reports estimates
of the economic value of emissions reductions resulting from the
considered TSLs.
g. Other Factors
EPCA allows the Secretary, in determining whether a standard is
economically justified, to consider any other factors that the
Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effects that proposed
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable presumption payback calculation
is discussed in section III.D of this proposed rule.
IV. Issues Affecting Rulemaking Schedule
In the schedule presented in the framework document of this
rulemaking, the preliminary analysis was scheduled to be published in
September 2012, the NOPR in August 2013, and the final rule
establishing any amended standards in 2014. During the framework stage,
stakeholders expressed concerns that because the 2009 Lamps Rule
standards would require compliance July 14, 2012, the preliminary
analysis published in September 2012 would not be able to account for
the impacts of the July 2012 standards. DOE noted these concerns and
extended the schedule, publishing the preliminary analysis in February
2013. DOE received additional comments regarding the timing of this
rulemaking in the preliminary analysis phase.
Philips questioned whether this rulemaking is statutorily required
to be completed at this time, specifically asking if EPAct 1992
provided a date by which the final rule of the second cycle of energy
conservation standards for GSFLs and IRLs has to be published.
(Philips, Public Meeting Transcript, No. 30 at pp. 27-28)
In a Joint Comment, the Appliance Standards Awareness Project
(ASAP), the Natural Resources Defense Council (NRDC), the Alliance to
Save Energy, the American Council for an Energy-Efficient Economy
(ACEEE), the Consumer Federation of America, and the National Consumer
Law Center, (hereafter the ``Joint Comment'') and Northeast Energy
Efficiency Partnerships (NEEP) emphasized that EPAct 1992 requires DOE
to complete two rounds of rulemakings for IRLs and GSFLs. The Joint
Comment noted that final rule of the first cycle was required to be
published by April 1997. (42 U.S.C. 6295(i)(3)) DOE was required to
publish the final rule of the second cycle five years later. (42 U.S.C.
6295(i)(4)) NEEP and the Joint Comment stated that as DOE failed to
publish a final rule for the first cycle until July 2009, it is not
possible for DOE to meet the required deadline date for the second
cycle. Therefore, NEEP and the Joint Comment agreed that the second
cycle should occur within the interval contemplated by Congress when it
set out the original deadlines, and a final rule should be issued no
later than 2014. (NEEP, No. 33 at p. 1; Joint Comment, No. 35 at pp. 1-
2) ASAP agreed stating that given that the 2009 Lamps Rule was
complete, it was not
[[Page 24082]]
discretionary for DOE to have any other schedule than the one currently
in place for this rulemaking. (ASAP, Public Meeting Transcript, No. 30
at pp. 192-193)
General Electric (GE) stated its concern that this rulemaking is
occurring too soon after the 2009 Lamps Rule, making it difficult for
manufacturers to recover investments in new technologies or to develop
products meeting even higher standards. GE indicated that the close
proximity of the rulemakings will have a severe and negative impact on
manufacturers. (GE, Public Meeting Transcript, No. 30 at p. 192)
National Electrical Manufacturers Association (NEMA) noted that for
certain GSFL product classes, Office of Hearing and Appeals (OHA)
issued waivers providing a stay of enforcement for many manufacturers
due to the limited availability of rare earth phosphors. NEMA pointed
out that as a result, the July 2012 standards still have not been fully
implemented. (Philips, Public Meeting Transcript, No. 30 at pp. 27-28;
NEMA, No. 36 at p. 1) Therefore, NEMA stated that the market has not
fully shifted to reflect the impacts of the July 2012 standards and
there is little to no accurate information available regarding future
market shares and technology capability. Hence, NEMA concluded that as
it is too soon after the 2009 Lamps Rule to set new energy conservation
standards, DOE and the Secretary should declare no new standard in this
rulemaking. (NEMA, No. 36 at p. 1) Further, NEMA called attention to
DOE's newer authority to review energy conservation standards six years
after a final rule is published. NEMA found that this review will
provide an opportunity to better assess standards for GSFLs and IRLs.
(NEMA, No. 36 at pp. 1-2)
The California investor-owned utilities, including Pacific Gas and
Electric Company (PG&E), Southern California Gas Company (SCGC), San
Diego Gas and Electric (SDG&E), and Southern California Edison (SCE),
(hereafter the ``CA IOUs'') approved of the current timeline for this
rulemaking. They commented that because DOE waited until after the July
2012 standards required compliance before completing the preliminary
analysis and due to the amount of time before standards promulgated by
this rulemaking would require compliance, now is the correct time to
proceed with the second cycle of energy conservation standards for
these products. (CA IOUs, Public Meeting Transcript, No. 30 at pp. 30-
31)
The Joint Comment emphasized the significance of this rulemaking as
a reason to proceed within the five-year timeframe. They stated that
according to the 2010 U.S. Lighting Market Characterization (2010
LMC),\13\ the U.S. inventory of installed IRLs was estimated to be in
excess of 641 million lamps, representing almost 8 percent of the total
installed lighting base, consuming an estimated 39 terawatt hours (TWh)
annually. The 2010 LMC estimated an inventory of nearly 2.4 billion
GSFLs, representing 29 percent of the total installed base, consuming
approximately 294 TWh annually. While the Joint Comment recognized that
these numbers will likely begin to decrease over time with the
increased prevalence of light-emitting diode (LED) alternatives, they
noted that IRLs and GSFLs will still likely command a significant
portion of the lighting market for decades to come, as a perceived
cheaper alternative to LEDs. Due to this and the findings of the
preliminary analysis that this rulemaking offers the potential for
significant, cost-effective savings for U.S. consumers and businesses,
the Joint Comment urged DOE to place this rulemaking's completion as a
high priority. (Joint Comment, No. 35 at p. 2)
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\13\ U.S. Department of Energy. 2010 U.S. Lighting Market
Characterization. January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
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DOE is obligated to conduct this second review of GSFL and IRL
standards. EPCA required DOE to initiate the first review of standards
no earlier than three years after October 24, 1992, and publish a final
rule no later than four years and six months after that date. 42 U.S.C.
6295(i)(3) The second review of standards was to be initiated no
earlier than eight years after October 24, 1992, and the final rule
published no later than nine years and six months after that date. 42
U.S.C. 6295(i)(4) DOE published the final rule for the first review of
standards in July 2009. DOE is conducting this rulemaking to satisfy
the EPCA requirement for a second review of the standards. Applying the
schedule DOE developed for the second review of standards would result
in an interval of five years between the publications of the final
rules for the first and second review of standards, and any final rule
for this rulemaking would be published in 2014.
To address comments that product availability, product pricing, and
investment decisions in response to the July 2012 standards would not
be finalized within the proposed scheduled, DOE delayed the publication
of the preliminary analysis to update its product databases and
assessments based on changes that took place after the compliance date
on July 14, 2012. Additionally, for the preliminary analysis stage, DOE
obtained information during interviews with manufacturers regarding new
product lines they were preparing to launch to ensure that DOE's
analysis captured the initial market impacts of the July 2012
standards. The analysis presented in this NOPR was updated and
finalized more than a year after the July 2012 standards required
compliance, reflecting the most recent data available. Further, in
manufacturer interviews conducted for this NOPR, DOE learned that most
manufacturers were not planning to introduce any additional covered
products to market. Therefore, DOE believes that the revised schedule
for this GSFL and IRL rulemaking has allowed the preliminary analysis
and NOPR analysis to be conducted so as to have adequately captured the
impacts of the July 2012 standards for these products. Any additional
data received will be considered in the development of any final rule.
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
The scope of this rulemaking for GSFLs is defined by the terms
``fluorescent lamp'' and ``general service fluorescent lamp.'' 10 CFR
430.2 The definition of general service fluorescent lamp includes
certain exemptions. DOE has received several questions on the
application of these exemptions. Therefore, in the preliminary analysis
DOE evaluated each exemption and determined that the following
exemption categories could be further clarified: ``impact-resistant
fluorescent lamps,'' ``reflectorized or aperture lamps,'' ``fluorescent
lamps designed for use in reprographic equipment,'' and ``lamps
primarily designed to produce radiation in the ultra-violet region of
the spectrum.'' For these exemption categories, the terminology was
either not defined elsewhere or the application of the exemption could
be further clarified. DOE examined product literature and industry
reference sources to determine language that would further explain
these exemptions. DOE determined that the exemptions should be
clarified as follows:
Impact-resistant fluorescent lamp means a lamp that:
a. Has a coating or equivalent technology that is compliant with
NSF/ANSI 51 (incorporated by reference; see Sec. 430.3) and designed
to contain the glass if the glass envelope of the lamp is broken; and
[[Page 24083]]
b. Is designated and marketed for the intended application, with:
i. The designation on the lamp packaging; and
ii. Marketing materials that identify the lamp as being impact-
resistant, shatter-resistant, shatter-proof, or shatter-protected.
Reflectorized or aperture lamp means a fluorescent lamp that
contains an inner reflective coating on the bulb to direct light.
Fluorescent lamp designed for use in reprographic equipment means a
fluorescent lamp intended for use in equipment used to reproduce,
reprint, or copy graphic material.
Lamps primarily designed to produce radiation in the ultra-violet
region of the spectrum mean fluorescent lamps that primarily emit light
in the portion of the electromagnetic spectrum where light has a
wavelength between 10 and 400 nanometers.
In the preliminary analysis, DOE also considered clarifications of
the terms ``designed'' and ``marketed'' as applied to definitions of
lighting products covered under DOE standards. These terms are
generally used to ensure that exemptions from applicable standards
apply only to lamps used in certain intended applications and/or
functions. Therefore, DOE considered the terms ``designed,''
``designated,'' ``designation,'' ``designated and marketed,'' and
``designed and marketed,'' for covered lighting products to mean that
manufacturers explicitly state the intended application of the lamp in
a publicly available document (e.g., product literature, catalogs,
packaging labels, and labels on the product itself).
NEMA agreed with the proposed clarifications to definitions for
GSFLs. (NEMA, Public Meeting Transcript, No. 30 at p. 45; NEMA, No. 36
at pp. 4-5) NEMA noted that the definitions have been in use since the
early 1990s and are well understood within the industry; the additional
clarification suggested is in line with current industry practice. NEMA
stated that no further definitions are required beyond this
clarification. (NEMA, No. 36 at pp. 4-5)
The CA IOUs agreed that DOE should clearly define the lamp types
exempted from standards. Specifically, the CA IOUs recommended further
clarifying the definition for fluorescent lamps ``designed for cold
temperature applications.'' (CA IOUs, Public Meeting Transcript, No. 30
at pp. 31-32; CA IOUs, No. 32 at p. 12) The CA IOUs expressed concern
that that many common GSFLs are currently being designed with amalgam
to be operated in lower temperatures, but without a negative effect on
the lamps' efficacy and not intended to be exempt from standards. The
CA IOUs stated their understanding that the exemption for cold
temperature lamps has been preserved to accommodate uncommon lamps
designed to be used outdoors in extreme, sub-freezing temperatures that
cannot meet the efficacy requirements established for GSFLs. (CA IOUs,
No. 32 at p. 12)
The Northwest Energy Efficiency Alliance (NEEA) and Northwest Power
and Conservation Council (NPCC) agreed with the CA IOUs and found the
descriptor ``designed for cold temperature applications'' to be too
vague to adequately differentiate between products that are covered
currently and those that have design features that make it impossible
for them to meet the standards. NEEA and NPCC commented that this lack
of clarity seems to create a significant loophole. (NEEA and NPCC, No.
34 at p. 3) In addition to clearly defining the exempt cold temperature
lamps, the CA IOUs asked DOE to revisit the market share and
performance of these lamps to confirm that they do in fact justify an
exemption. (CA IOUs, No. 32 at p. 12)
The exemption for cold temperature lamps is stated in the CFR as
``Fluorescent lamps specifically designed for cold temperature
applications.'' Further the CFR provides a definition for ``cold
temperature fluorescent lamp'' stated as follows:
Cold temperature fluorescent lamp means a fluorescent lamp
specifically designed to start at -20[emsp14][deg]F when used with a
ballast conforming to the requirements of American National Standards
Institute (ANSI) C78.81 (incorporated by reference; see Sec. 430.3)
and ANSI C78.901 (incorporated by reference; see Sec. 430.3), and is
expressly designated as a cold temperature lamp both in markings on the
lamp and in marketing materials, including catalogs, sales literature,
and promotional material. 10 CFR 430.2
Cold weather starting is accomplished through both the lamp and
ballast design. Product literature indicates that cold temperature
fluorescent lamps paired with the appropriate ballast can be started at
temperatures as low as -20[emsp14][deg]F. Therefore, the existing
definition, which includes the specific starting temperature and the
requirement of being marketed and designed for cold temperature
applications, is a sufficient description of fluorescent lamps designed
to be operated in cold temperatures. Additionally, product offerings of
cold temperature fluorescent lamps remain limited, indicating their
specialty use. Hence, DOE is not proposing any further clarification
for the exemption category of fluorescent lamps designed for cold
temperature applications.
DOE did not receive any further comment on definitions considered
in the preliminary analysis. In this NOPR, DOE is also considering
providing a definition for 700 series fluorescent lamps. OHA has
granted several manufacturers waivers from standards for their 700
series T8 products. (See section VI.D.2.a for further discussion
regarding OHA waivers.) A definition for 700 series lamps would provide
clarification regarding these lamp types.
The term ``700 series'' is widely used in industry when referring
to fluorescent lamps with a CRI in the range of 70 to 79. The
Illuminating Engineering Society of North America (IESNA) Lighting
Handbook \14\ presents fluorescent lamp nomenclature and states that
color is represented by a three digit number (i.e., 735 or 835)
beginning with the first digit of the lamp's CRI (i.e., 7 or 8) and
followed by the first two digits of the lamp's correlated color
temperature (CCT) (e.g., 30, 35, 41). DOE explained this nomenclature
in chapter 3 of the 2009 Lamps Rule TSD,\15\ stating that typically
lamps with a CRI in the 60s use only less efficient halophosphors,
while lamps with a CRI in the 70s (700 series phosphor) and in the 80s
(800 series phosphor) use more efficient rare earth phosphors. The DOE
test procedure at 10 CFR part 430, subpart B, appendix R requires CRI
to be measured and reported to demonstrate compliance with standards.
Thus, the measured CRI of a lamp is used to determine if the lamp
qualifies as a 700 series lamp. Hence DOE is proposing to define 700
series fluorescent lamps to mean a fluorescent lamp with a CRI that is
in the range of 70 to 79.
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\14\ DiLaura, D. L., K. W. Houser, R. G. Mistrick, and G. R.
Steffy. Lighting Handbook: Reference and Application, 10th Edition.
New York: IESNA, 2011.
\15\ The 2009 Lamps Rule TSD is available at
www.regulations.gov/#!documentDetail;D=EERE-2006-STD-0131-0147.
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In this NOPR, DOE is proposing the definitions as previously
specified in this section and in the preliminary analysis for ``impact-
resistant fluorescent lamps,'' ``reflectorized or aperture lamps,''
``fluorescent lamps designed for use in reprographic equipment,'' and
``lamps primarily designed to produce radiation in the ultra-violet
region of the spectrum.'' DOE is also proposing a definition of
``designed and marketed.'' This definition is intended to apply to the
use of these and similar terms (i.e., designated or labeled) in any
[[Page 24084]]
grammatical form or combination. In addition, DOE is proposing a
definition for ``700 series fluorescent lamp.''
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
In this rulemaking, DOE evaluates energy efficiency standards for
additional GSFLs beyond those for which standards have already been
established. (42 U.S.C. 6295(i)(5)) Any additional GSFLs considered for
coverage under standards must meet the definition of a fluorescent lamp
in 42 U.S.C. 6291(30)(A); satisfy the majority of fluorescent lighting
applications; not be within the exclusions specified in 42 U.S.C.
6291(30)(B); and not already be subject to energy conservation
standards. 73 FR 13620, 13629 (March 13, 2008). For each additional
GSFLs that meets these criteria, DOE then assesses whether standards
could result in significant energy savings and are technologically
feasible and economically justified. Standards for any applicable
additional GSFLs are adopted based on the same criteria used to set new
or amended standards for products pursuant to 42 U.S.C. 6295(o).
Using these criteria, DOE evaluated whether the following GSFL
types warranted coverage under standards: (1) pin base compact
fluorescent lamps (CFLs); (2) non-linear fluorescent lamps (e.g.,
circline); and (3) fluorescent lamps with alternate lengths (e.g., 2-,
3-, and 5-foot lamps).
For pin base CFLs, DOE determined that these lamp types fall within
the definition of ``general service lamps,'' which excludes GSFLs. (42
U.S.C. 6291(30)(BB)) Therefore, these lamp types cannot be considered
under this rulemaking. DOE is evaluating these lamp types in the
rulemaking for general service lamps. Documents related to this
rulemaking can be found on regulations.gov, docket number EERE-2013-BT-
STD-0051.
For non-linear fluorescent lamps, DOE considered circline
fluorescent lamps, the primary shape not currently covered under
standards. DOE used the miscellaneous category of fluorescent lamps
reported by the 2010 LMC to determine market share and energy
consumption of circline fluorescent lamps. This category included
fluorescent lamps other than the T5, T8, T12 linear lamps, and T8 and
T12 U-shaped lamps, and is therefore mainly comprised of circline lamps
and lamps with unknown characteristics. The 2010 LMC reported this
category made up 2.1 percent of lighting and consumed 4 TWh of
electricity in 2010. Interviews with manufacturers also confirmed the
low market share of these lamp types. Therefore, DOE tentatively
concluded that coverage should not be expanded to non-linear
fluorescent lamps as standards would not likely result in significant
energy savings.
For linear lengths not already covered by standards, DOE focused on
linear medium bipin (MBP) fluorescent lamps ranging from 1 to 6 feet,
with the exception of the 4-foot MBP, which is already subject to
standards. DOE's analysis showed that 5- and 6-foot lengths comprise a
very low percentage of the linear MBP product offerings. For the T8
\16\ MBP lamps with lengths less than 4 feet, according to the 2010
LMC, these lamps comprised about 0.2 percent of all installed lighting
and consumed 1 TWh of electricity in 2010. Feedback from manufacturers
also indicated a low market share for these lamp types. Therefore, DOE
tentatively concluded that coverage should not be expanded to linear
fluorescents of lengths not covered by standards as standards would not
likely result in significant energy savings.
---------------------------------------------------------------------------
\16\ The majority of T12 MBP lamps with lengths less than 4 feet
do not comply with the July 2012 standards.
---------------------------------------------------------------------------
DOE received several comments on its assessment not to extend
coverage to linear fluorescent lamps of lengths not already covered. In
particular, several stakeholders asserted that the 2-foot linear
fluorescent lamps comprised a market share that warranted coverage
under standards. The CA IOUs urged DOE to reassess the 2-foot linear
fluorescent lamp market share and recommended that they be included in
the scope of coverage of this rulemaking. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 32-33; CA IOUs, No. 32 at pp. 11-12) NEEA and
NPCC advised that 2-foot linear fluorescent lamps be included under
scope of coverage and in their own product class, if appropriate. (NEEA
and NPCC, No. 34 at pp. 2-3) Specifically, the CA IOUs asserted that
DOE should have considered the proportion of GSFL market share that
these lamps represent and also included T12 lamps in its assessment, as
these lamps would be covered by standards for 2-foot linear lamps. (CA
IOUs, No. 32 at pp. 11-12)
In assessing whether additional GSFL types should be included under
coverage of standards in the preliminary analysis, DOE evaluated the
market share and energy consumption of the lamp type relative to the
entire lighting market. DOE's analysis provided a comprehensive
representation of the lamp type and the energy savings potential of
standards for the lamp type. In the NOPR, DOE also evaluated market
share relative to the entire fluorescent lamp market. Based on the 2010
LMC, T8 MBP lamps less than 4 feet comprised 0.7 percent of the
fluorescent lamp market versus 0.2 percent of the entire lighting
market. Therefore, the evaluation of these lamps relative to the
fluorescent lamp market also indicates that 2-foot MBP linear lamps
have a very low market share.
DOE excluded T12 lamps from this analysis to reflect future market
trends. The 2011 final rule amending energy conservation standards for
fluorescent lamp ballasts (hereafter the ``2011 Ballast Rule''), which
will require compliance on November 14, 2014, set standards difficult
for T12 ballasts to meet.\17\ 76 FR 70548 (Nov. 14, 2011). Therefore,
the market will likely shift away from T12 lamps. Additionally,
historical shipments of most T12 lamps have been decreasing steadily
and manufacturer feedback from interviews suggests that this trend will
continue. Therefore, DOE focused on T8 lamps when evaluating the energy
savings of additional GSFL types to include under coverage of
standards.
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\17\ The full text and all related documents of the 2011 Ballast
Rule can be found on regulations.gov, docket number EERE-2007-BT-
STD-0016 at www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-
0016.
---------------------------------------------------------------------------
The CA IOUs also asserted that in the 2010 LMC, T8 and T12 lamps
less than 4 feet have GSFL market shares very similar to the market
shares for three other product types currently subject to DOE
standards: T8 lamps greater than 4 feet (1.4 percent of the linear
fluorescent market), T8 U-shaped lamps (2 percent of the linear
fluorescent market), and T12 U-shaped lamps (0.5 percent of the linear
fluorescent market). (CA IOUs, No. 32 at pp. 11-12; NEEA and NPCC, No.
34 at pp. 2-3)
The standards for GSFL types cited by the CA IOUs, specifically,
the 2-foot U-shaped lamps, 8-foot SP slimline lamps, and 8-foot
recessed double contact (RDC) HO lamps, were established in EPAct 1992.
(42 U.S.C. 6295(i)(1)) As noted, for this rulemaking, in determining
whether additional GSFL types should be covered under standards
pursuant to 42 U.S.C. 6295(i)(5) DOE considers several criteria. In
particular, DOE assesses whether a potential standard for an additional
GSFL type would result in significant energy savings. Therefore, DOE
examined parameters such as market share and energy consumption of each
lamp type under consideration relative to the fluorescent lighting
[[Page 24085]]
market. DOE believes that this evaluation of each potential additional
GSFL provides the most useful indication of whether significant energy
savings could be gained from regulation of the lamp type.
Stakeholders also cited data sources in addition to the 2010 LMC
indicating that 2-foot linear lamps should be included under coverage
of standards. The CA IOUs asserted that an anecdotal survey from their
lighting audit teams suggest 2-foot linear lamps may be 5 to 10 percent
of lamps installed in the CA IOUs' service territory, which is higher
than suggested by the 2010 LMC. The CA IOUs also reported that the vast
majority of commercial buildings in California have some two-by-two
fixtures, and many of these have been retrofitted from U-shaped to 2-
foot linear lamps within the last several years, indicating a growing
trend toward 2-foot linear lamps over U-shaped lamps. (CA IOUs, Public
Meeting Transcript, No. 30 at pp. 32-34; CA IOUs, No. 32 at pp. 11-12)
NEEA and NPCC stated that they would submit field data to DOE and
asserted that currently available data indicates 2-foot linear GSFLs
make up a notably larger fraction of the market than the preliminary
analysis suggests. (NEEA and NPCC, No. 34 at pp. 2-3)
The CA IOUs and NEEA and NPCC referred to a Navigant Consulting,
Inc. (Navigant) study published in October 2012 that surveyed existing
commercial and industrial building stock in Vermont, the 2011 Vermont
Market Characterization and Assessment Study.\18\ The raw data from the
Navigant study, obtained in May 2013 from the state of Vermont by NEEP,
shows that of more than 136,000 lamps surveyed, 2-foot lamps
represented 6.3 percent of installed fluorescent lamps. This included
3.6 percent of high performance T8s, 9.3 percent of standard efficiency
T8s, 3.9 percent of T12s, and 5.2 percent of T5s. Behind 4-foot lamps,
2-foot lamps were by far the most common lamp length in these sectors.
The CA IOUs stated that 6.3 percent of fluorescent lamp sales represent
a significant amount of energy and, as explained in previous comments
submitted by the CA IOUs, 2-foot lamps are available in a wide range of
efficacies. (CA IOUs, No. 32 at pp. 11-12; NEEA and NPCC, No. 34 at pp.
2-3)
---------------------------------------------------------------------------
\18\ Navigant Consulting, Inc. 2011 Vermont Market
Characterization and Assessment Study. October 2012. Available at
http://publicservice.vermont.gov/sites/psd/files/Topics/Energy_Efficiency/EVT_Performance_Eval/VT%20CI%20Existing%20Buildings%20Market%20Assessment%20and%20Characterization_2012-10-6_FINAL.pdf
---------------------------------------------------------------------------
NEMA, however, stated that the 2010 LMC showed a low market share
\19\ for these products, which does not justify standards for these
lamps. (NEMA, No. 36 at p. 4) Edison Electric Institute (EEI) stated
its belief that 2-foot linear lamps were mainly installed in task
lighting applications. (EEI, Public Meeting Transcript, No. 30 at p.
34) GE advised that 2-foot linear lamps should not be included in the
scope of this rulemaking. While installing these lamps may be customary
in California, GE stated that they are not very common across the
nation. Further, GE commented that DOE had received shipment data in
preliminary manufacturer interviews that showed the sales of 2-foot
straight lamps to be significantly less than the sales of 4-foot lamps.
(GE, Public Meeting Transcript, No. 30 at pp. 35-36) ASAP requested DOE
make the shipment data publicly available so stakeholders could
determine the significance. (ASAP, Public Meeting Transcript, No. 30 at
pp. 36-39)
---------------------------------------------------------------------------
\19\ DOE's assessment indicated that the T8 MBP lamps less than
4 feet comprised 0.2 percent of the entire lighting market. NEMA's
written comment had incorrectly quoted this number as 0.02 percent.
---------------------------------------------------------------------------
DOE did not receive shipment data specifically for 2-foot linear
lamps and based its assessment of market share and energy consumption
provided in the 2010 LMC report and feedback received in manufacturer
interviews. The anecdotal survey and the Vermont study cited by the CA
IOUs are focused on very specific areas of the nation, while the 2010
LMC is the most recent assessment of installed stock and energy use of
fluorescent lighting at the national level. The Vermont study collected
primary data through on-site visits from a random selection of 120
commercial and industrial buildings in specific regions in Vermont.
Therefore, DOE found the 2010 LMC provided a more comprehensive basis
for its assessment. A comparison of the installed stock provided in the
2000 LMC report \20\ and the 2010 LMC report shows that installed stock
for both T8 and T12 lamps less than 4 feet has declined by about 50
percent over that 10-year period. DOE also received feedback from
manufacturers in interviews stating that 2-foot linear lamps, both in
the MBP and MiniBP categories, comprise a low market share that will
either stay the same or decline. Further, manufacturers noted in
interviews that the 2-foot linear lamps are generally used for
kitchens, bathrooms, vanity lighting, hospitality applications,
cabinets, and to round out edges of ceilings in commercial spaces.
---------------------------------------------------------------------------
\20\ U.S. Department of Energy. U.S. Lighting Market
Characterization Volume I: National Lighting Inventory and Energy
Consumption Estimate. September 2002. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/lmc_vol1_final.pdf.
---------------------------------------------------------------------------
Given the above, DOE finds insufficient evidence to indicate that
the market share or energy consumption of 2-foot linear fluorescent
lamps would result in significant energy savings if DOE established
standards for these lamps. DOE is not proposing standards for any
additional GSFL types that are not currently covered.
2. Additional General Service Fluorescent Lamp Wattages
DOE specifies a certain minimum wattage for each lamp type included
in the definition of ``fluorescent lamp.'' In this rulemaking, DOE also
evaluates whether coverage should be extended to additional wattages of
these lamp types. (42 U.S.C. 6295(i)(5)) As part of this assessment,
DOE reviewed product offerings for covered lamp types to determine if
any new, lower wattage products had been introduced since publication
of the 2009 Lamps Rule. DOE found the following reduced wattage lamps
not covered under standards: 49 W, 50 W, 51 W 8-foot SP slimline, 25 W
4-foot T5 MiniBP standard output (SO), and 44 W, 47 W 4-foot T5 MiniBP
HO lamps. DOE currently covers 8-foot SP slimline lamps with wattages
of 52 W or more; 4-foot T5 MiniBP SO lamps with wattages of 26 W or
more; and 4-foot T5 MiniBP HO lamps with wattages of 49 W or more.
Therefore, in the preliminary analysis, DOE considered extending
coverage to the following GSFLs:
8-foot SP slimline lamps with wattages >=49 W and <52 W;
4-foot T5 MiniBP SO lamps with wattages >=25 W and <26 W;
and
4-foot T5 MiniBP HO lamps with wattages >=44 W and <49 W.
These reduced wattage lamps are generally more efficacious than their
full wattage counterparts and offer the potential for increased energy
savings.
Philips commented that if a product is already highly efficacious,
DOE does not need to consider standards for the product. (Philips,
Public Meeting Transcript, No. 30 at pp. 44-45)
The emergence of these new reduced wattage lamps on the market
since the 2009 Lamps Rule and the number of product offerings indicate
that there is significant consumer demand for these lamps. Further,
because reduced wattage lamps are often incentivized by utilities and
promoted as an easy
[[Page 24086]]
pathway to energy savings, they are likely to increase in market share.
DOE's review of product catalogs indicated that lamps with these
wattages generally have a range of efficacies. The lower wattages of
these lamps and their potential to achieve higher efficacies indicate
that including these wattages under energy conservation standards have
the potential to realize significant energy savings.
NEMA agreed with expanding the GSFL wattages covered by this
rulemaking, but cautioned DOE that reduced wattage GSFLs are often
``energy saver'' models. These lamps do not have the same performance
as full wattage GSFLs. Specifically, NEMA stated that reduced wattage
GSFLs have difficulty operating in low-temperature applications and do
not have full dimming functionality, a performance feature that is
highly desired considering the proliferation of dimming systems. (NEMA,
Public Meeting Transcript, No. 30 at pp. 23-24; NEMA, No. 36 at p. 4)
DOE acknowledges there are certain issues related to dimming
associated with ``energy saver'' or reduced wattage lamps. Therefore,
in this rulemaking, DOE has ensured that full wattage lamps can achieve
the levels proposed for GSFLs. See section VI.D.2.g for further details
on this issue.
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
In this rulemaking, DOE does not consider the following IRL types:
(1) Lamps rated 50 W or less that are ER30, BR30, BR40, or ER40; (2)
lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 IRLs
rated 45 W or less. (42 U.S.C. 6295(i)(C)) These IRLs are the subject
of a separate rulemaking on which further information can be found on
regulations.gov under docket ID EERE-2010-BT-STD-0005 at
www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0005. DOE has
suspended activity on this rulemaking as a result of section 315 of
Public Law (Pub. L.) 112-74 (Dec. 23, 2011), which prohibits DOE from
using appropriated funds to implement or enforce standards for ER, BR,
and bulged parabolic reflector IRLs.
2. Incandescent Reflector Lamp Wattages
In this rulemaking, DOE also does not consider IRLs with wattages
lower than 40. EPCA defines an incandescent reflector lamp as a lamp
that ``has a rated wattage that is 40 watts or higher.'' (42 U.S.C.
6291(30)(C), (C)(ii), and (F)) DOE received several comments on this
lower limit on wattage for IRLs. EEI reported that highly efficacious
39 W halogen IRLs capable of replacing less efficacious 60 W IRLs are
on the market. (EEI, Public Meeting Transcript, No. 30 at pp. 24-25)
The CA IOUs considered the presence of commercially available 39 W
lamps to suggest that DOE should extend the IRL wattage range covered.
(CA IOUs, Public Meeting Transcript, No. 30 at p. 33) EEI also noted
that the 39 W IRLs are close to covered lamps in efficacy and serve as
replacements for IRLs of higher wattages, possibly increasing efficacy
by 30 to 40 percent. (EEI, Public Meeting Transcript, No. 30 at pp. 34-
35) The CA IOUs responded that in the California market there is a wide
range of efficacy for the 39 W products. (CA IOUs, Public Meeting
Transcript, No. 30 at p. 35)
GE stated that EPAct 1992 gave 40 W as the lower wattage limit for
IRLs and that this limit is appropriate. GE asserted that there was no
need to cover lower wattage IRLs as they use less energy, and a market
shift to them would still fulfill the purpose of this rulemaking. (GE,
Public Meeting Transcript, No. 30 at p. 36) ASAP questioned whether DOE
had the authority to cover lower wattages if the 40 W limit was a
statutorily defined scope. (ASAP, Public Meeting Transcript, No. 30 at
p. 39) NEMA asserted that because the CFR stipulates coverage for 40 W
IRLs and above, DOE does not have the authority to expand the scope to
lower wattages. (NEMA, No. 36 at p. 2)
NEEA noted that if the 40 W limit was statutory, it is doubtful DOE
would change it. However, NEEA found that a lower wattage limit is an
increasingly less useful way to describe coverage as technologies
shift. Additionally, NEEA noted that a wattage limit was not an
appropriate qualifier for products subject to a lm/W standard that
drives products to use fewer watts to deliver a certain lumen output,
such as a 20 W IRL that has the same lumen output as a 60 W IRL. NEEA
commented that it had seen a similar shift occur in the market for
street lighting. (NEEA, Public Meeting Transcript, No. 30 at pp. 43-44)
As described by commenters, the 40 W limit is included in the EPCA
definition of IRLs. (42 U.S.C. 6291(30)(C), (C)(ii), and (F))
Therefore, proposed standards in this notice apply only to covered IRLs
40 W or higher. Additionally, while the definition of IRLs does not
provide an upper wattage limit, DOE did not assess covered IRLs higher
than 205 W in this proposed rule. DOE research indicated that wattages
greater than 205 W comprise a very small portion of the market and are
typically designed for specialty uses, and therefore, do not represent
significant energy savings.
D. Summary of Scope of Coverage
In conclusion, in this rulemaking DOE is proposing extending the
scope of coverage for GSFLs to certain wattages but not additional GSFL
types. Further, DOE is proposing clarifying certain exemptions noted
under the definition of ``general service fluorescent lamp.'' DOE is
not considering IRLs less than 40 W or greater than 205 W and is also
not considering the following IRL types: (1) Lamps rated 50 W or less
that are ER30, BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30,
BR40, or ER40 lamps; and (3) R20 IRLs rated 45 W or less.
VI. Methodology and Discussion
In the preliminary phase of this rulemaking, DOE conducted a market
and technology assessment, screening analysis, engineering analysis,
product price determination, energy-use characterization, LCC and PBP
analyses, shipments analysis and NIA, as well as a preliminary MIA.
These analyses were then updated and revised as appropriate based on
feedback received for this NOPR. Further, in this NOPR DOE conducted an
LCC subgroup analysis, a complete MIA, a utility impact assessment, an
employment impact assessment, an emissions analysis, a determination of
monetization of reduced emissions from proposed standard levels, and an
RIA.
DOE used three spreadsheet tools to estimate the impact of
standards proposed in this NOPR. The first spreadsheet calculates LCCs
and payback periods of potential new energy conservation standards. The
second provides shipments forecasts and then calculates NES and NPV
impacts of potential new energy conservation standards. The Department
also assessed manufacturer impacts, largely through use of the
Government Regulatory Impact Model (GRIM).
DOE used a version of EIA's National Energy Modeling System (NEMS)
for the utility and environmental analyses. The NEMS model simulates
the energy sector of the U.S. economy. EIA uses NEMS to prepare its
AEO, a widely known baseline energy forecast for the United States. The
version of NEMS used for appliance standards analysis is called NEMS-BT
\21\, and is based on the
[[Page 24087]]
AEO 2013 version with minor modifications. The NEMS-BT accounts for the
interactions between the various energy supply and demand sectors and
the economy as a whole.
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\21\ The EIA approves the use of the name ``NEMS'' to describe
only an AEO version of the model without any modification to code or
data. Because the present analysis entails some minor code
modifications and runs the model under various policy scenarios that
deviate from AEO assumptions, the name ``NEMS-BT'' refers to the
model as used here. (BT stands for DOE's Building Technologies
Program.) For more information on NEMS, refer to The National Energy
Modeling System: An Overview, DOE/EIA-0581 (2009), available at:
http://www.eia.gov/oiaf/aeo/overview/index.html.
---------------------------------------------------------------------------
NEEA and NPCC stated that analyses presented in the preliminary
analysis phase need further development before stakeholders will be
able to comment in depth. NEEA and NPCC also offered to provide DOE
field data from 2012-2013 on lamp and fixture types from their
Residential Building Stock Assessment (RBSA) and the survey data from
their Commercial Building Stock Assessment (CBSA). (NEEA and NPCC, No.
34 at p. 6) NEEA and NPCC strongly support the comments provided by the
CA IOUs for this rulemaking. (NEEA and NPCC, No. 34 at p. 2)
In the preliminary analyses, DOE assessed the products that are the
subject of this rulemaking, as well as the achievable levels of
efficiency and their impacts. As noted, DOE has updated these analyses
with more recent data and, where appropriate, made adjustments based on
comments received from stakeholders in the preliminary analysis phase.
DOE will also consider any additional data submitted by commenters in
response to the NOPR.
A. Market and Technology Assessment
In the energy conservation standards rulemaking process, DOE
conducts a market and technology assessment to provide an overall
picture of the market for products concerned. Based primarily on
publicly available information, the analysis provides both qualitative
and quantitative information. The market and technology assessment
includes the major manufacturers, product classes, retail market
trends, shipments of covered products, regulatory and non-regulatory
programs, and technologies that could be used to improve the efficacy
of GSFLs and IRLs. DOE identified several technology options after
conducting this assessment for the preliminary analysis.
DOE received a general comment from NEMA on the market and
technology assessment questioning why a rulemaking is justified given
the lack of technological innovations and changes since the 2009 Lamps
Rule, the steep decline in GSFL and IRL sales expected, as shown in
DOE's projections, and the waivers still providing certain products a
stay of enforcement from the July 2012 standards. (NEMA, No. 36 at p.
6)
As explained in II.A, EPCA directs DOE to complete a rulemaking
that examines whether current GSFL and IRL standards should be amended
and if so, amend them as appropriate based on its analysis. Further, in
any rulemaking DOE must adopt standard levels that achieve the maximum
energy savings that is technologically feasible (see chapter 3 of the
NOPR TSD) and economically justified (see chapters 8 and 12 of the NOPR
TSD). Additionally, as noted previously, DOE understands that OHA has
granted numerous manufacturers 2-year waivers from standards for their
700 series T8 products that expire in 2014. Because standards from this
rulemaking would become effective in 2017, DOE conducts its analysis
assuming that the waivers will not be in place.
NEMA also added that whether there are any technological
innovations that have happened since the 2009 Lamps Rule is a valid
point of discussion, but each potential technology would have to be
given the same level of rigor regarding whether it is a feasible
pathway or not. (NEMA, Public Meeting Transcript, No. 30 at pp. 178-
179) DOE examines the latest industry literature and patents, and
receives feedback from manufacturers to develop viable technology
options that can increase the efficacy of GSFLs and IRLs. The
identified technology options are then subjected to rigorous screening
criteria before they can be considered as design options in the
engineering analysis (see section VI.B). For further details on the
technology options and the screening process, see, respectively,
chapters 3 and 4 of the NOPR TSD.
1. General Service Fluorescent Lamp Technology Options
DOE received comments specific to the GSFL technology options put
forth in the preliminary analysis. Specifically, stakeholders provided
feedback on higher efficiency lamp diameters, higher efficiency lamp
fill gas composition, and higher efficiency phosphors.
Higher Efficiency Lamp Diameters
DOE considered more efficient lamp diameters as one of the
technology options to increase GSFL efficacy in the preliminary
analysis. This option is considered as there is an optimum design
diameter for a specific fluorescent lamp type that can increase lamp
efficacy.
NEMA stated that strictly speaking the reduction of lamp diameter
does not necessarily increase efficacy and that T5 and T8 lamps are
already at their optimum diameters. Further, NEMA and GE stated that
the market has already shifted to the most efficient diameters. (NEMA,
Public Meeting Transcript, No. 30 at pp. 73; NEMA, No. 36 at p. 5; GE,
Public Meeting Transcript, No. 30 at pp. 71-72) While NEMA did not
believe higher efficiency diameter should be retained as a technology
option, NEMA and Philips requested additional clarifying information
about DOE's underlying analysis of this option. (NEMA, No. 36 at p. 5;
Philips, Public Meeting Transcript, No. 30 at p. 70)
In small diameter lamps, an increase in diameter decreases the
number of electrons and mercury ion recombination at the bulb wall,
increasing ultraviolet (UV) output and lamp efficacy. In large diameter
lamps, this recombination may already be minimal and a further
enlargement in diameter causes a greater imprisonment of radiation
within the lamp, decreasing light output and efficacy. Therefore, DOE
understands this technology option should be applied only in cases
where there is a potential to optimize the lamp diameter in order to
achieve higher lamp efficacy gain. Based on DOE's assessment there are
less efficacious lamps on the market that can be improved by using a
higher efficiency diameter. For example, standards-compliant T12
diameter product offerings remain in the 4-foot MBP and 8-foot SP
slimline product classes. Therefore, DOE continues to consider higher
efficiency lamp diameter as a technology option to increase the
efficacy of GSFLs.
Higher Efficiency Lamp Fill Gas Composition
Higher efficiency lamp fill gas composition was another technology
option identified in the preliminary analysis. Lamp fill gases in
fluorescent lamps increase mobility of mercury ions and electrons,
facilitating recombination and resulting in increased UV output and
higher lamp efficacy. Gases with lower molecular weight, such as argon,
generally result in higher lamp efficacy. Full wattage lamps generally
use argon gas. Reduced wattage lamps use a mixture of krypton and
argon. Krypton, while a higher molecular weight gas, lowers the wattage
of the lamp, thereby resulting in a higher lamp efficacy. NEMA stated
that GSFLs are already optimized for the tradeoff of argon and krypton
mixes and further efficacy gains are not possible using krypton. (NEMA,
No. 36 at p. 14)
Based on DOE's research and feedback from manufacturers in
interviews, the type and ratios of fill gases remain a mechanism to
increase
[[Page 24088]]
lamp efficacy. Because lamps are present on the market at more than one
level of efficacy, DOE believes lamp fill gas is one option that can be
utilized to improve the efficacy of less efficacious products.
Therefore, DOE continues to consider higher efficiency lamp fill gas as
a means to improve the efficacy of fluorescent lamps covered under this
rulemaking.
Higher Efficiency Phosphors
DOE also identified higher efficiency phosphors as an option for
increasing efficacy in GSFLs. The main purpose of phosphor in a
fluorescent lamp is to absorb the UV radiation and reemit it as visible
radiation. In particular, the lamp efficacy can be improved in this
manner by using triband phosphors containing rare earth elements, which
can greatly increase UV absorption and emission of radiation in the
visible spectrum relative to other phosphors. In response to this
technology option, NEMA stated that GSFLs are already optimized for
rare earth phosphors. (NEMA, No. 36 at p. 14)
Based on DOE's research and feedback from manufacturers in
interviews, the blend, weight, and thickness of rare earth phosphors in
fluorescent lamps is a key element in increasing the lamp efficacy.
Because lamps are present on the market at more than one level of
efficacy, DOE believes higher efficiency phosphor is one option that
can be utilized to improve the efficacy of less efficacious products.
Therefore, DOE continues to consider higher efficiency phosphors as a
means to improve the efficacy of fluorescent lamps covered under this
rulemaking.
Summary of GSFL Technology Options
In summary, DOE has developed the list of technology options shown
in Table VI.1 to increase efficacy of GSFLs.
Table VI.1--GSFL Technology Options in the NOPR Analysis
------------------------------------------------------------------------
Name of technology option Description
------------------------------------------------------------------------
Highly Emissive Electrode Coatings..... Improved electrode coatings
allow electrons to be more
easily removed from
electrodes, reducing lamp
power and increasing overall
efficacy.
Higher Efficiency Lamp Fill Gas Fill gas compositions improve
Composition. cathode thermionic emission or
increase mobility of ions and
electrons in the lamp plasma.
Higher Efficiency Phosphors............ Phosphors increase the
conversion of ultraviolet
light into visible light.
Glass Coatings......................... Coatings on inside of bulb
enable the phosphors to absorb
more UV energy, so that they
emit more visible light.
Higher Efficiency Lamp Diameter........ Optimal lamp diameters improve
lamp efficacy.
Multi-Photon Phosphors................. Phosphors emit more than one
visible photon for each
incident UV photon.
------------------------------------------------------------------------
2. Incandescent Reflector Lamp Technology Options
DOE received comments specific to the IRL technology options put
forth by DOE in the preliminary analysis. Specifically, stakeholders
provided feedback on efficient filament placement, higher efficiency
inert fill gas, and integrally ballasted low voltage lamps.
Efficient Filament Placement
Efficient filament placement is one of the technology options
presented in the preliminary analysis that can increase the efficacy of
IRLs. An optimally placed filament allows a portion of the spectrum
emitted by the filament to focus back onto it. The additional heat
provided to the filament increases the operating temperature and
thereby increases lamp efficacy.
NEMA disagreed that efficient filament placement should be
considered a technology option for improving efficacy. NEMA commented
that filament placement determines the beam spread of a lamp, which is
considered a performance characteristic, not a degree of efficacy. If
the filament placement were changed to make a lamp more efficacious, it
would also change the beam spread, thereby altering a lamp's utility.
(NEMA, Public Meeting Transcript, No. 30 at pp. 74-75) Understanding
that efficient filament placement refers to the placement of the
filament in an infrared (IR) capsule, the CA IOUs stated that filament
placement impacts the amount of reflected radiation that hits the
filament, which in turn impacts the amount of light emitted by the
lamp. (CA IOUs, Public Meeting Transcript, No. 30 at p. 81-82) GE
responded that filaments must be placed as close to the center of IR
capsules as possible, and their placement has already been optimized.
(GE, Public Meeting Transcript, No. 30 at pp. 82) Philips noted that
manufacturers do not know how to place filaments any more precisely
than they are now, although there is manufacturing variation. (Philips,
Public Meeting Transcript, No. 30 at pp. 82-83)
DOE acknowledges that it is theoretically well understood where the
filament should be placed to achieve higher efficacy in IRLs.
Additionally, the above comments and feedback during manufacturer
interviews indicate that lamps are being designed so that the filament
is placed in the most optimal position. Therefore, because the optimal
filament placement design has been identified and is being applied in
all commercially available products, DOE proposes to not consider
efficient filament placement as a technology option.
Higher Efficiency Inert Fill Gas
DOE presented high efficiency inert fill gas as another technology
option to increase IRL efficacy in the preliminary analysis. Fill gases
such as krypton and xenon have low thermal conductivity that decreases
the convective cooling of the filament, allowing for higher temperature
operation and therefore higher efficacy. These gas molecules are larger
relative to other gases, and can more effectively slow down the
evaporation of tungsten and thereby extend the life of the lamp. Xenon,
having even lower heat conductivity and larger mass than krypton, can
more drastically change efficacy and life, but has a higher cost. Most
lamps compliant with the July 2012 standards use xenon as a fill gas.
NEEA and NPCC indicated that xenon fill gas should not be
considered a technology option as it is already used in all, or nearly
all, halogen-based technologies, including those at the lower end of
the efficacy scale. Comparatively, there is an approximately 3 percent
drop in efficacy when using a fill gas like krypton, and accordingly
the market has clearly adopted xenon and uses it almost exclusively.
(NEEA and NPCC, No. 34 at p. 2, 5) The CA IOUs also stated that their
research indicated that most, if not all, commercially available
parabolic aluminized reflector (PAR) lamps, including those that are
lower efficacy products or minimally compliant with the 2009 Lamps
Rule, are already using xenon as their fill gas. The CA IOUs,
therefore, concluded that additional xenon would not be required to
meet higher standards. (CA IOUs, No. 32 at pp. 9-10)
Based on feedback from manufacturer interviews, DOE confirmed that
the majority of covered standards-compliant
[[Page 24089]]
IRLs are utilizing xenon. However, DOE also learned that the amount of
xenon used in lamp can vary based on several factors. Because lamps are
present on the market at more than one level of efficacy, higher
efficiency inert fill gas is one option that can be utilized to improve
the efficacy of less efficacious products. Therefore, DOE continues to
consider high efficiency inert fill gas as a technology option.
Integrally Ballasted Low Voltage Lamps
DOE also considered integrally ballasted low voltage lamps as a
technology option in the preliminary analysis. The use of an integral
ballast in an incandescent lamp allows an increase in the efficacy
because it converts the line voltage to lower lamp operating voltages,
thereby reducing the lamp wattage.
NEMA stated that integrally ballasted low voltage lamps are not
viable at high wattages, and the technology is expensive and rarely
used. Therefore, NEMA asserted that this technology is for a niche
product, and cannot be applied across the board. (NEMA, Public Meeting
Transcript, No. 30 at p. 74-75; NEMA, No. 36 at p. 7)
While the technology is not appropriate for higher wattage
products, the CA IOUs argued that it is still a valid design option for
reduced wattage lamps. The CA IOUs explained that in halogen infrared
reflector (HIR) lamps, making the filament a denser target increases
the amount of radiation that is successfully reflected back to it,
thereby increasing the lamp efficacy. At line voltage, a higher wattage
halogen burner incorporates a relatively large diameter filament;
however a lower wattage capsule must use a finer filament. For these
low wattage lamps, reducing the line voltage to low voltage allows the
use of a shorter, fatter filament, which is ideal for HIR technology.
While a lamp greater than 50 W is suited for line voltage and may
operate at too high of a temperature for an integral ballast, a lamp
less than 50 W is better suited for low voltage operation and run at
temperatures compatible with an integral transformer. Particularly, as
halogen lamps are designed to be more efficacious, lower reduced
wattage products will be more common; for this reason, the CA IOUs
envisioned integrally ballasted low voltage halogen products to be the
predominant design strategy for very high efficacy halogen products
going forward. (CA IOUs, No. 32 at p. 9)
In interviews, manufacturers stated that the use of an integral
ballast to lower voltage is not a feasible technology in higher wattage
lamps due to issues with dissipating heat generated by the electronic
components. Manufacturers indicated that heat dissipation becomes a
problem at wattages ranging from 20 to 35 W. DOE research also
indicated that in converting to a lower voltage, current is increased
and greater heat generated from the filament. In higher wattage IRLs,
the resulting increased temperature can be damaging to the voltage
conversion circuitry. Further, based on manufacturer interviews there
are no covered IRLs that currently utilize this technology option.
Because the lower limit of IRL wattages covered under standards is 40
W, DOE is no longer considering integrally ballasted low voltage lamps
as a technology option for improving lamp efficacy.
Higher Efficiency Burner
DOE did not consider a higher efficiency halogen burner as a
technology option in the preliminary analysis. DOE acknowledged that
use of a double-ended burner in an IRL can increase the efficacy
compared to a single-ended burner. Further, because double-ended
burners could not fit into small diameter IRLs (i.e., diameters less
than or equal to 2.5 inches), DOE applied a 3.5 percent reduction when
scaling efficacy levels from large diameter lamps (i.e., all diameters
greater than 2.5 inches) that could utilize a double-ended burner to
small diameter lamps. (For further discussion on IRL scaling factor see
section VI.D.3.g and chapter 5 of the NOPR TSD.)
Based on further research and interviews with manufacturers, DOE
confirmed in the NOPR analysis that a key aspect of higher efficiency
IRLs is HIR technology. Because the type of burner utilized is an
important component of an HIR lamp, in this NOPR analysis, DOE is
considering higher efficiency burners as a technology option to
increase IRL efficacy. Single-ended burners feature a lead wire inside
of the capsule that carries current between the filament and the
electrical connection in the base of the lamp. The presence of this
wire inside of the capsule prevents a certain amount of energy from
reaching the capsule wall and being reflected (recycled) back to the
capsule filament. However, double-ended burners have a lead wire
outside of the capsule that does not interfere with the reflectance of
energy back to the filament, allowing for a more efficacious lamp.
Hence, DOE is proposing higher efficiency burner as a technology option
that can increase efficacy of IRLs.
Summary of IRL Technology Options
Of the IRL technology options presented in the preliminary
analysis, DOE is no longer considering integrally ballasted low voltage
lamps as a technology option. In addition to the IRL technology options
identified in the preliminary analysis, DOE is proposing the inclusion
of the higher efficiency burner as a technology option. In summary, in
this NOPR analysis, DOE is proposing the IRL technology options listed
in Table VI.2.
Table VI.2--IRL Technology Options in the NOPR Analysis
------------------------------------------------------------------------
Name of technology option Description
------------------------------------------------------------------------
Higher Temperature Operation. Operating the filament at higher
temperatures, the spectral output shifts
to lower wavelengths, increasing its
overlap with the eye sensitivity curve.
Microcavity Filaments........ Texturing, surface perforations,
microcavity holes with material
fillings, increasing surface area and
thereby light output.
Novel Filament Materials..... More efficient filament alloys that have
a high melting point, low vapor
pressure, high strength, high ductility,
or good radiating characteristics.
Thinner Filaments............ Thinner filaments to increase operating
temperature. This measure may shorten
the operating life of the lamp.
Efficient Filament Coiling... Coiling the filament to increase surface
area, thus increasing light output.
Crystallite Filament Coatings Layers of micron or submicron
crystallites deposited on the filament
surface that increases emissivity of the
filament.
Efficient Filament Positioning (horizontal or vertical) the
Orientation. incandescent filament to increase light
emission from the lamp. Vertical
orientation, used by majority of lamps,
allows for greater light emission.
Higher Efficiency Inert Fill Filling lamps with alternative gases,
Gas. such as Krypton, to reduce heat
conduction.
Higher Pressure Tungsten- Increased halogen bulb capsule
Halogen Lamps. pressurization, allowing higher
temperature operation.
[[Page 24090]]
Non-Tungsten-Halogen Novel filament materials that regenerate.
Regenerative Cycles.
Infrared Glass Coatings...... When used with a halogen capsule, this is
referred to as a HIR lamp. Infrared
coatings on the inside of the bulb to
reflect some of the radiant energy back
onto the filament.
IR Phosphor Glass Coatings... Phosphor coatings that can absorb IR
radiation and re-emit it at shorter
wavelengths (visible region of light),
increasing the lumen output.
UV Phosphor Glass Coatings... Phosphor coatings that convert UV
radiation into longer wavelengths
(visible region of light), increasing
the lumen output.
Electron Stimulated A low voltage cathodoluminescent phosphor
Luminescence. that emits green light (visible region
of light) upon impingement by thermally
ejected electrons, increasing the lumen
output.
Higher Efficiency Reflector Alternative reflector coatings such as
Coatings. silver, with higher reflectivity
increase the amount of directed light.
Corner Reflectors............ Individual corner reflectors in the cover
glass that reflect light directly back
in the direction from which it came.
High Reflectance Filament Filament supports that include a
Supports. reflective face that reflects light to
another filament, the reflective face of
another filament support, or radially
outward.
Permanent Infrared Reflector Permanent shroud with an IR reflector
Coating Shroud. coating and a removable and replaceable
lamp can increase efficiency while
reducing manufacturing costs by allowing
IR reflector coatings to be reused.
Higher Efficiency Burners.... A double-ended burner that features a
lead wire outside of the capsule, where
it does not interfere with the
reflectance of energy from the capsule
wall back to the capsule filament in HIR
lamps.
------------------------------------------------------------------------
B. Screening Analysis
After DOE identifies the technologies that improve the efficacy of
GSFLs and IRLs, DOE conducts the screening analysis. The purpose of the
screening analysis is to determine which options to consider further
and which options to screen out. DOE consults with industry, technical
experts, and other interested parties in developing a list of
technology options. DOE then applies the following set of screening
criteria to determine which options are unsuitable for further
consideration in the rulemaking (10 CFR Part 430, subpart C, appendix A
at 4(a)(4) and 5(b)):
Technological Feasibility: DOE will consider technologies
incorporated in commercially available products or in working
prototypes to be technologically feasible.
Practicability to Manufacture, Install, and Service: If
mass production of a technology and reliable installation and servicing
of the technology could be achieved on the scale necessary to serve the
relevant market at the time the standard comes into effect, then DOE
will consider that technology practicable to manufacture, install, and
service.
Adverse Impacts on Product Utility or Product
Availability: If DOE determines a technology to have significant
adverse impact on the utility of the product to significant subgroups
of consumers, or to result in the unavailability of any covered product
type with performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as products generally available in the United States at the time,
it will not further consider this technology.
Adverse Impacts on Health or Safety: If DOE determines
that a technology will have significant adverse impacts on health or
safety, it will not further consider this technology.
Those technology options not screened out by the above four
criteria are called ``design options'' and are considered as possible
methods of improving efficacy in the engineering analysis. DOE received
several comments on technology options not screened out and retained as
design options in the preliminary analysis for GSFLs and IRLs.
1. General Service Fluorescent Lamp Design Options
In the preliminary analysis, of the GSFL technology options
identified, DOE did not consider screening out higher efficiency lamp
fill gas composition and glass coatings; however, DOE received several
comments on these two design options. DOE did not receive any feedback
on the other GSFL design options put forth in the preliminary analysis.
Higher Efficiency Lamp Fill Gas Composition
In the preliminary analysis, DOE determined that higher efficiency
lamp fill gas composition met the screening criteria and considered it
as a design option. As previously described, lamp fill gases such as
argon increase mobility of mercury ions and electrons, facilitating
recombination and thereby increasing UV output and resulting in higher
lamp efficacy. Krypton is primarily used as a fill gas in reduced
wattage lamps because it lowers lamp wattage, thereby resulting in
higher lamp efficacy. NEMA noted that the resulting reduced wattage
lamps have issues with cold temperature applications, striations, and
dimmability due to the use of krypton and pointed out that these items
are performance characteristics that should be considered in the
screening analysis. NEMA encouraged DOE to explore the trade-offs to
ensure the right balance is obtained. (NEMA, Public Meeting Transcript,
No. 30 at pp. 78-79)
Based on previous manufacturer feedback, DOE is aware that the
presence of krypton in reduced wattage lamps causes issues with lamp
starting and striations in cold temperature applications below 60-
65[emsp14][deg]F. Feedback from manufacturers in interviews has also
indicated that problems encountered with dimming linear fluorescent
lamps, including lamp starting, striations, and dropout, are
exacerbated by the use of krypton in reduced wattage lamps. Krypton,
which lowers the wattage of a fluorescent lamp, is the primary fill gas
used in reduced wattage fluorescent lamps. Based on feedback from
manufacturers the use of any amount of krypton will result in dimming
issues and increase with the amount of krypton.
Philips noted that issues with dimming reduced wattage lamps could
also be related to the ballast as well as compatibility with the dimmer
and lamp. Philips further noted that they had observed that a lamp-
ballast system would dim successfully in one building but fail when put
in a different building.
[[Page 24091]]
(Philips, Public Meeting Transcript, No. 30 at p. 225)
Despite the issues with dimming and operation in cold temperatures,
DOE has determined that reduced wattage lamps using krypton can be
found on the market in various wattages. Feedback from manufacturers in
interviews also indicates that reduced wattage lamps comprise a
significant portion of their GSFL shipments. Additionally, consumers
have other options, as more reliable dimming can be attained using full
wattage lamps and fluorescent lamps designed to be operated in cold
temperature applications exist on the market.
Therefore, DOE has determined that higher efficiency lamp fill gas
composition, specifically in the form of krypton, meets the criteria of
being technologically feasible and practicable to manufacture as it is
used in commercially available products. DOE has found no evidence to
indicate it has adverse impacts on health and safety. Because DOE is
considering standard levels that ensure the availability of both full
and reduced wattage lamps, DOE has determined that the use of this
technology does not have an adverse impact on product utility or
availability. Therefore, DOE proposes to maintain higher efficiency
lamp fill gas as a design option for GSFLs.
Glass Coatings
In the preliminary analysis, DOE determined that glass coatings met
the screening criteria and considered them as a design option. To
increase the UV absorption by the phosphors, the lamp glass can be
covered with an antireflective coating. This coating is a refractory
oxide, such as aluminum oxide (Al2O3), silicon
oxide (SiO2), and titanium oxide (TiO2) that
reflects any UV radiation that passes through the phosphor back onto
the phosphor, allowing a greater portion of UV to be absorbed, thereby
increasing light output and lamp efficacy. NEMA stated that glass
coatings should be screened out as the techniques are not feasible,
which is the reason they are not already widely used. (NEMA, No. 36 at
p. 7; NEMA, Public Meeting Transcript, No. 30 at pp. 70)
DOE determined that most modern lamps utilize glass coatings that
minimize the absorption of mercury and act as reflectors of UV
radiation.\22\ An undercoat layer, preferably composed of aluminum
oxide and a getter material, reflects UV radiation that has passed
through the luminescent material of the lamp back onto the material for
increased visible light output and also reduces the contaminants in the
lamp. A patent relevant to this technology notes that such undercoating
is a common feature of modern fluorescent lamps.\23\
---------------------------------------------------------------------------
\22\ DiLaura, D. L., K. W. Houser, R. G. Mistrick, and G. R.
Steffy. IESNA Lighting Handbook: Reference and Application, 10th
Edition. New York: IESNA, 2011.
\23\ Trushell, Charles and Liviu Magean. Method of manufacturing
a fluorescent lamp having getter on a UV reflective base coat. U.S.
Patent No. 7,500,896 B2, filed May 9, 2005, and issued Mar 10, 2009.
---------------------------------------------------------------------------
Because this technology option is being used in commercially
available fluorescent lamps, DOE considers it to be practicable to
manufacture. DOE is not aware of any evidence indicating that the
technology has adversely impacted product utility or health and safety.
Therefore, DOE proposes to maintain glass coatings as a design option
for GSFLs.
In summary, in this NOPR analysis DOE is proposing as design
options the following GSFL technologies that have met the screening
criteria:
Highly Emissive Electrode Coatings
Higher Efficiency Lamp Fill Gas Composition
Higher Efficiency Phosphors
Glass Coatings
Higher Efficiency Lamp Diameter
See chapter 4 of the NOPR TSD for further details on the GSFL
screening analysis.
2. Incandescent Reflector Lamp Design Options
DOE did not receive any feedback on IRL design options put forth in
the preliminary analysis.
Higher Efficiency Burners
As mentioned previously, in this NOPR analysis DOE is proposing the
additional technology option of a higher efficiency burner as a means
to improve IRL efficacy. DOE evaluated the higher efficiency burner
technology against the screening criteria. DOE found that higher
efficiency burners, such as the double-ended burner, are currently
being utilized in commercially available lamps and have demonstrated
that they are technologically feasible, practicable to manufacture,
install, and service on a commercial scale by the compliance date of
any amended standards, and do not result in adverse impacts on product
utility or availability, or health and safety. DOE acknowledges that
double-ended burners cannot be used in small diameter lamps without
changing the physical shape of the lamp, which may impact whether the
lamp can fit standard fixtures, and thereby affect product utility.
Therefore, DOE is proposing higher efficiency burners as a design
option only for IRLs with diameters greater than 2.5 inches.
In summary, in this NOPR analysis DOE is proposing as design
options the following IRL technologies that have met the screening
criteria:
Higher Temperature Operation
Thinner Filaments
Efficient Filament Coiling
Efficient Filament Orientation
Higher Efficiency Inert Fill Gas
Higher Pressure Tungsten-Halogen Lamps
Infrared Glass Coatings
Higher Efficiency Reflector Coatings (with the exception
of gold reflector coatings)
Higher Efficiency Burner
See chapter 4 of the NOPR TSD for further details on the IRL
screening analysis.
C. Product Classes
DOE divides covered products into classes by: (a) The type of
energy used; (b) the capacity of the product; or (c) other performance-
related features that justify different standard levels, considering
the consumer utility of the feature and other relevant factors. (42
U.S.C. 6295(q)) In a general comment, NEMA requested that DOE ensure
CSLs do not potentially eliminate utility from the market. (NEMA, No.
36 at p. 20) As noted, when assessing factors for product class
divisions, DOE considers consumer utility.
DOE received several comments regarding product classes considered
in the preliminary analysis.
1. General Service Fluorescent Lamp Product Classes
In the preliminary analysis DOE considered product classes for
GSFLs based on the following three factors: (1) CCT; (2) physical
constraints of lamps (i.e., lamp shape and length); and (3) lumen
package. DOE received comments regarding the CCT product class division
and a suggestion to establish a product class division based on a
lamp's dimming functionality. DOE did not receive feedback on the other
product class divisions put forth for GSFLs in the preliminary
analysis.
CCT
In the preliminary analysis, DOE considered CCT, noted in degrees
Kelvin (K), as a class setting factor, specifically, product classes
for GSFLs with a CCT less than or equal to 4,500 K and a product class
for GSFLs with a CCT greater than 4,500 K. NEEA and NPCC noted that
while DOE stated that GSFLs with a CCT greater than 4,500 K show a
decline in efficacy, DOE did not
[[Page 24092]]
state the degree of the decline of efficacy, whether it was consistent
across manufacturers, or if the decline was inherent in the phosphor
mixes required to produce the higher CCT values. NEEA and NPCC noted
that they may support having a separate product class for these lamps,
but that additional data is needed. (NEEA and NPCC, No. 34 at p. 3)
CCT is a measure of the perceived color of white light emitted from
a lamp. The lower CCTs correspond to warm light and are in the red
wavelengths while the higher CCTs correspond to cooler light and are in
blue wavelengths. The human eye is less responsive to light in the blue
wavelengths and therefore, efficacy decreases in lamps with higher
CCTs. The phosphor blend used in a lamp substantially impacts the
lamp's CCT. For example, the use of rare earth phosphors results in
light emitted at wavelengths to which the human eye is most sensitive,
thereby increasing the lamp efficacy. Therefore, different phosphor
blends in lamps achieve different CCTs. (See chapter 3 of the NOPR TSD
for further details on fluorescent lamp technology.)
DOE determined through analysis and confirmed with manufacturers
that lamps with CCTs greater than 4,500 K start showing a decline in
efficacy. Feedback from manufacturers varied regarding the exact
efficacy reduction correlated with CCT and whether it was consistent
across GSFL types. DOE's evaluation of catalog and compliance
efficacies for similar lamp types at different CCTs for various
manufacturers has shown that in general, there is a reduction in the
range of 2-6 percent going from a CCT of 4,500 K or less to a CCT
greater than 4,500 K. (See section VI.D.2.h and chapter 5 of the NOPR
TSD for scaling to higher CCT product classes.)
Therefore, because consumers are afforded a different perception of
light at different CCTs and efficacy is impacted with varying CCTs, DOE
proposes to maintain CCT as a product class division factor.
Specifically DOE is proposing to establish a product class of lamps
with CCTs less than or equal to 4,500 K and a product class with CCTs
greater than 4,500 K.
Dimming Utility
NEMA noted that DOE may not set standards that would eliminate full
wattage GSFLs because the Secretary may not prescribe standards
``likely to result in the unavailability in the United States in any
covered product type (or class) of performance characteristics
(including reliability), features, sizes, capacities, and volumes that
are substantially the same as those generally available in the United
States at the time of the Secretary's finding.'' (42 U.S.C. 6295(o)(4))
NEMA emphasized that as dimmability and uniformity of light (absence of
flicker or striation) are all performance characteristics highly
desirable in the marketplace, they must be maintained. (NEMA, No. 36 at
p. 4) Further, NEMA stated that potential energy savings from dimming
will be reduced or lost if DOE eliminates full wattage 32 W GSFLs from
the market. (NEMA, No. 36 at p. 15) Lutron agreed that elimination of
full wattage lamps that are argon-filled would also get rid of dimming.
(Lutron, Public Meeting Transcript, No. 30 at pp. 25)
EEI noted that the increase of lighting controls requirements in
building codes such as those put out by American Society of Heating,
Refrigerating and Air-Conditioning Engineers (ASHRAE) and International
Energy Conservation Code (IECC) means that dimmability is a performance
characteristic necessary for operation in commercial buildings. (EEI,
Public Meeting Transcript, No. 30 at p. 79-80) The CA IOUs reiterated
the importance of not eliminating dimming products from the market.
They suggested that if there are two sets of products, one with dimming
capability and one with higher efficacy, there may be grounds to create
separate product classes so that covered products will comply with
standards either by having higher efficacy or by dimming. (CA IOUs,
Public Meeting Transcript, No. 30 at pp. 135)
DOE acknowledges that there are issues with dimming reduced wattage
lamps that do not typically manifest in full wattage lamps. DOE is
aware that unreliable dimming is in part due to the use of krypton as
the fill gas in reduced wattage lamps as well as other factors. (See
the discussion on higher efficiency lamp fill gas composition in
VI.A.1.) Therefore, DOE is ensuring that any proposed level can be met
by full wattage lamps. Because the utility of dimming is being
preserved in the existing product class structure and for the analyzed
standard levels, DOE is not proposing fill gas that allows for reliable
dimming as a product class setting factor. (See section VI.D.2.g and
chapter 5 of the NOPR TSD for the GSFL engineering analysis.)
Summary of GSFL Product Classes
In this NOPR analysis, DOE is proposing the product classes for
GSFLs summarized in Table VI.3. See chapter 3 of the NOPR TSD for
further details on each GSFL product class.
Table VI.3--GSFL Product Classes in NOPR Analysis
------------------------------------------------------------------------
Lamp type CCT
------------------------------------------------------------------------
4-foot medium bipin..................................... <=4,500 K
>4,500 K
2-foot U-shaped......................................... <=4,500 K
>4,500 K
8-foot single pin slimline.............................. <=4,500 K
>4,500 K
8-foot recessed double contact high output.............. <=4,500 K
>4,500 K
4-foot T5, miniature bipin standard output.............. <=4,500 K
>4,500 K
4-foot T5, miniature bipin high output.................. <=4,500 K
>4,500 K
------------------------------------------------------------------------
2. Incandescent Reflector Lamp Product Classes
In the preliminary analysis, DOE considered product classes for
IRLs based on the following three factors: (1) Rated voltage,
separating lamps less than 125 V from lamps greater than or equal to
125 V; (2) lamp spectrum, separating lamps with a standard spectrum
from lamps with a modified spectrum; and (3) lamp diameter, separating
lamps with a diameter greater than 2.5 inches from lamps with a
diameter less than or equal to 2.5 inches. DOE received several
comments on the rated voltage class setting factor. DOE did not receive
feedback on the other product class divisions put forth for IRLs in
this preliminary analysis.
Rated Voltage
In the preliminary analysis, DOE considered rated voltage as a
class setting factor, establishing a product class for IRLs with
voltages less than 125 V and a product class for IRLs with voltages
greater than or equal to 125 V. IRLs mainly come in rated voltages of
120 or 130. This product class division establishes two separate
product classes for the 120 V IRLs and the 130 V IRLs.
NEEA and NPCC stated that DOE should maintain separate product
classes for lamps that are less than 125 V and those that are greater
than or equal to 125 V. They indicated that if there were demand for
130 V lamps, it would be highly likely that standards compliant 130 V
lamps would enter the market, as there is nothing inherent in the
standard levels that would eliminate 130 V lamps. (NEEA and NPCC, No.
34 at p. 4)
Advanced Lighting Technologies (ADLT) agreed, pointing out that
combining lamps less than 125 V and greater than or equal to 125 V
lamps into one product class would allow 130 V lamps on the market that
fall below
[[Page 24093]]
the July 2012 efficacy requirement of 5.9P\0.27\ when operated at 120
V. ADLT gave the example that a 130 V 70 W lamp would be required to
produce 19.5 lm/W under DOE's CSL 1 of 6.2P\0.27\ for less than 125 V
lamps. However, operating the same 130 V, 70 W lamp in a 120 V socket
would result in lowering the wattage to 61.5 W and efficacy to 16.8 lm/
W,\24\ which equates to 5.4P\0.27\. Therefore, a 130 V, 70 W lamp
operating at 120 V would fall well below the July 2012 requirement of
5.9P\0.27\. (ADLT, No. 31 at p. 2)
---------------------------------------------------------------------------
\24\ DiLaura, D. L., K. W. Houser, R. G. Mistrick, and G. R.
Steffy. IESNA Lighting Handbook: Reference and Application, 10th
Edition. New York: IESNA, 2011.
---------------------------------------------------------------------------
Existing DOE test procedures provide for lamps rated at 130 V to be
tested at 130 V and for lamps rated at 120 V to be tested at 120 V.
However, DOE is aware that a large number of consumers actually operate
130 V lamps at 120 V, which results in longer lifetime but lower
efficacy. With a single EL for lamps rated at each voltage, this
situation would effectively lead to a lower efficacy requirement for
these 130 V lamps run at 120 V, compared to 120 V lamps run at 120 V.
The 130 V lamps would not require the same level of technology as 120 V
lamps to meet the same standard, and, thus, would be cheaper to
produce. Therefore, setting higher standards for IRLs without
accounting for voltage differences could result in increased migration
to 130 V lamps instead of the 120 V lamps. When consumers operate these
lamps at 120 V, they may need to purchase more lamps to obtain
sufficient light output, thereby increasing energy consumption. Hence,
in order to preserve energy savings, DOE proposes to maintain the rated
voltage class division that separates covered IRLs less than 125 V from
those that are greater than or equal to 125 V.
Summary of IRL Product Classes
In this NOPR analysis, DOE is proposing the product classes for
IRLs summarized in Table VI.4. See chapter 3 of the NOPR TSD for
further details on each IRL product class.
Table VI.4--IRL Product Classes in NOPR Analysis
------------------------------------------------------------------------
Diameter (in
Lamp type inches) Voltage
------------------------------------------------------------------------
Standard Spectrum....................... >2.5 >=125 V
.............. <125 V
<=2.5 >=125 V
.............. <125 V
Modified Spectrum....................... >2.5 >=125 V
.............. <125 V
<=2.5 >=125 V
.............. <125 V
------------------------------------------------------------------------
D. Engineering Analysis
1. General Approach
The engineering analysis is generally based on commercially
available lamps that incorporate the design options identified in the
technology assessment and screening analysis. (See chapters 3 and 4 of
the NOPR TSD for further information on technology and design options.)
The methodology consists of the following steps: (1) Selecting
representative product classes, (2) selecting baseline lamps, (3)
identifying more efficacious substitutes, and (4) developing efficacy
levels by directly analyzing representative product classes and then
scaling those efficacy levels to non-representative product classes.
The details of the engineering analysis are discussed in chapter 5 of
the NOPR TSD. The following discussion summarizes the general steps of
the engineering analysis:
Representative product classes: DOE first reviews covered lamps and
the associated product classes. When a product has multiple product
classes, DOE selects certain classes as ``representative'' and
concentrates its analytical effort on these classes. DOE selects
representative product classes primarily because of their high market
volumes.
Baseline lamps: For each representative product class, DOE selects
a baseline lamp as a reference point against which to measure changes
resulting from energy conservation standards. Typically, a baseline
model is the most common, least efficacious lamp sold in a given
product class. DOE also considers other lamp characteristics in
choosing the most appropriate baseline for each product class such as
wattage, lumen output, and lifetime.
More efficacious substitutes: DOE selects higher efficacy lamps as
replacements for each of the baseline models considered. When selecting
higher efficacy lamps, DOE considers only design options that meet the
criteria outlined in the screening analysis (see section VI.B or
chapter 4 of the NOPR TSD). For GSFLs, DOE pairs each lamp with an
appropriate ballast because fluorescent lamps are a component of a
system, and their performance is related to the ballast on which they
operate.
Efficacy levels: After identifying the more efficacious substitutes
for each baseline lamp, DOE develops ELs. DOE bases its analysis on
three factors: (1) The design options associated with the specific
lamps studied; (2) the ability of lamps across wattages to comply with
the standard level of a given product class; \25\ and (3) the max tech
EL. DOE then scales the ELs of representative product classes to those
classes not directly analyzed.
---------------------------------------------------------------------------
\25\ ELs span multiple lamps of different wattages. In selecting
ELs, DOE considered whether these multiple lamps can meet the
standard levels.
---------------------------------------------------------------------------
DOE received a general comment on the methodology used in this
rulemaking to develop efficacy levels for both GSFLs and IRLs. NEMA
noted that additional adjustments for variation of product performance
for manufacturing and testing variations must be afforded not only to
compliance but to interpretations of published catalog data. NEMA
referred DOE to NEMA LSD-63 Measurement Methods and Performance
Variation for Verification Testing of General Purpose Lamps and Systems
for guidance on proper application of statistical analysis for lighting
products. (NEMA, No. 36 at pp. 11-12; Philips, Public Meeting
Transcript, No. 30 at pp. 134)
DOE reviewed NEMA LSD-63 to determine whether additional
adjustments due to manufacturing and testing variation were needed
based on the guidance provided in the document. DOE determined that the
guidance was not applicable to the datasets utilized by DOE to conduct
the analysis,
[[Page 24094]]
specifically lamp manufacturer catalog data and DOE's certification
database. DOE received feedback from manufacturers that catalog data
represents the long term average performance of products. In
comparison, LSD-63 provides guidance for comparing a small sample set
of test data to rated catalog values through statistical analysis to
determine if the small sample set is part of the long term rating
distribution. Because the guidance prescribed in LSD-63 is relevant for
small sample sets and DOE is basing its analysis on catalog data
representing long term performance data, DOE did not make adjustments
for variation using this guidance.
Further, as discussed in section VI.D.2.a, DOE considers
certification data provided in DOE's database to account for variation
when establishing the minimum efficiency requirements for each efficacy
level. By accounting for the compliance requirements when establishing
efficacy levels, DOE incorporates manufacturing and testing variation
and therefore uses values representative of the energy use of the
products.
Stakeholders had several comments regarding the engineering
analysis presented in the preliminary TSD specific to GSFLs and IRLs.
The following sections discuss and address feedback received from
stakeholders for each product. DOE requests comment on the overall
methodology, assumptions, and results of the GSFL and IRL engineering
analyses.
2. General Service Fluorescent Lamp Engineering
DOE received comments on the engineering analysis for GSFLs
presented in the preliminary TSD. Stakeholders provided feedback on
DOE's data approach, representative product classes, baseline lamps,
selection of more efficacious substitutes, lamp-and-ballast pairings,
max tech levels, CSLs, and scaling. The following sections summarize
the comments and responses received on these topics, and present the
proposed GSFL engineering for this NOPR analysis.
a. Data Approach
For the preliminary analysis, DOE considered commercially available
lamps when possible. DOE used performance data of the commercially
available lamps presented in manufacturer catalogs to identify
potential baseline lamps and develop initial efficacy levels. DOE
calculated efficacy as the initial lumen output published in
manufacturer catalogs divided by the ANSI rated wattage. For lamp types
that do not have a defined ANSI rated wattage, DOE utilized the lamp's
nominal wattage to calculate catalog efficacy. However, DOE also
analyzed publicly available data submitted to DOE by manufacturers to
demonstrate compliance with existing energy conservation standards.\26\
DOE adjusted efficacy levels to account for certification data when
available.
---------------------------------------------------------------------------
\26\ The publicly available compliance information for GSFLs can
be found in DOE's Compliance Certification Database available here:
www.regulations.doe.gov/certification-data/.
---------------------------------------------------------------------------
Usability of Certification Data and Catalog Data
The CA IOUs noted statements made during the public meeting
indicated that the catalog data may not be precise as it is not subject
to any reporting regulations and further the certification database may
be inaccurate. The CA IOUs asked that clarification be provided
regarding the data used in the GSFL analysis. (CA IOUs, No. 32 at pp.
12-13) The CA IOUs also noted that a large number of products in DOE's
certification database did not seem to have been included in this
rulemaking analysis for GSFLs. In particular, the CA IOUs noted that
there were about 20 or 30 products that are above 96 lm/W for the
representative 4-foot MBP product class from about ten manufacturers
including MaxLite, Satco, Philips, and Westinghouse, as well as a
product exceeding 100 lm/W. (CA IOUs, Public Meeting Transcript, No. 30
at pp. 114-115)
GE suggested that because such high measured lm/W values are not
achievable, the issue may be that the information in the certification
database is being misread or there may be confusion among manufacturers
about what exactly to report in each column which could be resulting in
false calculations. (GE, Public Meeting Transcript, No. 30 at p. 115,
pp. 141) GE noted that manufacturers have questions pending to DOE
regarding certification reporting. (GE, Public Meeting Transcript, No.
30 at pp. 141) The CA IOUs agreed with GE that there could be
inconsistencies or confusion with which values to report and encouraged
DOE to look into these issues further. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 115-116) ASAP pointed out that there may be
possible enforcement issues if there are products in the certification
database that are non-compliant. (ASAP, Public Meeting Transcript, No.
30 at pp. 139) GE added that it could be that the lamps are in
compliance but the claims being made are aggressive. (GE, Public
Meeting Transcript, No. 30 at pp. 141)
NEEA disagreed that the certification database was being misread.
NEEA recommended the use of a consistent set of data and requested
general clarification on the data utilized in the analysis. (NEEA,
Public Meeting Transcript, No. 30 at pp. 139-140) ASAP asked if there
is a discrepancy between catalog and certification values for products.
(ASAP, Public Meeting Transcript, No. 30 at pp. 146-147) Philips
explained that values initially published in catalogs are based on a
small set of samples and these values change as the sample size
increases and is more representative of manufacturing. The initially
published catalog values are eventually synched with values based on
the greater sample size but catalogs are updated only every two or
three years. Further there is some allowable difference between the
marketed efficacy values and the certification efficacy values.
(Philips, Public Meeting Transcript, No. 30 at pp. 147-148)
NEEA and NPCC stated that they are unable to comment extensively on
the GSFL analysis due to DOE's use of catalog efficacy values and ANSI
rated wattages instead of measured and/or certified values including
using test data at appropriate test conditions such as testing at 25
[deg]C. (NEEA and NPCC, No. 34 at p. 2, 3) Noting that comments by
manufacturers during the public meeting indicated that catalog and
certification values will be different, NEEP as well as NEEA and NPCC
recommended DOE use measured and/or certified values for its analysis,
and not use catalog values for any part of the analysis. (NEEA and
NPCC, No. 34 at p. 2, 3; NEEP, No. 33 at p. 2) NEEA and NPCC stated
that once it had seen measured and/or certified values, it suspected
the range of lamp performance will be much narrower than presented in
the preliminary analysis. (NEEA and NPCC, No. 34 at p. 2, 3) NEEP
stated that while there appear to be significant energy savings for
GSFLs at CSL1, DOE's use of catalog data puts the accuracy of these
estimates into question. (NEEP, No. 33 at p. 2)
DOE understands the concerns raised by stakeholders regarding the
difference between catalog and certification values and their
subsequent recommendations to utilize certification data. At the time
of the preliminary analysis, DOE's certification database consisted of
data for only 38 percent of covered GSFLs. Because not all commercially
available products had associated certification data, DOE was unable to
rely solely on certification data in the preliminary analysis. At the
time of the NOPR analysis, DOE's certification database
[[Page 24095]]
contained data for 68 percent of the covered commercially available
lamps. While this was an increase from the preliminary analysis, it
still did not represent a comprehensive dataset on which to base an
engineering analysis. Therefore, in this NOPR analysis, DOE again
utilized catalog data to identify baseline products and develop initial
efficacy levels. This approach ensured consideration of all available
products. DOE then used available certification data to adjust the
initial efficacy levels, if necessary, thereby ensuring that the
proposed levels can be met based on the certification values submitted
by manufacturers to demonstrate compliance with standards.
Wattage
The CA IOUs asked why DOE is using ANSI rated wattage to calculate
efficacy when the certification database lists specific wattages for
products. (CA IOUs, Public Meeting Transcript, No. 30 at pp. 96) The CA
IOUs stated that using a rated wattage of 32.5 W gives an expected
average efficacy and recommended looking at whether lamps are
performing at different levels of efficacy than projected and setting
baselines and standards around more measured data rather than a rated
wattage. (CA IOUs, Public Meeting Transcript, No. 30 at p. 100)
NEMA noted the rated wattage is based on a very large number of
samples that are averaged out and manufacturers produce lamps to fall
on and around that point. Therefore, the individual lamp tested wattage
will differ from this rated value of that lamp. NEMA stated that it
would defer to its members, but in general it supported using the ANSI
rated wattage rather than the measured wattage. (NEMA, Public Meeting
Transcript, No. 30 at pp. 98) GE did not think industry had a firm
position on the issue, recognizing different wattages can be used. (GE,
Public Meeting Transcript, No. 30 at pp. 99-100; NEMA, Public Meeting
Transcript, No. 30 at pp. 98-99)
For the preliminary analysis and the NOPR analysis, DOE used
catalog data to develop initial CSLs and ELs and assessed certification
data to make any adjustments to the levels. As noted, DOE's
certification database does not include data for all covered GSFLs;
therefore, the measured wattages of all commercially available covered
lamps are not readily accessible. Additionally, DOE identified
inconsistencies with the values reported for wattage, specifically in
some cases nominal wattage may be reported rather than the measured
wattage in DOE's certification database. Therefore, as mentioned
previously, DOE used manufacturer lamp catalogs to establish initial
CSLs in the preliminary analysis and ELs in the NOPR. To determine
catalog efficacies, DOE used catalog lumen output and ANSI rated
wattage instead of the nominal wattage provided by manufacturers in
catalogs. ANSI rated wattage is the result of standardized ANSI testing
and represents an industry agreed upon wattage, as explained by NEMA.
If an ANSI standard did not provide a rated wattage for a lamp type
analyzed, efficacy was calculated using the nominal wattage.
For the assessment of certification values, DOE used the reported
values for efficacy, which are based on measured lumen output and
measured wattage as specified in DOE's test procedures for GSFLs set
forth at 10 CFR part 430, subpart B, appendix R. Utilizing ANSI rated
wattage to calculate catalog efficacy and reported efficacy for
developing final efficacy levels eliminates the uncertainty associated
with the wattages reported for compliance.
Using Data at 25 Degrees Celsius
NEMA stated that DOE should conduct all its analyses, payback and
feasibility equations based on data referenced to and measured at 25
[deg]C, not 35 [deg]C, otherwise, results will be skewed because
efficiency can ``appear'' higher at 35 [deg]C for certain products made
(optimized) for those conditions. NEMA noted that DOE's test procedure,
existing and previous rules, as well as reporting and catalogs, use 25
[deg]C data. (NEMA, No. 36 at p. 18; NEMA, Public Meeting Transcript,
No. 30 at p. 127) GE noted that discussions during the 2009 Lamps Rule
had concluded that T5 lamps should be tested at 25 [deg]C as currently
done by labs because testing becomes very unreliable at 35 [deg]C.
Therefore, it is not appropriate to have a lm/W level based on 35
[deg]C. (GE, Public Meeting Transcript, No. 30 at pp. 89-90) Philips
stated that lamps for which efficacy values are provided at 35 [deg]C
operating temperature in catalogs are particular amalgam lamps that
were designed specifically for that environment. (Philips, Public
Meeting Transcript, No. 30 at p. 127)
In the preliminary analysis, DOE developed efficacy levels based on
performance at 25 [deg]C because the DOE test procedure for GSFLs
requires the lamps to be tested at 25 [deg]C, including T5 lamps.
However, because all manufacturers do not provide lumen output data at
25 [deg]C for T5 lamps in their catalogs but do provide it at 35
[deg]C, DOE developed initial efficacy levels based on 35 [deg]C
catalog data for T5 lamps. This allowed DOE to evaluate performance for
all T5 lamps based on data provided by manufacturers at the same
operating temperature. As noted, because the DOE test procedure used to
determine compliance with standards requires GSFLs to be tested at 25
[deg]C, DOE adjusted the initial efficacy levels to reflect operation
at 25 [deg]C. To do this, DOE utilized information in lamp manufacturer
catalogs that provided performance characteristics for lamp operation
at both 25 [deg]C and 35 [deg]C. In cases where this information was
not available, DOE adjusted the 35 [deg]C data to reflect lamp
operation at 25 [deg]C. Specifically, when operated at 25 [deg]C, the
lumen output of T5 lamps is approximately 10 percent lower than the
lumen output of such lamps when operated at 35 [deg]C. For this NOPR
analysis, DOE has maintained this approach and developed efficacy
levels based on performance at 25 [deg]C.
Decimal Usage for lm/W
Philips stated that the CSLs analyzed in the preliminary analysis
are to the tenths decimal place which provides an artificial measure of
accuracy that doesn't even exist and Philips doesn't think it can be
measured accurately. (Philips, Public Meeting Transcript, No. 30 at p.
146) Regarding this comment that reporting lm/W to one significant
digit is not conducive to repeated and reliable measurements, the CA
IOUs stated the rulemaking must adhere to the existing DOE test
procedure that calculates an efficacy value using a specific sample
size and confidence limit procedure. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 149-151)
As specified in DOE's test procedures for GSFLs set forth at 10 CFR
part 430, subpart B, appendix R, lamp efficacy is the ratio of measured
lumen output in lumens to the measured lamp electrical power input in
watts rounded to the nearest tenth in units of lumens per watt. In the
2009 final rule for the GSFL and IRL test procedure, DOE amended the
test procedure to require reported efficacy measurements for GSFLs to
be rounded to the nearest tenth of a lumen per watt allowing for future
energy conservation standards to be rounded to the nearest tenth of a
lumen per watt. 74 FR 31829, 31836 (July 6, 2009). DOE concluded this
amendment to the test procedure was feasible because manufacturers
routinely generate test results that would allow reporting to at least
the tenth of a lumen per watt level. 74 FR at 31836 (July 6, 2009).
Therefore, DOE is analyzing efficacy levels in this rulemaking rounded
to the nearest tenth of a lumen per watt as DOE maintains
[[Page 24096]]
that this is an achievable level of accuracy.
Using High Frequency Test Data
According to NEMA, in recognition of the marketplace shift to
electronic high frequency (HF) ballasts, the American National
Standards Institute Lighting Group has drafted new standards for the
electrical and photometric characterization of GSFL T8 lamps that are
based on HF rather than the former low frequency 60 Hz reference
ballasts. When these new standards are published later in 2013, the
industry will comply and begin characterizing their products using HF-
based photometry. (NEMA, No. 36 at p. 2) NEMA also stated that current
test procedures unfairly compare energy-saver lamps to standard lamps,
owing to the removal of cathode heat voltage from the energy-efficiency
calculation of energy-saver lamps, thus they cannot be compared without
unfairly skewing the numbers in favor of low-wattage lamps. High
frequency measurement standards account for this difference. (NEMA, No.
36 at pp. 14-15) Therefore, NEMA recommends that this rulemaking should
be based on the new ANSI HF standards. (NEMA, No. 36 at p. 2)
The current GSFL test procedure as specified in 10 CFR part 430,
subpart B, appendix R requires lamps be tested at low frequency unless
only high frequency ballast specifications are available for the lamp.
The test procedure also specifies that for high frequency testing,
cathode heat should not be used when the lamp is in operation. DOE
acknowledges that high frequency reference specifications may be in
development for additional lamp types and may consider standards based
on high frequency operation after ANSI publishes the revised industry
standard.
700 Series Waiver
NEMA also noted that 700 series lamps are under the U.S. Office of
Hearings and Appeals (OHA) compliance waivers from the July 2012
standards. Therefore, their performance and market changes are still
several years away from being known. (NEMA, No. 36 at p. 1)
In April of 2012, several manufacturers \27\ were granted exception
relief exempting their 700 series T8 lamps from the July 2012 standards
for a period of two years. The waiver was granted due to the global
supply restrictions on rare earth phosphors, the rising world demand of
these phosphors, and the resulting impacts on producing higher efficacy
GSFLs.\28\ Because this waiver will expire in 2014, and any standards
adopted by this rulemaking are expected to require compliance in 2017,
DOE has conducted this analysis for GSFLs assuming that the waiver
would not be in place and has therefore not considered non-compliant
700 series lamps in its analysis. DOE notes that the term ``700
series'' is widely used in industry when referring to fluorescent lamps
with a CRI in the range of 70 to 79. See section V.A for the proposed
definition of a 700 series lamp.
---------------------------------------------------------------------------
\27\ At the time of this analysis, the following manufacturers
had been granted exception relief exempting their 700 series T8
lamps from current standards: Philips, GE, OSI, Ushio America, Halco
Lighting Technologies, Premium Quality Lighting, Inc., Tailored
Lighting, Inc., Litetronics International, Inc., Satco Products,
Inc., DLU Lighting USA, Westinghouse Lighting Corporation, Ascent
Battery Supply, LLC, Eiko, Ltd, Topaz Lighting Corporation,
Technical Consumer Products, Feit Electric Company.
\28\ Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001,
EXC-12-0002, EXC-12-0003 (2012). Accessible here: http://energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf.
---------------------------------------------------------------------------
b. Representative Product Classes
When a covered product has multiple product classes, DOE identifies
and selects certain product classes as representative and analyzes
those product classes directly. DOE chooses these representative
product classes primarily due to their high market volumes. For GSFLs,
in the preliminary analysis DOE identified all GSFLs with CCTs less
than or equal to 4,500 K with the exception of the 2-foot U-shaped
lamps as representative product classes as shown (in gray) in Table
VI.5. NEMA agreed with the representative product classes presented for
GSFLs. (NEMA, No. 36 at p. 7)
Table VI.5--GSFL Representative Product Classes
------------------------------------------------------------------------
Lamp type CCT
------------------------------------------------------------------------
4-foot medium bipin..................................... <=4,500 K
>4,500 K
2-foot U-shaped......................................... <=4,500 K
>4,500 K
8-foot single pin slimline.............................. <=4,500 K
>4,500 K
8-foot recessed double contact high output.............. <=4,500 K
>4,500 K
4-foot T5, miniature bipin standard output.............. <=4,500 K
>4,500 K
4-foot T5, miniature bipin high output.................. <=4,500 K
>4,500 K
------------------------------------------------------------------------
NEEA questioned why none of the products with CCT greater than
4,500 K were being directly analyzed and noted that at least one should
be assessed in order to ensure the analysis is accounting for the
magnitude of difference between greater than and less than or equal to
4,500 K CCT products. (NEEA, Public Meeting Transcript, No. 30 at p.
88)
As noted previously, DOE chose representative product classes based
on high market volumes. DOE received feedback from manufacturers in
interviews indicating that the volume of lamps with CCT greater than
4,500 K is considerably lower than the volume of lamps with CCT less
than or equal to 4,500 K. In addition, DOE used manufacturer feedback
and catalog data to quantify the difference in performance between
lamps with higher CCTs and lamps with lower CCTs. For these reasons,
DOE did not directly analyze lamps with CCT greater than 4,500 K in the
preliminary analysis and this NOPR analysis. DOE scaled the directly
analyzed product classes with CCTs less than or equal to 4,500 K to
those with CCTs greater than 4,500 K in the preliminary and NOPR
analyses. See section VI.D.2.h and chapter 5 of the NOPR TSD for
further information.
EEI stated it thought that the 2-foot U-shaped lamps would have
sales comparable to some of the other product classes. EEI also did not
agree with determining the efficiency standard for the 2-foot U-shaped
lamps using the 4-foot MBP lamps as a proxy. (EEI, Public Meeting
Transcript, No. 30 at p. 86-88)
In the preliminary analysis, DOE utilized the 4-foot MBP linear
fluorescent products to scale to the 2-foot U-shaped products, as both
products use the same fluorescent technology, span the same range of
wattages, and, without its bent curve, the 2-foot U-shaped lamp would
be approximately the same length as the 4-foot MBP linear lamp. Thus,
DOE could determine impact on efficacy from the bent curve and scale
from the 4-foot MBP product class. Further, the market share of 2-foot
U-shaped lamps is significantly lower than 4-foot MBP lamps. As
indicated in the LMC, T8 4-foot linear lamps comprise 44 percent of all
linear fluorescent lighting, whereas T8 2-foot U-shaped lamps make up
just 2 percent. Therefore, in this NOPR analysis, DOE did not directly
analyze the 2-foot U-shaped lamps and scaled ELs from the 4-foot MBP
product class to the 2-foot U-shaped product class. See section
VI.D.2.h and chapter 5 of the NOPR TSD for further information.
c. Baseline Lamps
Once DOE identifies the representative product classes for
analysis, it selects baseline lamps to analyze in each class.
Typically, a
[[Page 24097]]
baseline lamp is the most common, least efficacious lamp that just
meets existing energy conservation standards. For fluorescent lamps,
the most common lamps were determined based on characteristics such as
wattage, lumen output, lifetime, and CCT. To identify baseline lamps,
DOE reviews product offerings in catalogs, shipment information, and
manufacturer feedback obtained during interviews.
In the preliminary analysis, DOE considered commercially available
lamps as baselines. In some cases, the most common, least efficacious
commercially available product was at an efficacy above the existing
standard level. Specifically, for the 8-foot RDC HO, T5 MiniBP SO, and
T5 MiniBP HO product classes, DOE was unable to identify a commercially
available product at the existing standard level. DOE received several
comments regarding the selection of these lamps with efficacies higher
than the existing standard levels as baselines.
NEMA stated that the arguments for baseline, CSL 0 in the
preliminary TSD, are based on predictions of market shift that
erroneously justify a new baseline higher than the minimum requirements
put forth by the 2009 Lamps Rule. (NEMA, No. 36 at p. 1) NEMA
questioned why the baselines for product classes were not set at the
standard level adopted in the 2009 Lamps Rule. (NEMA, Public Meeting
Transcript, No. 30 at pp. 85-85) The CA IOUs recommended DOE use the
efficacy levels set in the 2009 Lamps Rule as the baselines for all
GSFL product classes because minimum product performance generally
gravitates to the minimum standards set for the product. (CA IOUs, No.
32 at p. 13) GE concurred, stating that the market will move to lamps
at that level due to the cost of rare earth materials. Therefore, GE
asserted that it is easy to make the assumption that lamps will
gravitate towards that minimum level over time and that that should be
the analysis going forward over the next six to ten years. (GE, Public
Meeting Transcript, No. 30 at pp. 93-94)
NEEA and NPCC agreed that DOE should use products that minimally
comply with existing standards as baselines and this would be validated
by the measured and/or certified values. (NEEA and NPCC, No. 34 at p.
1, 4) The CA IOUs also noted that the certification database shows that
there are products right at the level, particularly for the 4-foot MBP
class. (CA IOUs, Public Meeting Transcript, No. 30 at pp. 93-94)
As noted previously, DOE assesses commercially available products
on the market and chooses baseline lamps representative of the common
characteristics within that product class and just meet existing
standards. However, feedback from stakeholders and manufacturer
interviews has indicated that manufacturers will likely produce lamps
at the existing standard level even if no products are currently
available. Further, after the 2009 Lamps Rule, DOE observed the
introduction of products that were not previously available at the
newly adopted standard levels for some product classes. Thus, DOE
believes this trend could continue and additional lamps may be offered
that just meet the existing standard level for the remaining product
classes.
Therefore, in this NOPR analysis DOE is proposing baselines at the
existing standard levels for all product classes. For the 4-foot MBP
product class, DOE determined the baseline selected in the preliminary
analysis to be the least efficient product on the market at the
existing standards. For the 8-foot SP slimline product class, DOE also
changed the baseline lamp to be the least efficient product on the
market at the existing standards. For representative product classes in
which there were no commercially available lamps at the existing
standard level, DOE modeled baseline lamps. To determine the
performance characteristics of these lamps, DOE took the ANSI rated
wattage of the most common, least efficacious commercially available
lamp and calculated the lumen output required to develop an efficacy at
the existing standard level. DOE assumed the modeled baseline lamp
would have similar characteristics as the most common commercially
available lamps in each product class, including lifetime and lumen
depreciation. DOE modeled baseline lamps for the 8-foot RDC HO, T5
MiniBP SO, and T5 MiniBP HO product classes.
If DOE considered additional types of GSFLs in the scope of this
rulemaking, NEEA and NPCC recommended that for product classes that do
not currently have a standard, DOE should establish the baseline at the
lowest level of efficiency commonly found in the marketplace. (NEEA and
NPCC, No. 34 at p. 1, 4) In this NOPR analysis, DOE is not considering
additional types of GSFLs that are not subject to standards. See
section V.B for more details.
NEEP noted that the 2011 Vermont Market Characterization and
Assessment Study conducted by Navigant for Vermont's Public Service
Department (mentioned previously in this notice) established baselines
for certain products in the state's commercial sector. NEEP urged DOE
to utilize the fluorescent lighting data collected to corroborate DOE's
findings. (NEEP, No. 33 at p. 3)
DOE reviewed the study and found that, given the level of detail
provided, it was difficult to use the results to corroborate DOE's
baseline selections. The study aims to characterize the prevalence of
T8 lamps, high performance T8 lamps, T12 lamps, and T5 lamps in the
state of Vermont. While it provides market share information for
standard T8s and high performance T8s, it does not provide this
information by level of efficiency for T5 lamps. Further, the lengths
of these lamp types are not included, and thus DOE was unable to
compare the results on a product class basis.
When considering general overall trends, the study confirmed that
T8 lamps are significantly more prevalent than T12 lamps, and T8
standard efficiency lamps are more commonly installed than high
performance T8 lamps. These high level results support certain aspects
of the baseline selections, namely the selection of T8 standard
performance lamps at the baseline. However, the study covers a very
limited service area and therefore cannot be regarded as indicative of
the most commonly installed lamp types at a national level.
DOE is proposing the baseline lamps for GSFLs specified in Table
VI.6. See chapter 5 of the NOPR TSD for further details on this
assessment. DOE requests comment on the baseline lamps analyzed in the
NOPR analysis, in particular the modeled baseline lamps in the 8-foot
RDC HO, T5 MiniBP SO, and T5 MiniBP HO product classes.
[[Page 24098]]
[GRAPHIC] [TIFF OMITTED] TP29AP14.000
d. More Efficacious Substitutes
DOE selects more efficacious replacements for the baseline lamps
considered within each representative product class. DOE considers only
design options identified in the screening analysis. In the preliminary
analysis, these selections were made such that potential substitutions
maintained light output within 10 percent of the baseline lamp's light
output with similar performance characteristics, when possible. DOE
also sought to keep other characteristics of substitute lamps as
similar as possible to the baseline lamps, such as rated life, CRI, and
CCT. In identifying the more efficacious substitutes, DOE utilized a
database of commercially available lamps. DOE received comments
regarding its choices for more efficacious substitutes in the
preliminary analysis.
T5 HO Product Class
For the preliminary analysis, in its assessment of commercially
available products, DOE was unable to find a full wattage T5 HO lamp
with an efficacy higher than the baseline. However, DOE did find
several more efficacious, reduced wattage T5 HO lamps at higher levels
of efficacy. As discussed in section VI.D.2.e, DOE is only analyzing
efficacy levels that can be met by full wattage lamps. Therefore, in
the preliminary analysis, DOE modeled a more efficacious full wattage
T5 HO lamp. Specifically, DOE created a higher efficacy model lamp
using a more efficacious commercially available reduced wattage T5 HO
lamp to calculate the characteristics of a full wattage T5 HO lamp of
comparable efficacy. The CSL considered for the T5 HO product class was
set according to the efficacy of this modeled full wattage lamp.
DOE received several comments regarding this approach. NEMA stated
that it could not comment on the manufacturability or functionality of
the T5 HO model lamp put forth in the preliminary analysis because the
product does not exist, and it is poor practice to invent new products.
(NEMA, No. 36 at p. 8) NEMA stated that if DOE is unable to use a
commercially available lamp for analysis for this product class it
should not pursue an increased efficiency level. However, in the case
that DOE does intend to further regulate this product class, NEMA
stated DOE should arrange for the construction and testing of a
representative number of this modeled lamp to obtain information on
manufacturing feasibility. (NEMA, No. 36 at p. 8-9) Philips agreed,
stating that DOE is designing and inventing new lamps and it is not
known whether they are even feasible. This approach could potentially
result in a product class where there are no products available.
(Philips, Public Meeting Transcript, No. 30 at p. 124)
GE stated it had to get more information but noted that its
engineers had significant concerns regarding the T5 MiniBP HO model
lamp and the high efficacy of the max tech level being considered for
this product class. Noting that it had not seen DOE take this approach
before, GE stated that DOE seems to be going from T5 efficacy levels
that are relatively easy to meet to efficacy levels that may not even
be technically feasible. (GE, Public Meeting Transcript, No. 30 at pp.
125-126)
In the preliminary analysis, DOE concluded that the higher efficacy
level achieved by reduced wattage T5 HO lamps demonstrated the
potential for a full wattage lamp to achieve an efficacy level above
the baseline. Accordingly, DOE modeled the lamp efficacy of a higher
efficacy full wattage lamp using commercially available reduced wattage
lamps. DOE acknowledged in the preliminary analysis that in determining
whether it is appropriate to consider a CSL based on this model lamp,
DOE would gather additional information on the manufacturability and
functionality of this lamp, as well as its projected efficacy, when
measured according to the DOE test procedure. DOE does not have the
necessary information to determine whether the higher efficacy full
wattage T5 HO model lamp was technologically feasible, and therefore is
not considering the higher efficacy modeled T5 HO lamp in the NOPR
analysis.
As noted previously, in response to the stakeholder comments
discussed in section VI.D.2.c, DOE modeled a
[[Page 24099]]
baseline lamp for the NOPR analysis because the T5 HO product class
does not have a commercially available lamp that just meets the
existing standard. Because there are full wattage products that have
demonstrated efficacy higher than the existing standard, DOE believes
the modeled baseline lamp is feasible. Based on this new baseline, in
the NOPR analysis DOE was able to identify a more efficacious full
wattage T5 HO substitute that is commercially available. The more
efficacious T5 HO lamps are shown in Table VI.7.
Lifetime Characteristics
NEEP stated that Energy Efficiency Program Administrators from
Efficiency Vermont and National Grid noted that the rated life values
for the lamps DOE has identified as more efficacious substitutes (for
4-foot MBP) are low. They specifically pointed out that GE's reduced
wattage 25 and 28 W lamps and their high lumen 32 W lamps are all rated
between 40-50,000 hours (instant start [IS], 3 hours per start).
Further Philips rates their reduced wattage 25 and 28 W lamps at 32,000
hours (IS, 3 hours per start). ``Extended life'' lamps offer even
longer rated lifetimes. (NEEP, No. 33 at p. 3)
As noted in section VI.D.2.c, baseline lamps are selected in part
based on the most common characteristics of their respective product
classes, and DOE selects more efficacious substitutes with similar
performance characteristics as the baseline representative unit when
possible. Thus, the baseline and more efficacious substitutes selected
represent the most common lifetimes for each product class. In the case
of the 4-foot MBP product class, DOE found that a 24,000 hour lifetime
on IS ballasts with 3 hour starts and a 40,000 hour lifetime on
programmed start ballasts with 3 hour starts were the most common
lifetimes for the product class. DOE notes that the rated lifetime
values cited by NEEP for GE's reduced wattage 25 and 28 W lamps and
high lumen 32 W lamps represent rated lifetime on a programmed start
ballast with 3 hour starts rather than an IS ballast. Therefore the 40-
50,000 hour lifetimes cited by NEEP do align with the rated lifetimes
(programmed start, 3 hours per start) of the more efficacious
substitutes selected. Further, DOE received manufacturer feedback
during interviews that the lifetime values of the more efficacious
substitutes were representative of their respective product classes.
Therefore, in this NOPR analysis, DOE is maintaining the same more
efficacious substitutes as selected in the preliminary analysis. DOE
requests comment on the rated lifetimes of the GSFL baselines and more
efficacious substitutes.
Summary of GSFL Representative Lamps
DOE received no other comments regarding the selection of more
efficacious substitutes for GSFLs. The GSFL representative lamps
analyzed in the NOPR are shown in Table VI.7.
Table VI.7--GSFL Representative Lamps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Nominal Rated Rated Initial Mean light Life
wattage wattage efficacy light output ------------
Product classes EL Lamp ------------------------------------ output ------------ CRI
diameter ------------ hr
W W lm/W lm lm
--------------------------------------------------------------------------------------------------------------------------------------------------------
4-foot MBP....................... EL 1................. T8 32 32.5 90.0 2,925 2,770 21,000 85
EL 2................. T8 25 26.6 93.0 2,475 2,350 24,000 85
EL 2................. T8 32 32.5 95.4 3,100 2,945 24,000 85
EL 2................. T8 28 28.4 96.0 2,725 2,590 24,000 85
8-foot SP slimline............... EL 1................. T8 59 60.1 98.2 5,900 5,490 24,000 85
EL 2................. T8 59 60.1 99.0 5,950 5,650 24,000 85
EL 2................. T8 54 54.0 105.6 5,700 5,415 24,000 85
EL 2................. T8 50 50.0 108.0 5,400 5,075 24,000 85
8-foot RDC HO.................... EL 1................. T8 86 84.0 95.2 8,000 7,600 18,000 78
EL 2................. T8 86 84.0 97.6 8,200 7,800 18,000 86
T5 MiniBP SO*.................... EL 1................. T5 28 27.8 93.5 2,600 2,418 30,000 85
EL 2................. T5 28 27.8 98.2 2,730 2,594 30,000 85
EL 2................. T5 26 26.0 100.0 2,600 2,470 30,000 85
EL 2................. T5 25 25.0 104.0 2,600 2,475 35,000 85
T5 MiniBP HO*.................... EL 1................. T5 54 53.8 82.7 4,450 4,275 25,000 85
EL 1................. T5 49 49.0 90.8 4,450 4,140 35,000 85
EL 1................. T5 47 47.0 91.9 4,320 3,969 30,000 84
--------------------------------------------------------------------------------------------------------------------------------------------------------
* 4-foot T5 MiniBP SO and HO rated efficacy, initial lumen output, and mean lumen output given at 25 [deg]C.
e. General Service Fluorescent Lamp Systems
Because fluorescent lamps operate on a ballast in practice, in the
preliminary analysis, DOE analyzed lamp-and-ballast systems, thereby
more accurately capturing real-world energy use and light output. In
the DOE test procedure for GSFLs, and therefore in this rulemaking,
lamp efficacy is based on the initial lumen output. However, because
light output decreases over time, in the preliminary analysis DOE
analyzed more efficacious systems that maintain mean lumen output \29\
within 10 percent of the baseline system, when possible. Further, in
the preliminary analysis, DOE selected replacement systems that do not
have higher energy consumption than the baseline system.
---------------------------------------------------------------------------
\29\ Mean lumen output is a measure of light output midway
through the rated life of a lamp.
---------------------------------------------------------------------------
DOE considered two different scenarios in the preliminary analysis:
(1) A lamp replacement scenario in which the consumer selects a reduced
wattage replacement lamp that can operate on the installed ballast and
(2) a lamp-and-ballast replacement scenario in which the consumer
selects a lamp that has the same or lower wattage compared to the
baseline lamp and also selects a new ballast with potentially different
performance characteristics, such as ballast factor \30\ (BF) or
ballast
[[Page 24100]]
luminous efficiency \31\ (BLE). In the preliminary analysis, for the
second scenario DOE attempted to select a ballast that would result in
energy savings and still maintain the mean lumen output within 10
percent of the baseline. In cases where energy savings were not
possible without going beyond the 10 percent threshold of the baseline
mean lumen output, DOE gave priority to energy savings. This resulted
in the mean lumen output being either 10 percent above or below the
baseline lumens for certain lamp-and-ballast scenarios.
---------------------------------------------------------------------------
\30\ BF is defined as the output of a ballast delivered to a
reference lamp in terms of power or light divided by the output of
the relevant reference ballast delivered to the same lamp (ANSI
C82.13-2002). Because BF affects the light output of the system,
manufacturers design ballasts with a range of ballast factors to
allow consumers to vary the light output, and thus power consumed,
of a fluorescent system. See the 2011 Ballast Rule final rule TSD
Chapter 3. The Ballast Rule materials are available at
www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016.
\31\ BLE is the ratio of the total lamp arc power to ballast
input power multiplied by the appropriate frequency adjustment
factor.
---------------------------------------------------------------------------
DOE received several comments regarding its methodology in
identifying more efficacious lamp-and-ballast systems, specifically
regarding selection of ballasts, maintenance of mean lumen output
within 10 percent of the baseline, and energy saving options not
explored in the preliminary analysis.
Ballast Selection
NEMA agreed with the lamp and ballast pairings presented in the
preliminary analysis. (NEMA, No. 36 at p. 8) However, NEMA also stated
that GSFL performance is highly dependent on ballast selection and
pairing. NEMA pointed out that NES of lighting systems will not be
affected significantly by this proposed rulemaking on GSFL efficacy due
to the overwhelming influence of ballast selection on final
performance. (NEMA, No. 36 at p. 1)
As mentioned, because fluorescent lamps operate on a ballast in
practice, DOE analyzed lamp-and-ballast systems in the engineering
analysis. The impacts of these systems on NES were analyzed in the NIA.
See section VI.I for more information on the NES of the proposed GSFL
systems.
The CA IOUs expressed concern regarding some of the replacement
systems identified, including lamps operating on residential ballasts
and programmed start ballasts. The CA IOUs questioned why a residential
ballast with a ballast factor of 0.83 was selected when DOE could have
chosen a ballast with a lower ballast factor of 0.77 and still stayed
within five percent of initial lumens. (CA IOUs, Public Meeting
Transcript, No. 30 at p. 253-255) The CA IOUs also questioned a
specific lamp-and-ballast replacement scenario considered in the
preliminary analysis in which a nominal 32 W lamp with an efficacy of
95 lm/W, installed with a 0.88 BF ballast, replaced a 32 W lamp at 89.2
lm/W, also using a 0.88 BF ballast. (See table 8.5.3 of the preliminary
TSD.) The CA IOUs noted that this retrofit results in a 7 percent
increase in light output and no reduction in energy consumption. If DOE
had paired a 0.78 BF ballast with the more efficacious lamp, the
retrofit would have resulted in a reduction in light output of only 5
percent, and would achieve some reduction in energy consumption and
some energy cost savings for the end user. (CA IOUs, No. 32 at pp. 13-
14)
In the preliminary analysis, DOE considered only commercially
available ballasts when selecting ballasts to pair with lamps. The CA
IOUs suggested a ballast with a 0.77 BF for the residential 2-lamp
instant start replacement scenario and a ballast with a 0.78 BF for the
2-lamp programmed start scenario, however, DOE found that these
ballasts do not exist. Because there were no residential 2-lamp instant
start low BF ballasts or 2-lamp programmed start low BF ballasts
commercially available that would also maintain mean lumen output
within 10 percent of the baseline system, DOE was unable to analyze
ballasts with lower BFs than those selected for these scenarios. DOE
instead selected the same ballast as the baseline as this was the
lowest BF ballast commercially available.
Ten Percent Mean Lumen Output Threshold
NEMA explained that in the past it was common practice to reduce
light levels by 10 percent or more when retrofitting from a T12 to a T8
lighting system because older lighting systems were typically designed
to higher light levels. Over the years, IES light level requirements
have been reduced, especially in office applications where the use of
computers reduces the need for high light levels. DOE must analyze the
future retrofit situation that will occur after 2018 in which 4-foot
linear fluorescent systems will have been retrofitted to a T8 or better
fluorescent system already operating at the appropriate lower light
levels. Retrofits beyond this 2018 time period should be expected to
maintain the new, lower recommended IES light levels where they are
already in place. Therefore, unlike T12 to T8 conversions, projecting
further light level reductions of 6 to 14 percent as is done in DOE's
analysis cannot be justified against the T8 systems operating in 2018.
For a fair economic comparison, DOE should seek to match the existing
light levels within a +/- 5 percent range. (NEMA, No. 36 at p. 8; GE,
Public Meeting Transcript, No. 30 at pp. 90-91; GE, Public Meeting
Transcript, No. 30 at pp. 110-112; Philips, Public Meeting Transcript,
No. 30 at pp. 105-106)
GE stated that it is not typical to replace lighting systems lamp
for lamp that are more than 10 percent lower in light output unless the
space is considered overlit to begin with or the space was repurposed.
(GE, Public Meeting Transcript, No. 30 at pp. 90-91) For a fair
comparison between lighting systems, GE recommended that DOE stay as
close as possible to 10 percent and not to go beyond this threshold as
some systems do in the analysis presented. (GE, Public Meeting
Transcript, No. 30 at pp. 119-120)
EEI agreed that at this time, retrofits are being done from T8 to
T8 and electronic ballast to electronic ballast and therefore lumen
depreciation is limited, at most 10 percent versus 20 or 30 percent
when replacing a T12. EEI noted that this could make a difference in
design for a new building and total renovations that are meeting
building codes. (EEI, Public Meeting Transcript, No. 30 at pp. 109-110)
EEI recommended analyzing equal to or higher lumen output replacement
systems to maximize consumer utility in terms of maintaining lumen
output in retrofit scenarios. (EEI, Public Meeting Transcript, No. 30
at p. 121) Cooper Lighting added that light level is important in
accurately and correctly doing a task in a space and the impact of
light levels on efficiency in the workplace should be given
consideration. (Cooper, Public Meeting Transcript, No. 30 at pp. 110)
The CA IOUs agreed with DOE's analysis of replacement systems that
maintained mean lumen output within 10 percent of the mean lumens of
the baseline system. Based on experience from offering rebate lamps
through its programs, the CA IOUs had found that nine times out of ten
after changing the lights in a commercial space, the complaints are
that it is too bright. The CA IOUs asserted that most spaces were not
designed exactly to IES standards but give a little extra light
initially. Additionally, the CA IOUs noted that lumen maintenance is a
significant issue with fluorescent systems, particularly because the
replacement of older T12 systems with newer, more efficacious systems
makes the space seem even brighter after a retrofit. The CA IOUs
further stated that the scenarios where you increase light output by 5,
8, 12 percent are not going to work for consumers and reducing light
output by 2, 4, 6, 8 percent will still seem too bright. (CA IOUs,
Public Meeting Transcript, No. 30 at pp. 106-108)
As stated previously, because light output decreases over time, DOE
[[Page 24101]]
analyzed more efficacious systems that maintain mean lumen output
within 10 percent of the baseline when possible. DOE established the 10
percent threshold based on feedback from manufacturers that, in
general, consumers would not notice a change in light output that is up
to 10 percent. Manufacturers noted during interviews that when a space
needs to be relamped, lumen depreciation has already typically occurred
and thus lower light levels of a newly installed lamp would likely not
be detected. Manufacturers also noted that while application dependent,
designing to achieve energy savings is common and a decreased lumen
output as a result is generally accepted as long as it is somewhere in
the range of 10 percent of the baseline system mean lumen output. DOE
concluded that selecting lamp-and-ballast system replacements within 10
percent of the baseline system when possible ensures sufficient light
levels are maintained and accurately reflects common practices.
Therefore, in this NOPR analysis, DOE is continuing to utilize the
criterion of maintaining 10 percent of the mean lumen output when
possible in developing lamp-and-ballast replacement scenarios. If it
was not possible to identify a lamp-and-ballast replacement that
maintained the 10 percent mean lumen output criterion, DOE prioritized
energy savings and analyzed a lamp-and-ballast system that reduced
light output by more than 10 percent \32\ but saved energy relative to
the baseline system. DOE continued to do this in the NOPR analysis
because feedback during manufacturer interviews confirmed that changes
in mean lumen output outside 10 percent of the baseline system are
acceptable in some applications.
---------------------------------------------------------------------------
\32\ Light output was reduced up to 18 percent in some
replacement scenarios. The percent reduction in light output was
based on the ballast factor of the commercially available ballasts
analyzed. For more information, see chapter 5 of the NOPR TSD.
---------------------------------------------------------------------------
In the preliminary analysis, some lamp-and-ballast replacement
systems maintained light output within 10 percent of the baseline
system but did not save energy. DOE analyzed these lamp and ballast
combinations as the only replacement option because they met the 10
percent mean lumen output criterion. For the NOPR analysis, DOE
considered additional scenarios for this situation based on feedback
from stakeholders and manufacturer interviews. DOE added another
replacement option in which the consumer could prioritize energy
savings by selecting a lamp-and-ballast system that reduced lumen
output by more than 10 percent but also reduced energy consumption.
Therefore, for certain lamp-and-ballast replacement scenarios, two
ballast selections may exist: (1) A ballast that maintains system mean
lumen output within 10 percent of the baseline; and (2) a ballast that
achieves energy savings but does not maintain system mean lumen output
within 10 percent of the baseline. DOE added this option only if
ballasts with the required lower ballast factor were commercially
available. Thus, it remains possible that certain scenarios do not
result in energy savings if a lower BF ballast or reduced wattage lamp
is not available (e.g., 8-foot RDC HO product class). See chapter 5 of
the NOPR TSD for more information.
In response to the lamp-and-ballast system selections presented in
the preliminary analysis, EEI commented that light output was being
reduced between 8 and 13.8 percent. EEI stated this is important
because even if it is possible to meet the watts per square
requirements in new buildings, the lumen output requirements on the
surface must also be met by putting in more fixtures. Therefore, EEI
argued that system input power calculations presented in the
preliminary analysis may show savings that disappear once the space is
designed to put in more fixtures. (EEI, Public Meeting Transcript, No.
30 at pp. 103-105) Philips noted that putting in more fixtures is not
going to help because fixtures are mainly in the middle of the room.
(Philips, Public Meeting Transcript, No. 30 at pp. 105-106)
As noted, for the lamp-and-ballast replacement scenarios, DOE
attempted to select a ballast that would result in energy savings and
still maintain the mean lumen output within 10 percent of the baseline
when possible. DOE determined that maintaining 10 percent of mean lumen
output allows for changes in lumen output within an acceptable range to
the consumer. If this was not possible, DOE prioritized energy savings
and analyzed a lamp-and-ballast system that reduced light output by
more than 10 percent but saved energy relative to the baseline system.
DOE did not analyze the installation of additional fixtures due to
feedback received from stakeholders that spacing adjustments are not
practical (for a discussion of this conclusion, see section VI.G.9).
Energy Savings Over Light Output
The CA IOUs and NEEA and NPCC did not agree with DOE's
consideration of lamp-and-ballast system replacements where the light
output increases without a reduction in system wattage. (CA IOUs, No.
32 at pp. 13-14; NEEA and NPCC, No. 34 at p. 2, 4) The CA IOUs stated
that commercial occupants are sensitive to changes in workplace
lighting, and react negatively to light increases. Furthermore,
commercial building operators are very sensitive to operating costs;
and will choose the retrofit option that results in energy cost savings
without significantly reducing the light levels unless the space was
known to be underlit. Therefore, where DOE is presented with a choice
between a lighting retrofit that would result in an increase of light
levels between 0-10 percent, with no energy savings, and another that
would result in a decrease of light levels between 0-10 percent, with
energy savings, DOE should model the energy saving option as the most
likely scenario for consumers. (CA IOUs, No. 32 at p. 14)
The CA IOUs and NEEA and NPCC cited the following available options
for reducing system wattage without reducing system lumen output by
more than 10 percent: installing reduced wattage lamps, reducing
ballast factors, delamping, and installing dimming ballasts. Though
some reduced wattage T8 lamps currently have some difficulty dimming as
well as their full wattage counterparts, this is only an issue for
lamps installed with dimming ballasts. (Although, they noted that this
may be improving in the future through the use of dimming ballasts
designed to operate reduced wattage lamps.) The CA IOUs noted that
reduced wattage lamps, lower ballast factor ballasts, or delamping are
valid options, when not using a dimming ballast. Further even if a
dimming ballast is installed, higher efficacy (brighter), full wattage
lamps can be installed and tuned to the appropriate light level, which
reduces system wattage. (CA IOUs, No. 32 at pp. 13-14)
The CA IOUs and NEEA and NPCC noted that using these measures to
achieve energy savings for the end user is a far more likely scenario
for a real-world lighting retrofit project. (CA IOUs, No. 32 at pp. 13-
14; NEEA and NPCC, No. 34 at p. 2, 4) NEEA and NPCC added that
resulting energy cost savings also help pay for the retrofit, and
retrofits may only infrequently result in increased light levels. (NEEA
and NPCC, No. 34 at p. 2, 4)
DOE acknowledges that consumers may prioritize energy savings over
maintaining light output in some applications. DOE also observes that
several options exist to reduce system wattage while maintaining lumen
output. DOE analyzed reduced wattage lamps and low BF ballasts as
[[Page 24102]]
replacement options in the engineering analysis. DOE also analyzed the
use of dimming ballasts paired with both reduced wattage and full
wattage lamps (for applicable product classes) to achieve energy
savings in a lighting controls scenario conducted as a sensitivity in
the LCC and NIA. See appendix 6A and chapter 12 of the NOPR TSD for
further information on the dimming analysis.
In addition to the above mentioned approaches utilized in the
preliminary analysis, DOE added scenarios in the NOPR to incorporate
the feedback from stakeholders that some consumers would prioritize
energy savings over increasing or maintaining light output. As
discussed previously, for the lamp-and-ballast replacement scenarios
that resulted only in increased light output, DOE added another
replacement option for this situation in which the consumer could
prioritize energy savings by selecting a lamp-and-ballast system that
reduced lumen output by more than 10 percent but also reduced energy
consumption. DOE received feedback from manufacturers that maintenance
of less than 10 percent of lumen output of the baseline system is more
likely than increasing lumen output when replacing systems in order to
achieve energy savings. Thus, DOE added the option for a consumer to
select a lower BF ballast, if commercially available, that results in
mean lumen output outside 10 percent of the baseline system in order to
provide an energy-saving option if possible. As in the preliminary
analysis, DOE did not consider delamping in this NOPR because
manufacturer feedback confirmed that delamping is not common practice
when retrofitting existing T8 systems.
Summary
DOE maintained its overall methodology from the preliminary
analysis for selecting lamp-and-ballast systems with the addition of
new replacement options in some scenarios for the NOPR analysis to
incorporate stakeholder feedback. To develop representative lamp-and-
ballast system pairings, DOE used manufacturer feedback and information
provided in the 2011 Ballast Rule to determine the most common
fluorescent lamp ballasts. In the preliminary and NOPR analyses, DOE
paired the representative ballasts utilized in the 2011 Ballast Rule
with the representative lamps selected in this analysis to characterize
the most common lamp-and-ballast combinations present in the market.
In events where consumers needed to replace both the lamp and the
ballast, DOE identified a new lamp-and-ballast system by pairing a more
efficacious lamp with a commercially available ballast that had the
lowest BF possible that still maintained system mean lumen output
within 10 percent of the baseline system. When multiple ballast options
with the same BF existed, DOE selected the most efficient ballast based
on the BLE metric, as this was considered to be the most likely ballast
substitute in a lamp-and-ballast replacement scenario designed to
achieve energy savings. If it was not possible to identify a lamp-and-
ballast replacement that maintained the 10 percent mean lumen output
criterion, DOE prioritized energy savings and analyzed a lamp-and-
ballast system that reduced light output by more than 10 percent \33\
but saved energy relative to the baseline system.
---------------------------------------------------------------------------
\33\ Light output was reduced up to 18 percent in some
replacement scenarios. The percent reduction in light output was
based on the ballast factor of the commercially available ballasts
analyzed. For more information, see chapter 5 of the NOPR TSD.
---------------------------------------------------------------------------
In the preliminary analysis, some lamp-and-ballast replacement
systems maintained light output within 10 percent of the baseline
system but did not save energy. In the preliminary analysis, DOE
analyzed these lamp-and-ballast combinations as the only replacement
option because they met the 10 percent mean lumen output criterion.
However, in the NOPR analysis, DOE added another replacement option for
this situation in which the consumer could prioritize energy savings by
selecting a lamp-and-ballast system that reduced lumen output by more
than 10 percent but also reduced energy consumption. DOE added this
option only if ballasts with the required lower BF were commercially
available. See chapter 5 of the NOPR TSD for more information. DOE
welcomes comments on its methodology for developing lamp-and-ballast
systems and as well as the results of these GSFL systems.
f. Maximum Technologically Feasible
DOE received several comments on the max tech level presented in
the preliminary analysis for GSFLs. Lutron commented that with the
exception of the 4-foot MBP class, CSLs presented in the preliminary
analysis were higher than the max tech levels identified in the 2009
Lamps Rule. Lutron noted that for the 8-foot SP slimline product class
the max tech level in the 2009 Lamps Rule was 98 lm/W while the CSL
level being considered is at 99 lm/W; for the 8-foot RDC HO product
class the 2009 Lamps Rule max tech was 95 lm/W while the preliminary
analysis CSL is 97 lm/W; for the T5 MiniBP SO product class the 2009
Lamps Rule max tech level was 90 lm/W while the preliminary analysis
CSL is 98.2 lm/W; for the T5 MiniBP HO product class the 2009 Lamps
Rule max tech level was 76 lm/W and the preliminary analysis CSL is
86.2 lm/W. (Lutron, Public Meeting Transcript, No. 30 at pp. 129-130)
NEEA and NPCC doubted the data used because CSLs presented were at
higher efficacy levels than the max tech levels identified in the 2009
Lamps Rule. (NEEA and NPCC, No. 34 at p. 2, 3) NEMA also commented that
having one CSL eliminates DOE's ability to analyze standard levels
other than the baseline and max tech and makes it more likely that max
tech will become the new standard. (NEMA, Public Meeting Transcript,
No. 30 at p. 350)
NEMA asked for an explanation of CSL levels higher than the max
tech identified in the 2009 Lamps Rule for the 8-foot lamps. (NEMA,
Public Meeting Transcript, No. 30 at pp. 12-13) Lutron stated and NEMA
concurred that unless there had been major technological breakthrough
in fluorescent lamps, adopting standards more stringent than the max
tech levels identified in the 2009 Lamps Rule would not be justified.
(Lutron, Public Meeting Transcript, No. 30 at pp. 129-130; NEMA, Public
Meeting Transcript, No. 30 at pp. 137) Philips and GE confirmed that
there had been no recent technology changes in fluorescent lamp
technology to warrant higher levels being considered than the max tech
levels identified in the 2009 Lamps Rule. (Philips, Public Meeting
Transcript, No. 30 at p. 130; GE, Public Meeting Transcript, No. 30 at
p. 130-131) NEMA concluded that because there have been no noteworthy
technological breakthroughs since the last rulemaking or great changes
in the market, the maximum-feasible performance levels of the previous
rule have not changed (NEMA, No. 36 at p. 1)
GE noted that because the 2009 Lamps Rule was moving from
relatively modest efficiency levels, the discussion did not center
around what lm/W are being reported and what is stated in catalogs.
However, GE noted that in this rulemaking because the levels being
considered are at very high levels it is important to consider whether
the lm/W numbers are actually achievable. GE recommended that for max
tech levels DOE use test data that show exactly what these products are
capable of and not base levels on marketing claims to avoid situations
where the established efficacy turns out to be unachievable, resulting
in the elimination of a product class. (GE, Public Meeting Transcript,
[[Page 24103]]
No. 30 at pp. 144-146) Specifically, GE noted that it was concerned
that the CSLs presented were based on more aggressive marketing claims
in catalogs and not on any real change in technology. (GE, Public
Meeting Transcript, No. 30 at pp. 138-139)
DOE identified several commercially available lamps performing at
efficacy levels higher than the max tech levels established in the 2009
Lamps Rule. Thus, manufacturers appear to be utilizing more advanced
technologies or to be more efficiently utilizing existing technologies.
The efficacy values provided in manufacturer product catalogs and
certification data supplied by manufacturers indicate that these levels
are achievable. DOE welcomes comment on the max tech levels identified
in this analysis and more information on the accuracy of catalog and
certification data.
g. Efficacy Levels
After identifying more efficacious substitutes for each of the
baseline lamps, in the preliminary analysis DOE developed CSLs based on
the consideration of several factors, including: (1) The design options
associated with the specific lamps being studied (e.g., grades of
phosphor for GSFLs); (2) the ability of lamps across wattages to comply
with the standard level of a given product class; \34\ and (3) the max
tech level. When evaluating CSLs in the preliminary analysis, DOE
considered only CSLs at which a full wattage version of the lamp type
was available because reduced wattage lamps have limited utility. DOE
received several comments on the CSLs considered in the preliminary
analysis.
---------------------------------------------------------------------------
\34\ ELs span multiple lamps of different wattages. In selecting
CSLs, DOE considered whether these multiple lamps can meet the ELs.
---------------------------------------------------------------------------
NEMA recommended revisions to the CSLs presented in the preliminary
analysis. Specifically, NEMA proposed a level at 89 lm/W for the 4-foot
MBP product class, 97 lm/W for the 8-foot SP slimline product class, 94
lm/W for the 8-foot RDC HO product class, 90 lm/W for the 4-foot T5
MiniBP SO product class, and 80 lm/W for the 4-foot T5 MiniBP HO
product class. (NEMA, No. 36 at p. 9) Further, in reference to T5
lamps, NEMA noted that regardless of whether DOE had presented CSLs at
25 [deg]C or 35 [deg]C, the efficacies of the analyzed products are too
high to serve as representative products. (NEMA, No. 36 at p. 10)
In the preliminary analysis, DOE considered two CSLs for the 4-foot
MBP product class. DOE found two levels of efficacy above the existing
standard that commercially available lamps were able to achieve. The
baseline represented a standard 800 series full wattage T8 lamp. CSL 1
(90.0 lm/W) represented an improved 800 series full wattage T8 lamp in
which the phosphor mix and/or coating was enhanced to increase
efficacy. CSL 2 (93.0 lm/W) represented an 800 series full wattage T8
high lumen lamp able to achieve a higher efficacy with even more
advanced phosphors. Reduced wattage lamps also met CSL 2. DOE analyzed
publicly available certification data to determine if any adjustments
were needed to ensure that proposed levels can be met based on the
certification data. DOE determined that the representative units and/or
equivalent lamps complied with the CSLs for the 4-foot MBP product
class. DOE therefore concluded that no adjustments were necessary in
the preliminary analysis based on the available certification data.
In response to the preliminary analysis CSLs, NEMA proposed
revising CSL 1 to 89 lm/W for the 4-foot MBP product class, which is
equivalent to the existing standard. In the NOPR analysis, DOE
continued to identify two levels of efficacy above the baseline.
Manufacturer-provided information in catalogs indicates that there are
two distinct product lines available with efficacies higher than the
baseline products. The baseline level represents a standard 800 series
full wattage T8 lamp. In the NOPR analysis, DOE maintained EL 1 (90.0
lm/W) which represents an improved 800 series full wattage T8 lamp. DOE
also maintained EL 2 (93.0 lm/W) which represents an 800 series high
lumen output full wattage T8 lamp and the 25 W and 28 W reduced wattage
lamps. DOE analyzed available certification information and found that
EL 1 did not need to be adjusted from 90.0 lm/W. DOE adjusted EL 2 from
the preliminary analysis value of 93.0 lm/W to 92.4 lm/W based on
additional certification data.
DOE considered one CSL for the 8-foot SP slimline product class at
99.0 lm/W in the preliminary analysis. The baseline represented a
standard 800 series full wattage T8 lamp, and DOE identified one level
of efficacy above the baseline. CSL 1 represented an improved 800
series full wattage (59 W) T8 lamp in which the phosphor mix and/or
coating is enhanced to increase efficacy. Reduced wattage lamps also
met this CSL. DOE determined through publicly available compliance
reports that the 54 W representative unit and/or equivalent lamps
complied with CSL 1. Thus, DOE concluded that no adjustment was
necessary to CSL 1 in the preliminary analysis.
NEMA recommended revising CSL 1 to 97 lm/W for the 8-foot SP
slimline product class, which is equivalent to the existing standard,
in response to the preliminary analysis. For the NOPR analysis, as
mentioned previously, DOE selected a new baseline lamp that just
complies with the existing standard level of 97 lm/W. The baseline
level represents a less efficient 800 series full wattage T8 lamp. DOE
then identified two levels of efficacy above this baseline that
commercially available lamps are able to achieve. Manufacturer-provided
information in catalogs indicates that there are two distinct product
lines available with efficacies higher than the baseline product. EL 1
represents a standard 800 series full wattage T8 lamp. EL 2 represents
an improved 800 series full wattage T8 lamp in which the phosphor mix
and/or coating is enhanced to increase efficacy. Reduced wattage lamps
also meet EL 2. DOE found no adjustments were necessary based on
certification data and established EL 1 at 98.2 lm/W and EL 2 at 99.0
lm/W.
For the 8-foot RDC HO product class, DOE had put forth CSL 1 at
97.0 lm/W in the preliminary analysis. The baseline represented a 700
series full wattage (86 W) T8 lamp, and DOE identified one level of
efficacy above the baseline. CSL 1 represented a shift from 700 series
to 800 series full wattage T8 lamps. Based on available certification
data for the 86 W T8 representative unit and/or equivalent lamps at CSL
1, DOE adjusted CSL 1 from 97.6 lm/W to 97.0 lm/W for 800 series full
wattage T8 lamps.
In response to the CSL proposed in the preliminary analysis for the
8-foot RDC HO product class, NEMA suggested changing CSL 1 to 94 lm/W.
DOE revised its analysis for the NOPR and modeled a baseline that just
met the existing standard level of 92 lm/W, as described in section
VI.D.2.c. DOE then identified two levels of efficacy above the baseline
level. EL 1 now represents a 700 series full wattage T8 lamp with basic
coating, gas composition, and phosphor mix. EL 2 represents a shift to
an 800 series full wattage T8 lamp. DOE again analyzed publicly
available certification data and determined that EL 1 should be
adjusted from 95.2 lm/W to 94.0 lm/W for 700 series full wattage T8
lamps based on available certification data. EL 2 was not adjusted
based on available certification data and remains 97.6 lm/W. DOE notes
that this level representing the 800 series design option in the
preliminary analysis (previously CSL 1) was adjusted to 97.0 lm/W;
however, based on additional
[[Page 24104]]
certification data, an adjustment is not necessary.
In the preliminary analysis, DOE had considered one CSL at 98.2 lm/
W for the 4-foot T5 MiniBP SO product class. The baseline represented
an 800 series full wattage (28 W) T5 lamp with basic coating, gas
composition, and phosphor mix. CSL 1 represented an improved 800 series
full wattage T8 lamp in which the phosphor mix and/or coating was
enhanced to increase efficacy. Reduced wattage lamps also met this
level. DOE then compared the certification data to the initial efficacy
level at 25 [deg]C to determine if adjustments were necessary. DOE
determined through publicly available compliance reports that the
representative unit and/or equivalent lamps complied with CSL 1.
Therefore, DOE did not adjust the initial CSL considered for this
product class.
NEMA recommended revising CSL 1 to 90 lm/W for the 4-foot T5 MiniBP
SO product class. DOE updated its analysis for the NOPR and modeled a
baseline that just met the existing standard level of 86 lm/W, as
described in section VI.D.2.c. The baseline level represents a less
efficient full wattage (28 W) lamp. Based on a review of commercially
available products, DOE then identified two levels of efficacy above
the baseline level at which lamps were consistently performing.
Manufacturer-provided information in catalogs indicates that there are
two distinct product lines available with efficacies higher than the
baseline product. EL 1 represents an 800 series full wattage T5 lamp
with basic coating, gas composition, and phosphor mix. EL 2 represents
an improved 800 series full wattage T8 lamp in which the phosphor mix
and/or coating is enhanced to increase efficacy. Reduced wattage lamps
also meet this level. DOE found that no adjustments were necessary for
EL 1 and therefore established EL 1 at 93.5 lm/W. For EL 2 representing
improved 800 series full wattage T8 lamps, DOE adjusted EL 2 from 98.2
lm/W to 97.1 lm/W based on additional certification data.
In the preliminary analysis, DOE considered one CSL for the 4-foot
T5 MiniBP HO product class at 86.2 lm/W. The baseline represented an
800 series full wattage (54 W) T5 lamp with basic coating, gas
composition, and phosphor mix. CSL 1 represented reduced wattage lamps,
including 50 W T5 and 47 W T5 lamps, or an improved 800 series full
wattage T8 lamp in which the phosphor mix and/or coating is enhanced to
increase efficacy. Because there were no commercially available full
wattage higher efficacy replacements for the 4-foot T5 MiniBP HO
baseline lamps, DOE modeled a more efficacious full wattage lamp. DOE
determined through publicly available compliance reports that the
commercially available reduced wattage representative units and/or
equivalent lamps complied with CSL 1. Therefore, DOE did not adjust the
initial CSL considered for this product class.
For the T5 MiniBP HO product class, NEMA suggested revising CSL 1
to 80 lm/W. DOE agrees with NEMA that there is only one level of
efficacy above the baseline level for this product class; however,
performance based on commercially available lamps corresponded to 76
lm/W. DOE revised its analysis for the NOPR and modeled a baseline that
just met the existing standard level of 76 lm/W, as described in
section VI.D.2.c. The baseline level represents a less efficient full
wattage (54 W) lamp. Manufacturer-provided information in catalogs
indicates that there is one distinct product line available with
efficacy higher than the baseline product. EL 1 represents an 800
series full wattage T5 lamp with basic coating, gas composition, and
phosphor mix. Reduced wattage lamps also meet this level. DOE did not
adjust this level based on certification data and is therefore
evaluating EL 1 at 82.7 lm/W.
NEMA commented that having one CSL eliminates DOE's ability to
analyze standard levels other than the baseline and max tech and makes
it more likely that max tech will become the new standard. (NEMA,
Public Meeting Transcript, No. 30 at p. 350) EEI also expressed concern
that besides the 4-foot MBP product class, only one CSL was being
considered for all other product classes which was also representative
of the max tech level based on the criteria that full wattage lamps had
to meet every CSL being considered. EEI further noted that it was not
aware of any other rulemaking where no other levels were proposed
between the baseline and max tech. (EEI, Public Meeting Transcript, No.
30 at pp. 124, 135-137)
As described in the preceding paragraphs, DOE revised its
engineering analysis for the NOPR analysis. DOE surveyed the market,
analyzed product catalogs, and took into account feedback from
manufacturers to develop ELs. Based on this assessment, DOE identified
varying levels of efficacy that reflected technology changes and met
the criteria for developing ELs outlined above. In the NOPR, DOE is
considering two ELs in each product class with the exception of the T5
MiniBP HO product class.
DOE also received several comments regarding full wattage lamps
meeting efficacy levels under consideration. NEMA stated that if the
efficacy level at CSL 2 for the 4-foot MBP lamp can be achieved only
with more efficient krypton-filled (i.e., reduced wattage) fluorescent
lamps, it will come at the cost of reliable dimming that will have an
impact on energy savings compared to the baseline. Lutron stated that
the full wattage lamps in both the T8 and T5 categories are the only
ones for which there are dimming standards in the industry. Lutron
expressed concern that the CSLs being considered by DOE would eliminate
full wattage lamps and that would result in a loss of significant
energy savings, not just the theoretical energy savings associated with
the lamp efficacy, which may or may not result in any actual energy
savings in buildings. (Lutron, Public Meeting Transcript, No. 30 at pp.
133-134) NEMA strongly cautioned DOE to bear in mind that reduced
wattage lamps are often ``energy saver'' models, which lack the robust
performance of full wattage models. Full functionality for dimming, a
desirable characteristic, is typically only available in full wattage
models. (NEMA, No. 36 at p. 11)
DOE acknowledges that there are limitations with using reduced
wattage fluorescent lamps. DOE received feedback during manufacturer
interviews that reduced wattage lamps cannot act as replacements for
full wattage lamps in all applications, particularly in cold
temperature applications below 60-65[emsp14][deg]F. Manufacturers also
noted that striations remain an issue for reduced wattage lamps because
not all ballasts contain striation control circuitry, and those
equipped with striation control circuitry do not completely eliminate
striation. Further, manufacturers identified issues with dimming
reduced wattage lamps indicating that these lamps dim unreliably in
certain applications. Manufacturers noted that problems encountered
with dimming linear fluorescent lamps, including lamp starting,
striations, and dropout, are exacerbated by the use of krypton in
reduced wattage lamps (see section VI.C.1 for more information).
Therefore, DOE has continued to ensure that full wattage lamps can meet
all ELs under consideration in this NOPR analysis.
For the NOPR analysis, DOE used updated catalog and certification
data, which resulted in slightly different ELs than those considered in
the preliminary analysis. The ELs for the representative product
classes of GSFLs are presented in Table VI.8. For further information
on the development of ELs, please refer to chapter 5 of the NOPR TSD.
DOE welcomes comments on the
[[Page 24105]]
methodology used to develop ELs for GSFLs as well as on the ELs.
Table VI.8--Summary of ELs for GSFL Representative Product Classes
----------------------------------------------------------------------------------------------------------------
Efficacy level lm/W
CCT Lamp type -------------------------
1 2
----------------------------------------------------------------------------------------------------------------
<=4,500 K..................................... 4-foot MBP............................ 90.0 92.4
8-foot SP slimline.................... 98.2 99.0
8-foot RDC HO......................... 94.0 97.6
4-foot T5 MiniBP SO................... 93.5 97.1
4-foot T5 MiniBP HO................... 82.7 N/A
----------------------------------------------------------------------------------------------------------------
h. Scaling to Other Product Classes
As noted previously, DOE analyzes the representative product
classes directly. DOE then scales the levels developed for the
representative product classes to determine levels for product classes
not analyzed directly. For GSFLs, the representative product classes
analyzed were all lamp types with CCTs <=4,500 K, with the exception of
2-foot U-shaped lamps. For the 2-foot U shaped product class DOE scaled
the efficacy levels developed for the 4-foot MBP product class.
Therefore, efficacy levels developed for lamp types with CCTs less
than or equal to the 4,500 K were scaled to obtain levels for higher
CCT product classes not analyzed. In the preliminary analysis, DOE
developed this scaling factor by identifying pairs of the same lamp
type manufactured by the same manufacturer, within the same product
family, and differed only by CCT. DOE determined the average difference
in efficacy between these lamp pairs to be 2 percent. DOE received
several comments on this approach and resulting scaling factor.
CCT Scaling
NEMA stated that the 2 percent decrease for lamps with CCT >4,500 K
is insufficient to reflect the actual drop in lm/W that occurs. NEMA
stated it is well known in the industry that as CCT increases above
4,500 K, the lumen output and consequently the lm/W continues to
decrease. Actual performance data for the common F32T8 5,000 K tri-
phosphor lamps indicates the decrease in lm/W to be in the 4-6 percent
range and in the 6-8 percent rage for an F32T8 6,500 K tri-phosphor
lamp. NEMA noted that this reduction in lm/W at >4,500 K CCT becomes
more significant for higher targets of lm/W. (NEMA, No. 36 at pp. 12-
13)
NEMA also noted that the 1 percent reduction from the 4-foot MBP
product class with <=4,500 K CCT to the higher CCT lamps set by the
2009 Lamps Rule was a significant error in the analysis. NEMA stated
that because of the resulting high lm/W target for the 4-foot MBP
lamps, the T8 tri-phosphor 6,500 K products were almost eliminated from
the market. Further, NEMA asserted that when the waiver of standards
for 700 series lamps is lifted this product may be eliminated because
manufacturers may not be able to reliably meet current regulations for
the high CCT products. (NEMA, No. 36 at pp. 12-13)
GE stated that the 2 percent decrease for the high chromaticity
lamps is probably accurate. (GE, Public Meeting Transcript, No. 30 at
pp. 153-154) NEMA recommended a scaling factor that allows a decrease
of at least 7 percent to accommodate the average performance of the
higher CCT's. These highly efficient high CCT families of products have
been growing in importance and sales in recent years due to results
from studies (i.e., IESNA TM-24) indicating that lighting that has more
blue component actually provides for better visual capabilities,
especially for the aging population. NEMA stated that this has resulted
in a noticeable shift in the market to >4,500 K products. Any increase
in the lm/W requirements for the >4,500 K lamps will eliminate some,
and possibly all, of these higher performing high CCT lamps in the
remaining classifications. While the prior ruling may have already
destined the elimination of the 6,500 K tri-phosphor 4-foot T8-T12
linear classification of GSFLs, there is still the opportunity to
protect the 5,000 K tri-phosphor family of lamps by not changing the
lm/W targets for this group. (NEMA, No. 36 at pp. 12-13)
Based on comments received from stakeholders and feedback in
manufacturer interviews, DOE reassessed the scaling analysis for the
higher CCT lamps. DOE examined the differences in efficacies between
lower and higher CCT lamps in each product class based on performance
data provided in manufacturer catalogs. Finding substantial variation
in the percent reduction in efficacy associated with increased CCT
among product classes, DOE is proposing a separate scaling factor for
each product class. DOE is proposing to maintain a 2 percent scaling
factor for the 4-foot MBP product class in order to ensure that any
proposed level does not allow for more energy use than the current
minimum standard.\35\ Based on its assessment, DOE is proposing a 3
percent scaling factor for the 2-foot U-shaped product class, 5 percent
for the 8-foot SP slimline product class, 2 percent for the 8-foot RDC
HO product class, 6 percent for the T5 SO product class, and 5 percent
for the T5 HO product class. DOE also verified the scaling factors
developed against certification data. Further, DOE confirmed that lamps
with CCT greater than 4,500 K will meet the scaled levels. See chapter
5 of the NOPR TSD for more information on CCT scaling. DOE welcomes
comments on the scaling factors developed to scale GSFL product classes
from the less than or equal to 4,500 K CCT lamps to the greater than
4,500 K CCT lamps.
---------------------------------------------------------------------------
\35\ Current standards for the 4-foot MBP product classes are 89
lm/W for CCT <=4,500 K and 88 lm/W for CCT >4,500 K. Because the
difference between existing standards is small, the allowable
scaling factor is restricted to 2 percent.
---------------------------------------------------------------------------
2-Foot U-Shaped Scaling
NEMA stated that the scaling factor for 2-foot U-shaped lamps of 2
percent is too small. Because no technology changes or improvements
have been made to U-shaped lamps during the past three years, NEMA
recommended remaining consistent with the 2009 Lamp Rule scaling factor
and use 6 percent. NEMA added that the efficiency of these lamps cannot
be significantly, feasibly raised, so the minimum efficiency of these
products should remain 84 lm/W. (NEMA, No. 36 at p. 12) GE noted there
are some confounding factors for which DOE needs to account if the
scaling factor analysis for the 2-foot U-shaped class is
[[Page 24106]]
based on catalog data and even manufacturer to manufacturer data. GE
stated that efficacy difference was more likely in the 4-6 percent
range as opposed to what is found in catalog data. (GE, Public Meeting
Transcript, No. 30 at p. 154)
DOE reassessed the scaling analysis for 2-foot U-shaped lamps based
on comments received. In the preliminary analysis, DOE had based its
scaling assessment on lamp performance data found in catalogs. However,
DOE revised its analysis to utilize certification data for the NOPR
based on feedback received from manufacturers indicating that
confounding factors exist that are not reflected in catalog data. By
comparing certification data for 2-foot U-shaped lamps with equivalent
4-foot MBP lamps, DOE determined an average efficacy reduction of 6
percent for the 2-foot U-shaped lamps from the 4-foot MBP lamps was
appropriate. DOE confirmed that the technology impacts of the scaled
ELs for the 2-foot U-shaped lamps were consistent with those of the
proposed ELs for the 4-foot MBP product class. See chapter 5 of the
NOPR TSD for more information on 2-foot U-shaped scaling. DOE welcomes
comments on the scaling factor developed to scale from the 4-foot MBP
product class to the 2-foot U-shaped product class.
i. Rare Earth Phosphors
NEMA restated its support of previous submitted comments of its
concerns regarding the rare earth phosphor issue. (NEMA, No. 36 at p.
14) NEMA asked how the analysis accounts for the current shortage of
rare earth elements and the existing practice of waivers and further
how these factors impact compliance capability. (NEMA, Public Meeting
Transcript, No. 30 at pp. 131-132) NEMA recommended the DOE confer with
Dr. Alan King of the Critical Materials Institute of the AMES
Laboratories to fully understand and predict the availability of
critical materials, including rare earth elements. He observed to the
NEMA Lighting Systems Division recently that once a material becomes
critical, it tends to stay critical, with fluctuations, but no slacking
of demand/criticality until the product demand disappears altogether.
(NEMA, No. 36 at p. 14)
DOE notes that manufacturers, in their applications for exception
relief, stated that they expected an improvement in the rare earth
market, specifically noting that supplies of key rare earth phosphors
used in fluorescent lamps will become more equal to estimated demand
beginning in 2014. Manufacturers also stated that the two-year relief
would provide time for potential development of additional supplies
outside of China, for progress in technology advancements and
development of alternative technologies that use lesser amounts of rare
earth material, and for the expansion of recycling and reclamation
initiatives.\36\ DOE understands a constrained supply of rare earth
phosphors may have impacts on the production of higher efficiency
fluorescent lamps. DOE also acknowledges that supply and demand of rare
earth phosphors should continue to be considered when evaluating
amended standards for GSFLs. Thus as in the preliminary analysis, for
this NOPR analysis DOE is considering a scenario of increased rare
earth phosphor prices in the LCC and NIA. See appendices 7B and 9B of
the NOPR TSD for more information.
---------------------------------------------------------------------------
\36\ Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001,
EXC-12-0002, EXC-12-0003 (2012). Accessible here: http://energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf.
---------------------------------------------------------------------------
3. Incandescent Reflector Lamp Engineering
For IRLs, DOE received comments on the engineering analysis
presented in the preliminary TSD. Stakeholders provided feedback on the
metric used to measure IRL efficacy, as well as feedback on DOE's
representative product classes, selection of more efficacious
substitutes, baseline lamps, max tech level, CSLs, scaling, and
proposing standards for IRLs. The following sections summarize the
comments and responses received on these topics, and present the IRL
engineering methodology for this NOPR analysis.
a. Metric
Existing IRL standards are based on lamp efficacy measured as the
lumen output of the lamp per watt supplied to the lamp. Further, the
scope of coverage for existing IRL standards includes lamps that are
equal to or greater than 40 W and less than or equal to 205 W. (See
section V.C for further information on IRL scope.) Noting that wattage
is a factor in defining the scope of IRLs covered, The CA IOUs
recommended moving in the direction of lumen-based standards because
lumens are useful to a consumer, whereas watts are no longer a useful
metric. For example, the CA IOUs noted that lamp packaging that says
that the lamp's rated 55 W equals 70 W does not make sense. The CA IOUs
recommended that in general, DOE should do as much as possible to help
shift discourse to be lumen-based instead of wattage-based, and
standards are one way to help do so. Additionally, the CA IOUs stated
that for a specific product type, manufacturers are accustomed to
designing to a wattage because that is what consumers are used to
(e.g., designing to 50 W regardless of the product efficacy), which
produces a volume of products giving more or less light. However, the
CA IOUs asserted that efficacy should be improved by reducing wattage
rather than increasing light output. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 45-48)
EEI, however, noted that the wattage equivalency provided on
packaging is useful to the consumer. They noted that the standards are
in lumens per watt, which is a formula that provides a requirement for
lamps to be more efficient on an efficacy, rather than wattage, basis.
However, especially for incandescent lamps, packaging stating that the
72 W halogen lamp is equal to an old 100 W incandescent lamp lets
consumers know what they are getting, including the associated light
output. Otherwise, as historically higher watts produce higher lumens,
consumers would be confused, especially with CFLs and LED lamps. (EEI,
Public Meeting Transcript, No. 30 at pp. 48-50)
Energy conservation standards must prescribe either a minimum level
of energy efficiency or a maximum quantity of energy use, where the
former is a ratio of the useful output of services to the energy use of
the product. 42 U.S.C. 6291(5)(6) The existing standard for IRLs is a
lumens per watt, or lamp efficacy, metric. Setting a standard based on
lumens alone would not capture the efficiency of the product nor allow
for a true comparison of efficiency across lamp wattages. By relating
the input power to the light output, this metric appropriately measures
the efficiency of the lamp.
Regarding setting standards that would drive manufacturers to meet
energy conservation standards by reducing wattage and not increasing
light output, DOE standards do not aim to favor any one design pathway
for achieving energy efficiency and saving energy. DOE employs an
equation that relates lumens to wattage and sets a minimum efficacy
requirement across all wattages for IRLs. This power law equation
captures the potential efficacy using a particular design option for
all wattages. DOE acknowledges that manufacturers may choose to
increase lumen output rather than decrease wattage to meet the minimum
efficacy requirement. Therefore, the engineering analysis considers
energy-saving options. Further, lumen outputs that are not within 10
percent of the baseline lumens are not considered in the
[[Page 24107]]
analysis. (See chapter 5 of the NOPR TSD for further details on the
engineering analysis.) The NIA considers all available options for
consumers in choosing IRLs. (See section VI.J and chapter 12 of the
NOPR TSD.)
DOE acknowledges consumer understanding of the relationship between
watts and lumens could be improved through labeling and marketing of
lamps. However, this is not within the scope of DOE's authority in this
rulemaking. Therefore, because the lumens per watt metric is an
appropriate measure of the energy efficiency of IRLs and DOE considers
energy savings when developing efficacy levels, DOE is not proposing to
change this metric for IRLs in this rulemaking.
b. Representative Product Classes
When a product has multiple product classes, DOE identifies and
selects certain product classes as representative and analyzes those
product classes directly. DOE chooses these representative product
classes primarily due to their high market volumes. For IRLs, in the
preliminary analysis DOE identified standard spectrum lamps, with
diameters greater than 2.5 inches, and input voltage less than 125 V as
the representative product class, shown in gray in Table VI.9. NEMA
agreed with the representative product classes presented for IRLs.
(NEMA, No. 36 at p. 7) DOE did not receive any other comments regarding
representative product classes for IRLs. In this NOPR, DOE is
maintaining the same IRL representative product classes as presented in
the preliminary analysis.
Table VI.9--IRL Representative Product Classes
------------------------------------------------------------------------
Diameter (in
Lamp type inches) Voltage
------------------------------------------------------------------------
Standard spectrum....................... >2.5 >=125
.............. * <125
<=2.5 >=125
.............. <125
------------------------------------------------------------------------
Modified spectrum....................... >2.5 >=125
.............. <125
<=2.5 >=125
.............. <125
------------------------------------------------------------------------
* Representative.
c. Baseline Lamps
Once DOE identifies representative product classes for analysis, it
selects baseline lamps to analyze in each representative product class.
Typically, a baseline lamp is the most common, least efficacious lamp
that meets existing energy conservation standards. To identify baseline
lamps, DOE reviews product offerings in catalogs, shipment information,
and manufacturer feedback obtained during interviews. For IRLs, the
most common lamps were determined based on characteristics such as
wattage, diameter, lifetime, lumen package, and efficacy.
In the preliminary analysis, DOE identified a PAR38 lamp as the
most prevalent lamp shape and diameter in the representative product
class. From all PAR38 lamps with the most common characteristics, DOE
selected two lamps that just met existing standards as baselines. One
was a 60 W halogen lamp with a lifetime of 1,500 hours that utilized a
higher efficiency inert fill gas and a higher efficiency reflector
coating, and had an efficacy right at the existing standard, 5.9P
\0.27\. The other was a 60 W HIR lamp with a lifetime of 3,000 hours
that utilized IR glass coatings and had an efficacy very close to the
existing standard. DOE received several comments on its selection of
two baselines for IRLs.
The CA IOUs and NEEA and NPCC stated that DOE should use only one
baseline lamp which should have an efficacy that just meets the current
IRL standards, and it should provide the minimum lamp life expected of
these products. (CA IOUs, Public Meeting Transcript, No. 30 at p. 163;
CA IOUs, No. 32 at p. 2; NEEA and NPCC, No. 34 at pp. 2, 4-5) The Joint
Comment stated that DOE must select the least efficacious lamp meeting
current conservation standards as its baseline for IRLs. (Joint
Comment, No. 35 at p. 2) ASAP also stated that DOE should not consider
two baselines and pointed out that typically, a baseline is the
commercially available product with the lowest efficiency. ASAP
provided the example of a dishwasher rulemaking, where the most common
dishwasher was an ENERGY STAR compliant product. As this product was
above the minimum of the last standard, the previous standard itself
was used as the baseline. Thus, using the most common product is
different than using the least efficient product available. (ASAP,
Public Meeting Transcript, No. 30 at p. 158)
NEMA also disagreed with two baselines for IRLs, stating that the
two baseline products being compared are not identical, and a dual-
baseline will eliminate a product class. NEMA further recommended that
rather than expend numerous resources trying to interpolate what the
market ``might'' be, DOE should simply employ the baseline selection
criteria from the 2009 Lamps Rule and use the standard from that
rulemaking as the baseline. (NEMA, No. 36 at p. 7) NEMA stated that the
arguments for baseline, CSL 0 in the preliminary TSD, are based on
predictions of market shift that erroneously justify a new baseline
higher than the minimum requirements put forth by the 2009 Lamps Rule.
(NEMA, No. 36 at p. 1)
The CA IOUs, NEEA and NPCC, and GE agreed that the true baseline is
the less efficient product with the shorter lifetime (i.e., the 60 W
halogen lamp with a 1,500-hour lifetime). (CA IOUs, Public Meeting
Transcript, No. 30 at p. 163; NEEA and NPCC, No. 34 at p. 5; GE, Public
Meeting Transcript, No. 30 at pp. 159-161) The CA IOUs and the Joint
Comment noted that the 60 W halogen lamp with a 1,500-hour lifetime is
representative of the minimum performance that is compliant with July
2012 standards, which require an efficacy of 17.8 lm/W for a 60 W lamp.
(CA IOUs, No. 32 at p. 2; Joint Comment, No. 35 at p. 2)
The CA IOUs, NEEA and NPCC, the Joint Comment, and GE also agreed
that the 60 W HIR lamp with a 3,000-hour lifetime was not a baseline
lamp because it was using more advanced technology. (CA IOUs, No. 32 at
pp. 2-3; NEEA and NPCC, No. 34 at pp. 2, 4-
[[Page 24108]]
5; Joint Comment, No. 35 at p. 2) The CA IOUs, ASAP, and NEEA and NPCC
noted there is a trade-off between lifetime and efficacy in
incandescent lamp designs and absent other design improvements, an
increase in lamp life results in a decrease in efficacy, and vice
versa. (CA IOUs, No. 32 at pp. 2-3; ASAP, Public Meeting Transcript,
No. 30 at p. 159; NEEA and NPCC, No. 34 at pp. 4-5) Because the second
lamp proposed as a baseline lamp in DOE's analysis has a longer life
and a higher efficacy, it clearly includes some other advanced design
features that have allowed for improved performance in both metrics.
(CA IOUs, No. 32 at pp. 2-3) The Joint Comment added that if the
lifetime of the second baseline lamp was reduced to 1,500 hours to
allow for an accurate comparison to the first baseline lamp, its
efficacy would be even greater than 18.3 lm/W. (Joint Comment, No. 35
at p. 2) Further, the CA IOUs and NEEA and NPCC pointed out that the
higher cost of the HIR lamp indicated that it was a more
technologically advanced product than the halogen lamp. (CA IOUs, No.
32 at pp. 2-3, NEEA and NPCC, No. 34 at pp. 2, 4-5)
The CA IOUs also noted that minimum product performance generally
gravitates towards the minimum standards set for a product and such IRL
products are on the market. Therefore, the CA IOUs contended it is
inaccurate to define a baseline product that is higher than the minimum
standard. (CA IOUs, No. 32 at p. 2) ASAP further added that by
introducing the 60 W HIR, 3,000-hour lifetime lamp as a baseline, DOE
took that first, most cost effective improvement and averaged it into
the baseline. (ASAP, Public Meeting Transcript, No. 30 at p. 161)
DOE recognizes that the HIR baseline lamp with the longer lifetime
considered in the preliminary analysis is using more advanced
technology than the halogen baseline lamp. Therefore, in this NOPR, DOE
is not proposing to analyze the 60 W HIR lamp with a 3,000-hour
lifetime as a baseline lamp. DOE is proposing one baseline represented
by the 60 W halogen lamp with a 1,500-hour lifetime.
The CA IOUs noted that, historically, many reflector lamps have
been offered with a minimum lifetime of 1,000 hours, and generally no
fewer. Therefore, DOE could even more accurately represent the baseline
by lowering the baseline lifetime to 1,000 hours. (CA IOUs, No. 32 at
p. 2)
DOE reviewed product offerings in catalogs, shipment trends, and
information obtained during manufacturer interviews to identify the
common characteristics of lamps that meet standards. Based on DOE's
analysis, the 1,500-hour lamps are much more common than other lower
lifetime lamps, including 1,000-hour lamps, among the covered IRLs.
Therefore, DOE is proposing a 1,500-hour lamp as the baseline.
Stakeholders also commented on whether it was necessary to have
different lamp lifetimes for different sectors. GE stated that the
consumer market, which does not necessarily need the long lifetime, is
looking for a less expensive opening price point. However, the 60 W HIR
with the 3,000-hour lifetime would be sold to a commercial customer who
is more concerned about long operating hours and does not want to
replace lamps frequently. Therefore, the commercial consumer will
gravitate more towards the higher technology lamp, trying to reduce
maintenance costs. (GE, Public Meeting Transcript, No. 30 at pp. 159-
161)
The CA IOUs disagreed that a shorter lifetime lamp was appropriate
for only the residential sector and a longer lifetime lamp for the
commercial sector. They stated that products with shorter lifetimes are
commonly marketed and sold into various market segments, including the
commercial sector. They provided the examples of Halco Haloxen SPAR
Series product line and the Satco Xenon Halogen line,\37\ both of which
are standards-compliant 1,500-hour life lamps specifically marketed for
use in the commercial sector. According to the CA IOUs, this suggests
that the shorter lifetime products (1,000-1,500 hours) are appropriate
to represent the baseline lamp for both the residential and commercial
sectors. (CA IOUs, No. 32 at p. 2) NEEA and NPCC added that both the 60
W halogen lamp with a 1,500-hour lifetime and the 60 W HIR lamp with a
3,000-hour lifetime can be found at typical do-it-yourself (DIY) stores
and in commercial lamp catalogs. (NEEA and NPCC, No. 34 at p. 5)
---------------------------------------------------------------------------
\37\ More information on these lamps is provided in the written
comment available on regulations.gov under docket number EERE-2011-
BT-STD-0006.
---------------------------------------------------------------------------
Several stakeholders asked for further information about the market
share breakdown of these lamps by sector. EEI asked about the
percentage of the IRL market that is residential versus commercial.
(EEI, Public Meeting Transcript, No. 30 at pp. 163-164) EEI also asked
how the baseline characteristics put forth in the preliminary analysis
compared to those in the marketplace in terms of what is actually being
sold using 2012 or 2013 data. (EEI, Public Meeting Transcript, No. 30
at p. 157) Noting that it was difficult to determine where a lamp going
through distribution channels such as Home Depot or Lowe's ends up,
NEEA asked how DOE determines which lamps are in the residential sector
and which are in the commercial sector (e.g., by distribution channel
or socket). (NEEA, Public Meeting Transcript, No. 30 at p. 164) NEMA
asked if the 2010 LMC contained data on sockets in specific sectors so
as to determine what percentage of those tend to be the higher
technology. (NEMA, Public Meeting Transcript, No. 30 at pp. 165-166)
ASAP agreed that the market is important but noted that it is
factored into the downstream analyses. ASAP provided an example that if
100-percent of commercial shipments are already at this level, then
this will be reflected in the shipments analysis and it would flow
through to the LCC and NIA, rather than be built into the baseline.
(ASAP, Public Meeting Transcript, No. 30 at pp. 162-163)
DOE acknowledges that different lamps may be popular in different
market sectors. The 2010 LMC provides data on the inventories of
halogen reflector lamps in each sector. However, because there is
nothing that would limit the use of a covered IRL in a specific sector,
DOE does not conduct sector-based assessments in the engineering
analysis. Rather, the LCC and NIA consider lamp use in different market
sectors. The LCC analysis provides results for each analyzed lamp in
each relevant sector. The shipments analysis accounts for the number of
shipments by sector and the popularity of analyzed lamps in each
sector. The results are subsequently used in the NIA analysis. Please
see section VI.J for more detail.
Summary of IRL Baseline Lamps
DOE is proposing the baseline lamp for IRLs specified in Table
VI.10. For further information, please see chapter 5 of the NOPR TSD.
DOE requests comments on its selection of baseline lamps for IRLs.
[[Page 24109]]
Table VI.10--IRL Baseline Lamp
----------------------------------------------------------------------------------------------------------------
Baseline lamp
---------------------------------------------------------------------------------
Wattage Efficacy Initial Lifetime
Representative product class -------------------------- light ------------
Lamp type Descriptor output
W lm/W ------------- hr
lm
----------------------------------------------------------------------------------------------------------------
Standard Spectrum, Voltage PAR38 Improved Halogen 60 17.8 1,070 1,500
<125 V, Diameter >2.5 Inches.
----------------------------------------------------------------------------------------------------------------
d. More Efficacious Substitutes
DOE selects more efficacious replacements for the baseline lamps
considered within each representative product class. DOE considers only
design options identified in the screening analysis. In the preliminary
analysis, DOE considered substitute lamps that saved energy and, where
possible, had a light output within 10 percent of the baseline lamp's
light output. In identifying the more efficacious substitutes, DOE
utilized a database of commercially available lamps. In the preliminary
analysis, DOE identified a higher efficacy, lower wattage lamp,
referred to in this analysis as an improved HIR lamp with a lifetime of
4,400 hours, as a more efficacious substitute for the two baseline
lamps. DOE received several comments regarding its choice for a more
efficacious substitute.
ASAP expressed concern that two dependent variables, lumens per
watt and lifetime, are changed so that the more efficacious substitute
is providing not just greater efficacy but also more light, more hours
of lighting, and greater utility. The product is different and is
designed to meet some commercial consumers' desire for a long-lived
product. If the hours were reduced for that product to be equivalent to
the baseline lamp lifetime, it would have a significantly higher
efficacy from an engineering perspective. ASAP concluded that lifetime
is a limiting factor on the efficacies that can be used for the
selection of more efficacious, commercially available lamps. (ASAP,
Public Meeting Transcript, No. 30 at p. 169)
The CA IOUs provided information on the relationship between
lifetime and efficacy in incandescent lamps, noting that a lamp's
efficacy could be improved by increasing current, but if no other
design options are employed, the lamp will have a shorter lifetime. On
the other hand, decreasing current can increase lamp lifetime, but if
no other design changes are made, the resulting product would have a
reduced efficacy. The CA IOUs also put forth a relationship where life
= life0 x {lpw/lpw0{time} -7.1 to show that the efficacy of
a lamp could be improved at the expense of lamp life rather than
investment or improvement in the lamp design.\38\ (CA IOUs, No. 32 at
pp. 3-4)
---------------------------------------------------------------------------
\38\ In the equation, ``life0'' is equal to the
design life at the designed efficacy (lpw0), while
``life'' is the resultant life when the designed efficacy is altered
to a new operational efficacy (lpw).
---------------------------------------------------------------------------
DOE recognizes that there is an inverse relationship between
efficacy and lifetime for IRLs. The engineering analysis focuses on
commercially available products. DOE is aware that to meet higher
efficacy levels, manufacturers can choose to produce lamps with a
shorter lifetime than the baseline lamp to achieve higher efficacy.
Given that manufacturers responded to the July 2012 standards by
introducing IRLs with shorter lifetimes, DOE understands that this is a
likely path manufacturers may take in response to higher standards. To
capture the impacts of the relationship between lifetime and efficacy
in IRLs, DOE determined how much the lifetime of a lamp with the same
wattage as the baseline lamp must be shortened to achieve each efficacy
level under consideration in the NOPR analysis. (See chapter 5 of the
NOPR TSD for further information.) The impact of these shortened
lifetime lamps are assessed as sensitivities in the LCC, NIA, and MIA.
(See respectively, appendix 8B, chapter 12, and appendix 13C of the
NOPR TSD).
In the main engineering analysis, DOE did not model IRLs with
shortened lifetimes at efficacy levels higher than those at which they
are currently commercially available because DOE believes that lifetime
is a feature valued by consumers. DOE believes typical lifetimes of
IRLs regulated by this rulemaking are between 1,500 and 4,400 hours.
The longest lifetime products are available at EL 1, the highest
analyzed efficacy level in this NOPR analysis. While manufacturers can
choose to introduce shorter lifetime products in the future, DOE does
not require shortening of lamp lifetime to meet any analyzed level.
In the preliminary analysis, DOE had put forth a representative
lamp with a 4,400-hour lifetime and improved HIR technology as the more
efficacious substitute. For the NOPR analysis, after reassessing
updated catalog and compliance information, DOE identified an
alternative representative lamp that better reflected the minimum
efficacy level for lamps with improved HIR technology. This
representative lamp has a lifetime of 4,200 hours. Because there is a
range of lifetimes available at a higher efficacy, in addition to the
4,200-hour representative lamp, DOE is proposing a second
representative lamp as a more efficacious substitute at EL 1 in this
NOPR analysis. The 2,500-hour lamp offers a different technology
pathway to achieve EL 1, namely IR glass coating without the use of
higher efficiency reflector coatings. Therefore DOE analyzes the 2,500-
hour lamp as a representative lamp at EL 1. DOE requests comment on the
lifetimes of the IRL baseline and more efficacious substitutes.
Summary of IRL Representative Lamps
DOE is proposing the representative lamps for IRLs specified in
Table VI.11. For further information please see chapter 5 of the NOPR
TSD. DOE requests comments on its selection of representative lamps for
IRLs.
[[Page 24110]]
Table VI.11--IRL Representative Lamps
----------------------------------------------------------------------------------------------------------------
Representative lamps
--------------------------------------------------------------------------------
Wattage Efficacy * Initial Lifetime
Representative product class ------------------------ light -----------
Lamp type Descriptor output
W lm/W ------------ hr
lm
----------------------------------------------------------------------------------------------------------------
Standard Spectrum, Voltage <125 PAR38 HIR.............. 55 18.5 980 2,500
V, Diameter >2.5 Inches.
PAR38 Improved HIR..... 55 18.5 1120 4,200
----------------------------------------------------------------------------------------------------------------
* Efficacy values are based on data from DOE's certification database.
e. Maximum Technologically Feasible
DOE presented one efficacy level (CSL 1) for consideration in the
preliminary analysis. Therefore, this level was also the max tech level
identified for IRLs. DOE received several comments on the max tech
level presented in the preliminary analysis.
The CA IOUs expressed their belief that DOE had not captured the
total potential energy savings from IRL standards. They noted that
according to the 2010 LMC, IRLs represent a sizable end use, an
estimated 39 TWh of annual energy use in the United States. (CA IOUs,
No. 32 at pp. 1-2) The CA IOUs cited the case of Natural Resources
Defense Council v. Herrington, 768 F.2d 1355, 1391-92 (D.C. Cir. 1985),
in which the D.C. Circuit Court explained the EPCA provision that
requires DOE to identify and analyze the ``maximum technology feasible
level'' to determine whether that level is both cost-effective and
feasible. The ruling further stated that DOE must explain why a
standard achieving max tech was rejected. (CA IOUs, No. 32 at p. 4)
Specifically, CA IOUs made the following assertions regarding the max
tech for IRLs presented in the preliminary analysis: (1) There are
commercially available IRLs higher than the max tech; (2) advanced
technology being used in other lamp types can be transferred to produce
higher efficacy IRLs; and (3) there are prototype IRLs that demonstrate
the feasibility of higher efficacy IRLs. (CA IOUs, No. 32 at pp. 4-7)
The CA IOUs commented that there is a wide array of currently,
commercially available products that are significantly more efficient,
by 13-20 percent, than the CSL proposed by DOE. (CA IOUs, No. 32 at p.
4) In the DOE certification database there is a Philips 70 W PAR38 at
22 lm/W, which is 13 percent better than CSL 1; a Philips 55 W lamp at
20.1 lm/W, which is 10 percent better than CSL 1; and a GE lamp at 23
lm/W, which is 12 percent better. The CA IOUs noted that OSI's best
products are not yet in DOE's certification database. They also noted
that smaller manufacturers with products such as one with 25 percent
higher performance than CSL 1 are not represented in the analysis. (CA
IOUs, Public Meeting Transcript, No. 30 at p. 172) ASAP stated it is
important that DOE analyze a max tech level chosen from all lamps on
the market and then examine the impacts of that level on utility.
(ASAP, Public Meeting Transcript, No. 30 at pp. 181-182) NEEA and NPCC
stated products that should be commercially available in 2013 range in
efficacy from the minimum federal standard to over 30 lm/W, and max
tech is probably over 35 lm/W, even at lower wattages, far above what
DOE has acknowledged. (NEEA and NPCC, No. 34 at pp. 2, 5) NEMA,
however, stated that there have been no noteworthy technological
breakthroughs since the last rulemaking or great changes in the market.
Therefore, the maximum-feasible performance levels of the previous rule
have not changed. (NEMA, No. 36 at p. 1)
In the preliminary analysis, DOE evaluated the latest catalogs and
DOE's certification database to identify the most efficacious IRLs to
develop the max tech level. DOE selected more efficacious replacements
with a similar reflector shape (PAR38) and lumen output (within 10
percent) as the baseline lamp. In the engineering analysis, DOE
considered only replacements that saved energy. Based on DOE's
analysis, the max tech presented in the preliminary analysis
represented the highest-efficacy commercially available lamp meeting
these criteria.
The CA IOUs noted that over the last few years, a number of
products have been designed and tested using improved halogen IR
capsules with new mixes and more layers of materials in the thin-film
coatings. IRLs have demonstrated efficacies above 30 to 35 lm/W, with
efficacies of 45 lm/W (with a 1,000-hour lifetime) having also been
achieved for omni-directional lamps in lab settings.\39\ The CA IOUs
cited a November 2012 Electric Power Research Institute (EPRI) study
\40\ that conducted extensive photometric, electrical, and durability
testing on a 32 lm/W A-lamp, including extended lifetime measurements
and testing of the lamp's ability to withstand sudden changes in
voltage, to assess its performance. All lamps were still functional at
1,000 hours and 70 percent of the test samples exceeded 2,000 hours.
The independent study concluded that the high efficacy lamps were ``a
true 100 watt incandescent-equivalent with respect to all output/
performance values, lifespan.'' The CA IOUs argued that the high
efficiency halogen IR capsules in those lamps could be inserted into
reflector lamps as well. (CA IOUs, No. 32 at pp. 5-6)
---------------------------------------------------------------------------
\39\ ETCC presentation, Dec 2010, slide 2. www.etcc-ca.com/pdfs/10_2X_Incandescent_ET_Open_Forum_121207_R1.pptx.
\40\ EPRI report 1025779; www.epri.com/abstracts/Pages/ProductAbstract.aspx?ProductId=000000000001025779&Mode=download
.
---------------------------------------------------------------------------
The CA IOUs further noted that Venture Lighting is offering 2X
halogen A-lamps ($6.98, 32 lm/W, 1,500 hours) \41\ and 2X halogen MR-16
lamps ($6.90, 22 lm/W, 6,000 hours) \42\ on the Web site,
www.2XLightDirect.com. The 2X lamps are deemed to be two times as
efficient as their typical incandescent counterparts. (CA IOUs, No. 32
at pp. 5-6) CA IOUs emphasized that the 2X MR-16 is a commercially
available product using technology that can be used in other lamp form
factors. The CA IOUs acknowledged, however, that the MR-16 lamp, which
is not a covered product, cannot be used for a direct comparison with
the lamps covered under this rulemaking due to different design
parameters, coatings on the lenses, and low voltage operation.
Additionally, the CA IOUs stated that the challenges encountered with
designing a smaller form factor lamp
[[Page 24111]]
such as an MR-16 may be more easily overcome with PAR lamps. (CA IOUs,
Public Meeting Transcript, No. 30 at pp. 170-173, 179-180) The CA IOUs
noted that the Web site www.2Xlightdirect.com, where these 2X lamps can
be found, states that PAR lamps are ``coming soon.'' \43\ (CA IOUs, No.
32 at pp. 5-6)
---------------------------------------------------------------------------
\41\ www.2xlightdirect.com/product-categories/a-line.
\42\ www.2xlightdirect.com/product-categories/2x-mr16.
\43\ www.2xlightdirect.com/product-categories/2x-par.
---------------------------------------------------------------------------
Philips stated that it is unknown if IRLs utilizing the 2X lamp
technology are technically viable. Philips provided the example that a
37 lm/W lamp can be demonstrated, but that it could only last 24 hours.
(Philips, Public Meeting Transcript, No. 30 at pp. 173-174)
DOE acknowledges that efficacious A-shape and MR-16 lamps are
currently being offered on the market. However, DOE cannot assume that
lamp designs and technologies that work for certain lamp shapes (e.g.,
MR-16 and A-shape lamps) and at low voltages will achieve the same
efficacies in the IRLs that are the subject of this rulemaking. The
incandescent lamps studied by EPRI and available from Venture Lighting
(the 2X A-lamps and MR-16s) are not covered IRLs. They do not utilize
the same reflector shapes and the MR-16s do not operate at the same
input voltage as the covered IRLs. Therefore, DOE cannot consider these
lamp types to determine a max tech for IRLs.
The CA IOUs asserted that covered IRLs exist in prototype form that
are dramatically more efficient than DOE's proposed CSL. (CA IOUs, No.
32 at p. 4) The CA IOUs stated that, in 2009, they funded the
development of a super-efficient PAR lamp achieving 37 lm/W at 57 W
with a lifetime of 1,500 hours. The CA IOUs provided information about
the lamp and its testing completed in 2009.\44\ (CA IOUs, No. 32 at p.
6; CA IOUs, Public Meeting Transcript, No. 30 at p. 173)
---------------------------------------------------------------------------
\44\ Appendix A is available at the end of the CA IOUs written
comment in the docket for this rulemaking.
---------------------------------------------------------------------------
Additionally, the CA IOUs pointed out a presentation from the
Emerging Technologies Coordinating Council (ETCC) site \45\ that
includes information about the market potential for advanced IR
coatings. Several PAR lamps achieving approximately 30 lm/W are
forecasted to be available by mid-2013, at a price point of $8 to
$9.\46\ The CA IOUs stated that they are tracking the development of
these products and intend to obtain samples to submit to DOE. The CA
IOUs encouraged DOE to reach out to manufacturers of these products
directly to understand more specifics about product development
schedules, manufacturing capability, likely cost points, technical
potential, and to potentially obtain prototypes of these lamps. (CA
IOUs, No. 32 at p. 6)
---------------------------------------------------------------------------
\45\ ETCC presentation, Dec 2010, slide 5. http://www.etcc-ca.com/pdfs/10_2X_Incandescent_ET_Open_Forum_121207_R1.pptx
\46\ At the time of the NOPR analysis, these lamps were not
commercially available.
---------------------------------------------------------------------------
The CA IOUs concluded that DOE needs to look at max tech and then
identify what is cost effective, feasible and can be scaled up for
production. The CA IOUs noted that this was not adequately addressed in
the preliminary analysis. Further, the CA IOUs suggested that one of
the CSLs should be set in line with the max tech level and another
should be set in line with the maximum commercially available level.
NEEP agreed with this recommendation. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 170-173; CA IOUs, No. 32 at pp. 6-7; NEEP,
No. 33 at p. 3) The Joint Comment also stated that to properly identify
the max tech level, DOE should examine those sources referenced in the
CA IOUs' comments, namely, EPRI, 2Xlightdirect.com, and ETCC. (Joint
Comment, No. 35 at p. 3)
NEMA stated that if DOE chooses to consider higher performance
levels based on any recently introduced technologies, they are
obligated to conduct actual testing of these lamps for all performance
parameters, such as reliability, lifetime, dimmability, beam spread,
light pattern, and any other performance features expected of new/
substitute lamps in this class. (NEMA, No. 36 at p. 11) NEMA also
cautioned DOE that emerging technology and prototype models do not
reliably represent the market, only market attempts. NEMA further
stated that technologies on which to base the future of an entire
product class must be demonstrated and proven for long-term feasibility
and market acceptance. (NEMA, No. 36 at p. 11)
For the NOPR analysis, DOE contacted manufacturers producing high
efficacy prototype IRLs and conducted independent testing of these
lamps. The testing indicated that these lamps were more efficacious
than the max tech level determined by DOE in this analysis.\47\ DOE
notes that the lamps tested were prototype lamps and were not
manufactured during commercial scale production runs. However, the
measured efficacy of the prototype lamps greatly exceeded the efficacy
of commercially available lamps with similar lumen packages. DOE does
not, however, have the necessary information to do a cost analysis to
determine if an efficacy level based on these lamps would be
economically justified. In appendix 5A of the NOPR TSD, DOE provides an
assessment of these higher efficacy prototypes (including test data),
conducts a further examination of the highly efficacious lamps relevant
to this rulemaking noted by stakeholders in comments, and specifies the
additional information it would need to consider prototypes in a
rulemaking analysis. DOE welcomes comments on the max tech level as
well as any further information on prototype lamps.
---------------------------------------------------------------------------
\47\ While DOE independently verified efficacy values, the
manufacturer's testing for lifetime was still ongoing at the time of
the NOPR analysis.
---------------------------------------------------------------------------
While DOE received several comments stating that the max tech level
is greater than that analyzed in the preliminary analysis, DOE also
received comments that the max tech level is not higher than the
analyzed level. GE stated that it did not believe technology existed
that would triple the efficiency of these lamps. GE noted that although
there may be a few more players in the market, the technology itself or
what can be done with it has not changed in the last three or four
years. GE asserted that the baseline technology represents the highest
technology available today that meets many different needs in the
marketplace. As efficacy requirements increase, even to the CSL 1,
utility is lost, potentially leading to only one product that works for
one consumer and one application. GE stated that CSL 1 represents the
max tech of what is available today that could cover all the different
market needs. (GE, Public Meeting Transcript, No. 30 at pp. 176-178)
As discussed previously, based on DOE's analysis of commercially
available lamps and because it does not have the adequate information
to conduct a full analysis on any lamp that represents an efficacy
level higher than EL 1, DOE is proposing 6.2P\0.27\ as EL 1 and the max
tech level.
Proprietary Technology
In response to the max tech level presented in the preliminary
analysis, DOE received several comments regarding the use of
proprietary technology. NEMA stated that for all IRLs, no further
elevations in product performance are possible. As support, NEMA quoted
from the final rule notice of the 2009 Lamps Rule, in which DOE had
noted that the max tech level was possible with the use of the highest-
efficiency technologically feasible reflector, halogen IR coating, and
filament design and because this would require the use of proprietary
technology, DOE could not consider this
[[Page 24112]]
level further in its analyses. 74 FR 34080, 34096 (July 14, 2009). NEMA
stated that if DOE proposes to raise the CSL above the existing level
set by the 2009 Lamps Rule, DOE must explain why the proprietary
technology hurdle no longer exists, and then explain how to achieve
those higher CSLs. (NEMA, No. 36 at p. 11) Specifically, Philips
expressed concern that the improved reflector technology option, such
as a silver reflector coating, was proprietary. (Philips, Public
Meeting Transcript, No. 30 at p. 169) GE added that requiring
proprietary technology could impact competition. (GE, Public Meeting
Transcript, No. 30 at pp. 169-170)
EEI expressed similar concerns as NEMA and stated that during the
2009 Lamps Rule, the Department of Justice was concerned about the
higher standard levels because certain technologies for HIR lamps were
proprietary and that because only a few companies made the highest
efficacy lamp, competition in the industry could be impacted. EEI asked
whether there were issues with the particular technology used in the
more efficacious substitute, such that it might be a proprietary
technology and made only by a very limited number or even one
manufacturer, which could limit its availability and result in an
extremely high price point. (EEI, Public Meeting Transcript, No. 30 at
pp. 167-168)
The CA IOUs noted that they had provided a number of comments to
that rulemaking's docket about alternate silverized reflector
technologies, and suggested that manufacturers would be able to utilize
them to improve efficacy of their lamps. The CA IOUs reported that
since the 2009 Lamps Rule, several manufacturers have begun making
lamps with silver reflectors, including, but not limited to, Halco,
Satco, Ushio, and Osram Sylvania.\48\ Further, the CA IOUs noted that
the Lawrence Livermore Lab has a patent; GE and DSI likely also have
patents related to reflector technology. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 170-171) Given the wide variety of major PAR
lamp manufacturers that are utilizing silverized reflectors, the CA
IOUs encouraged DOE to consider this a viable design option for all IRL
manufacturers. (CA IOUs, No. 32 at pp. 8-9)
---------------------------------------------------------------------------
\48\ More information on associated products can be found in the
written comment available on regulations.gov under docket number
EERE-2011-BT-STD-0006.
---------------------------------------------------------------------------
In the 2009 Lamps Rule, the highest level analyzed for IRLs was
based on a commercially available lamp that employed a silver
reflector, an improved IR coating, and a filament design that resulted
in a lifetime of 4,200 hours. While DOE had determined that the silver
reflector was patented technology, DOE research indicated that there
were alternate pathways to achieve this level, such as filament
redesign to achieve higher temperature operation (thus reducing the
lifetime), non-proprietary higher efficiency reflectors, and a higher
efficiency IR coating. 74 FR 34080, 34133 (July 14, 2009). In
interviews conducted in the preliminary analysis for this rulemaking,
manufacturers indicated that there were no specific patent or
intellectual property barriers to obtaining commercially available IRL
technologies. Further, in the preliminary analysis, DOE put forth a CSL
1 that was based on a commercially available improved HIR lamp that
does not necessarily require a silverized reflector coating to achieve
its efficacy. Several manufacturers have found means of designing more
efficacious IRLs that are commercially available, such as through the
use of IR glass coatings and higher efficiency reflector coatings that
do not use proprietary technology. In the NOPR analysis, DOE confirmed
during interviews that proprietary technology is not a barrier to
achieving the proposed max tech level, which is also EL 1. Therefore,
in this NOPR analysis, DOE is proposing the same efficacy level put
forth in the preliminary analysis. DOE has determined that this level
can be achieved without the use of proprietary technology.
f. Efficacy Levels
For IRLs, DOE developed a continuous equation that specifies a
minimum efficacy requirement across wattages and represents the
potential efficacy a lamp achieves using a particular design option.
DOE observed an efficacy division among commercially available IRL
products that corresponded to the design options utilized to increase
lamp efficacy. Based on this efficacy division, DOE considered one CSL
in the preliminary analysis. DOE received several comments regarding
the CSL presented for IRLs in the preliminary analysis.
The CA IOUs expressed concern that there is only one CSL. The CA
IOUs stated that DOE is not capturing the huge potential in the IRL
market for efficacy gains, both for commercially available and non-
commercially available products. The CA IOUs stated that based on
commercially available IRL products and other known high-performing
products, DOE should add at least three additional, higher efficacy
CSLs to its IRL analysis. (CA IOUs, No. 32 at p. 4)
The Joint Comment agreed with the CA IOUs, stating that DOE should
add multiple high efficacy CSLs to its analysis; ASAP suggested two or
three additional levels. (Joint Comment, No. 35 at p. 3; ASAP, Public
Meeting Transcript, No. 30 at pp. 171-172) NEEP noted that the higher
efficacies in DOE's certification database for standard levels should
be included in the analysis at this stage. NEEP suggested DOE consider
adding at least two additional CSLs to the analysis between CSL 1 and
the maximum commercially available level. (NEEP, No. 33 at p. 3) NEEA
and NPCC stated there is more than enough rationale to examine at least
two or three additional CSLs, if not three or four, including a ``max
tech'' level, which DOE has not included for this family of products.
(NEEA and NPCC, No. 34 at pp. 2, 5)
To demonstrate the feasibility of potential efficacy improvements
beyond the CSL 1 presented in the preliminary analysis, the CA IOUs
provided a graph that showed efficacy levels of commercially available
lamps from four manufacturers based on catalog data, plotted against
the considered CSL 1 and the standard from the 2009 Lamps Rule. In
further support, the CA IOUs provided another graph showing efficacy
levels of over 20 manufacturers from DOE's certification database, also
plotted against the considered CSL 1 and the standard from the 2009
Lamps Rule. Both graphs show a number of lamps above the considered CSL
1. (CA IOUs, No. 32 at pp. 4-5) ASAP asked how old the data DOE used in
its preliminary analysis was and why the lamps with higher efficacies
in DOE's database were not captured. (ASAP, Public Meeting Transcript,
No. 30 at pp. 171-172)
For the preliminary analysis, DOE conducted a thorough review of
the latest catalog and certification data provided for covered IRLs.
Because PAR38 lamps are the most popular products on the market and a
PAR38 lamp was selected as the baseline, DOE considered only PAR38
lamps when selecting more efficacious substitutes. Further, DOE
selected more efficacious substitutes with a lumen output within 10
percent of the baseline lumens, as this is the amount of change in
light output deemed acceptable to consumers. (See section VI.D.2.e for
further information.)
To ensure energy savings, DOE also chose higher efficacy lamps with
a lower wattage than the baseline lamp. DOE also did not consider any
lamp that could not be purchased in the United
[[Page 24113]]
States. Some of the products with the highest efficacies in DOE's
certification database were not found for sale in the United States.
Thus, although there are certain lamps with efficacies higher than
the levels proposed by DOE, DOE did not consider them in the
preliminary analysis for the reasons stated above. DOE maintained this
methodology for the NOPR analysis.
NEMA stated that the CSL 1 presented in the preliminary analysis
was infeasible given that there have been no technological
breakthroughs since the 2009 Lamps Rule. (NEMA, No. 36 at pp. 9-11)
NEMA also commented that having one CSL eliminates DOE's ability to
analyze standard levels other than the baseline and max tech and makes
it more likely that max tech will become the new standard. (NEMA,
Public Meeting Transcript, No. 30 at p. 350)
DOE based CSL 1 on commercially available products that achieved
catalog efficacies above the existing standard. Specifically, the
representative lamp for CSL 1 was a commercially available 55 W IRL
with a catalog efficacy of 20 lm/W. Acknowledging that the catalog
efficacy of a lamp varies from its certified efficacy, DOE also
reviewed certification data for IRLs. Based on certification data, DOE
accordingly adjusted CSL 1, resulting in an efficacy level of
6.2P\0.27\. Because DOE based CSL 1 on a commercially available lamp
and accounted for variances in efficacies between catalog and
certification data when establishing CSL 1, DOE believes that CSL 1 is
technologically feasible and is also the appropriate max tech level.
The CA IOUs recommended that DOE revisit the slope of the candidate
standard lines to better reflect the performance of lamps on the
market. The CA IOUs provided graphs that demonstrated three possible
additional CSLs that could be used to more effectively evaluate
potential standards at higher, technically feasible efficacy tiers. The
CA IOUs adjusted the slopes of the curves to account for higher
efficacy potential at higher wattage. (CA IOUs, No. 32 at pp. 7-8)
DOE examined the possibility of changing the exponent of the
existing equation for IRL standards to better reflect the performance
of lamps on the market. DOE conducted a best fit analysis and
determined that the current equation accurately reflects the wattages
and associated efficacies of commercially available products. Thus, DOE
retained the current standard equation.
Summary of IRL Efficacy Levels
For the NOPR analysis, DOE again reviewed the most updated catalog
and certification data available for covered IRLs. As in the
preliminary analysis, DOE used the catalog data to determine initial
efficacy levels and then adjusted the ELs to ensure that commercially
available IRLs would meet proposed levels based on compliance
information provided in DOE's certification database. In the
preliminary analysis, DOE had found there to be certification data for
only 36 percent of covered IRL products compliant with the July 2012
standards. For the NOPR analysis, DOE found that updates to DOE's
certification database resulted in certification data for 51 percent of
covered IRL products. Using certification data reported for the PAR38
2,500 hour HIR and 4,200 hour improved HIR representative lamps, DOE
adjusted EL 1. As mentioned previously, DOE developed a continuous
equation that specifies a minimum efficacy requirement across wattages
for IRLs. The proposed EL based on the representative lamps is a curve
that represents a standard across all wattages.
Table VI.12 presents the proposed efficacy level for IRLs. See
chapter 5 of the NOPR TSD for additional information on how the
engineering analysis was conducted.
Table VI.12--Efficacy Levels for Standard Spectrum, Voltage <125 V,
Diameter >2.5 Inches IRLs
------------------------------------------------------------------------
Efficacy
Efficacy level requirement lm/
W
------------------------------------------------------------------------
EL 1................................................... 6.2P0.27
------------------------------------------------------------------------
P = rated wattage.
g. Scaling to Other Product Classes
When more than one product class exists for a covered product, DOE
identifies and selects representative product classes to analyze
directly. Efficacy levels developed for these representative product
classes are then scaled to products not analyzed directly. For IRLs,
DOE analyzed directly standard spectrum lamps greater than 2.5 inches
in diameter and with input voltages less than 125 V. The efficacy
levels developed for this representative product class were then scaled
to product classes not analyzed, using a scaling factor to adjust
levels for modified spectrum lamps, smaller diameter lamps, and lamps
with higher input voltages. DOE received several comments specific to
the scaling factors applied to develop efficacy levels for the product
classes analyzed directly.
Diameters Less Than or Equal to 2.5 Inches
In the preliminary analysis, DOE scaled from the CSLs developed for
the IRLs with diameters greater than 2.5 inches (hereafter ``large
diameter lamps'') to IRLs with diameters less than or equal to 2.5
inches (hereafter ``small diameter lamps''). Based on catalog data, DOE
determined the reduction in efficacy caused by the smaller lamp
diameter to be approximately 12 percent. DOE also determined that the
more efficient double-ended HIR burners could not fit into small
diameter lamps. Therefore, in the preliminary analysis, DOE applied an
additional 3.5 percent reduction to account for the ability of small
diameter lamps to utilize only less efficient single-ended HIR burners.
Asserting that double-ended burners can be utilized in small
diameter lamps, NEEA and NPCC and the CA IOUs urged DOE not to use an
additional scaling factor to account for the use of a single-ended
burner in a small diameter lamp. (CA IOUs, No. 32 at p. 10, NEEA and
NPCC, No. 34 at p. 6) The CA IOUs noted that by providing a PAR20 lamp
with a double ended burner at the public meeting, they had demonstrated
that double-ended burners can be used in small diameter lamps. At the
preliminary analysis public meeting, the CA IOUs had presented two
small diameter lamps with double-ended burners. One was a commercially
available Philips MR-16 lamp, which the CA IOUs acknowledged to be out
of the scope of this rulemaking, but asserted that the MR-16 burner
would fit into a covered IRL. The other was a PAR20 lamp covered under
this rulemaking that was not yet commercially available. (CA IOUs,
Public Meeting Transcript, No. 30 at pp. 195-197) GE noted that the
MR16 uses a 12 V filament, which is much shorter than the filament at
120 V, and NEMA stated that many technical features are not
transferrable between 12 V and 120 V products. (GE, Public Meeting
Transcript, No. 30 at pp. 196-197, NEMA, No. 36 at p. 11) The CA IOUs
acknowledged that the MR16 used a 12 V filament, but noted that the
PAR20 lamp with a double-ended burner was designed for operation at 120
V. (CA IOUs, Public Meeting Transcript, No. 30 at p. 197) Further, the
CA IOUs noted that the PAR20 lamp with a double-ended burner achieved
an efficacy of 16.1 lm/W, which is 12 percent higher than the CSL
proposed
[[Page 24114]]
by DOE for this lamp type in the preliminary analysis. (CA IOUs, No. 32
at p. 10)
ADLT agreed with the CA IOUs, noting that these double-end burners
have a length of 52 mm and new double-end burners are being introduced
to the market that are 45 mm in length, which further mitigates
mechanical fit problems related with smaller reflectors. (ADLT, No. 31
at pp. 2-3) However, NEMA contended that double-ended burners will not
fit into existing small diameter PAR20 lamps without extending the lens
cover. The extension of the lens cover would lessen the utility as the
product would not fit into all fixtures designed to use PAR20 lamps,
and therefore could not be considered as an acceptable substitute.
(NEMA, No. 36 at p. 12) GE agreed that there were difficulties in
fitting halogen IR burners into small PAR20 envelopes. (GE, Public
Meeting Transcript, No. 30 at pp. 191-193)
Regarding the PAR20 lamp with a double-ended burner provided by the
CA IOUs at the preliminary analysis public meeting, DOE notes that it
must also consider how the use of a design option affects product
utility and whether a more efficacious product is an appropriate
substitute for the existing product. DOE must also consider whether the
product can be manufactured at a commercial scale by the compliance
date of any amended standards. Based on feedback given by manufacturers
in interviews, fitting a double-ended burner into a small diameter lamp
would require changes to the physical shape of the lamp, specifically
requiring an extension of the reflector lens. While the modified lamp
may still meet ANSI standards for a small diameter lamp such as a
PAR20, it would be larger than any PAR20 lamps sold in the past and
those currently installed. Because the lamp shape would be different
from the standard sizes of commercially available small diameter lamps,
the modified lamp may not fit in existing structures. Past a certain
wattage threshold, heat dissipation in lamps with a smaller envelope
using a double-ended burner could also become an issue. Further,
manufacturers stated that even if the double-ended burner could fit
into a small diameter lamp, it would be difficult to place the burner/
filament in the optimal position.
Therefore, in this NOPR analysis DOE continues to apply an
additional 3.5 percent reduction factor when scaling efficacies of
large diameter to small diameter lamps to account for the limitation of
small diameter lamps being able to utilize only single-ended burners.
The CA IOUs questioned DOE's methodology for determining the
scaling factor for large diameter to small diameter lamps. The CA IOUs
stated that it understood DOE compared the efficacies of small diameter
lamps to larger diameter lamps on the market, and established that
there was a 12 percent difference. Under the assumption that the
single-ended burner could not fit in small diameter lamps, DOE then
modeled the losses of using a single-ended burner. However, the CA IOUs
did not understand why these losses were added to the original 12
percent difference which represents the efficacy reduction going from a
large diameter to small diameter lamp. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 194-195)
ADLT stated that it supported a 12 percent scaling factor based on
the impact of the less efficient diameter of the reflector because it
was independent of capsule design. ADLT noted that a typical PAR30
aluminum-coated reflector with a front lens is approximately 75 percent
optically efficient while the same type of PAR20 reflector (aluminum
coated with a front lens) is approximately 66 percent efficient.
Therefore, ADLT concluded that the 12 percent reduction in efficiency
from large to small diameter lamps corresponds to DOE's findings when
comparing catalog efficacy data of each lamp type from several lamp
manufacturers (all other features remaining approximately the same).
(ADLT, No. 31 at p. 2)
In the preliminary analysis, DOE compared the catalog efficacies of
halogen PAR20 lamps (the most common IRL with a diameter less than or
equal to 2.5 inches) and their PAR30 or PAR38 counterparts from several
lamp manufacturers (all other lamp features remaining approximately the
same). Based on these results, DOE found that the reduction in efficacy
caused by the smaller lamp diameter was approximately 12 percent for
IRLs. Because only halogen lamps were used (no HIR lamps were
included), the 12 percent included the efficacy difference due only to
lamp diameter because the additional impact of a single-ended versus
double-ended burner on lamp efficacy is relevant only for HIR lamps. In
the NOPR analysis, using the same methodology, DOE confirmed that the
efficacy reduction from a large diameter to a small diameter lamp
should be 12 percent.
ADLT stated that the 3.5 percent scaling factor going from double-
ended to single-ended burners was also unnecessary because single-ended
burners can be highly efficient within small diameter reflectors. They
cited the example of an MR-16 lamp (2 inch diameter reflector)
utilizing single-ended IR halogen burner with an 85 percent optical
efficiency compared to a typical PAR38 (4.75 inch diameter reflector,
aluminized) with a 78 to 80 percent optical efficiency. Therefore, ADLT
urged DOE to consider a 12 percent reduction factor, which would equate
to an efficacy requirement of 5.5P\0.27\ for small lamp diameters.
(ADLT, No. 31 at pp. 2-3)
DOE cannot base its analysis on an MR-16 lamp because it is not
designed to operate at the same voltage as covered IRLs, and MR-16
lamps are not the subject of this rulemaking; DOE can assess the
efficiency of a single-ended burner only in a small diameter IRL
covered under this rulemaking.
With regards to scaling, NEMA stated that DOE must ensure not only
that the filaments and halogen burners must be able to be inserted into
all lamps scaled, but also that the beam characteristics required for
those lamps, a market-demanded performance characteristic, can be met.
NEMA suggested that DOE develop demonstration models to verify
performance; otherwise, scaling is not possible. (NEMA, No. 36 at p.
12)
As noted, DOE determined that double-ended burners cannot fit into
small diameter lamps without changes to the lamp shape that could
affect lamp characteristics and thereby product utility. Therefore, DOE
scaled from large diameter lamps with double-ended burners to small
diameter lamps with single-ended burners. DOE did not create
demonstration models because the scaling was based on lamp designs in
commercially available lamps.
Operating Voltages Greater Than or Equal to 125 Volts
In the preliminary analysis, DOE scaled from IRLs with voltages
less than 125 V to IRLs with voltages greater than or equal to 125 V.
DOE developed a scaling factor that would require 130 V lamps tested at
130 V to use the same technology and possess the same general
performance characteristics as 120 V lamps tested at 120 V. DOE found
that while there may be a slight decrease in efficacy, the lifetime of
a 130 V lamp is doubled when it is operated at 120 V, giving it an
advantage over 120 V lamps. Using the IESNA Lighting Handbook equations
that relate lifetime, lumens, and wattage to voltage of incandescent
lamps, DOE determined that a 15 percent scaling factor was necessary.
The CA IOUs stated that it can be assumed the primary utility of
the 130
[[Page 24115]]
V lamps was long life. However, they noted that the utility has not
been removed from the market, as there are still many other
commercially available long-life lamps. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 66-67) NEMA clarified that the primary
utility and selling point of the 130 V lamps was their ability to
withstand voltage spikes. The additional lifetime was just an added
benefit. (NEMA, Public Meeting Transcript, No. 30 at pp. 67) EEI agreed
that in some areas where the line voltage can be higher than 120 V, the
130 V lamps provided a safeguard against the lamp blowing out. (EEI,
Public Meeting Transcript, No. 30 at pp. 61-63) NEMA asserted that
consumers have arguably lost a utility and noted that elimination of a
market-desired performance characteristic is counter to requirements in
EPCA. (NEMA, No. 36 at p. 1, 5) Additionally, according to EEI,
consumers that now have to switch from 130 V to 120 V have to buy more
lamps. (EEI, Public Meeting Transcript, No. 30 at pp. 61-63)
DOE received feedback in manufacturer interviews that in certain
areas where voltage spikes may occur, a 130 V lamp will last longer
than a 120 V lamp. DOE remains concerned, however, that the operation
of 130 V lamps at 120 V has the potential to significantly affect
energy savings. DOE's research has shown that 130 V lamps are usually
operated by consumers at 120 V rather than at a higher voltage line.
This could incentivize manufacturers to design a less efficient and
less expensive 130 V lamp that would meet standards when tested at 130
V. Because they would be cheaper, there could be a market migration to
130 V lamps and due to the lower lumen output when 130 V lamps are
operated at 120 V, consumers may purchase more 130 V lamps, resulting
in increased energy consumption.
EEI noted that when 130 V lamps are operated at 120 V, their
lifetime is increased by about 2.5 times. (EEI, Public Meeting
Transcript, No. 30 at pp. 61) GE noted that as 130 V lamps are operated
on higher voltages, their efficacy decreases. GE stated that this
relationship was misanalysed in the 2009 Lamps Rule, and as a result,
the July 2012 standards have eliminated 130 V lamps from the market.
(GE, Public Meeting Transcript, No. 30 at pp. 60-61)
DOE's research indicates that operating 130 V lamps at 120 V
increases lifetime and lowers efficacy compared to operating these
lamps at 130 V. Therefore, to develop an appropriate scaling factor,
DOE determined the efficacy of 130 V lamps operated at 120 V if their
additional lifetime over that of 120 V lamps were instead used to
increase their efficacy. DOE found this increase in efficacy to be 15
percent. Therefore in this NOPR analysis, DOE is proposing a scaling
factor of a 15 percent efficacy increase from an IRL with voltages less
than 125 V to voltages greater than or equal to 125 V.
Modified Spectrum
In the preliminary analysis, DOE established CSLs for modified
spectrum IRLs by scaling from the CSLs developed for the standard
spectrum product class. DOE determined that a reduction of 15 percent
from the standard spectrum CSLs would be appropriate for modified
spectrum IRLs.
The Joint Comment urged DOE to eliminate the 15 percent allowance
for modified spectrum IRLs. The Joint Comment noted that a 2009 Ecos
Consulting study \49\ that found an average light loss of 9 to 11
percent associated with modified spectrum lenses. The study also
highlighted the feasibility of modified spectrum IRLs exceeding the
highest efficacy levels in the 2009 Lamps Rule. Therefore, the Joint
Comment found that the 15 percent scaling factor should be eliminated,
as there are high efficacy modified spectrum lamps, or DOE should
reduce the factor to 10 percent to match the findings of the Ecos
Consulting study. (Joint Comment, No. 35 at p. 3)
---------------------------------------------------------------------------
\49\ Ecos Consulting (prepared for Pacific Gas & Electric,
Natural Resources Defense Council, and the Appliance Standards
Awareness Project), 2009. Optical Losses of Modified Spectrum Lenses
on Incandescent Reflector Lamps.
---------------------------------------------------------------------------
In the 2009 Lamps Rule, DOE assessed the efficacy differences
between standard and modified spectrum IRLs by measuring the efficacies
of commercially available standard and modified spectrum lamps. 74 FR
34080 (July 14, 2009). In that analysis, DOE correlated the measured
color point data of the lamps with lamp light output reduction and lamp
spectral power distribution. By analyzing the data, DOE established
that a reduction of 15 percent from the standard spectrum to modified
spectrum lamps was necessary.
In the preliminary analysis, DOE confirmed this 15 percent
reduction by determining the difference between the catalog efficacies
of the standards-compliant modified spectrum lamps to comparable
standard spectrum lamps. Using the available data for standards-
compliant modified spectrum lamps on the market, DOE compared the
efficacies of these two lamps with standard spectrum lamps with the
same wattage and lifetime by the same manufacturer and confirmed a 15
percent reduction in efficacy from a modified spectrum lamp to a
standard spectrum lamp. Therefore, in this NOPR analysis DOE is
proposing a 15 percent efficacy reduction from a standard spectrum IRL
to a modified spectrum IRL.
h. Xenon
DOE identified higher efficiency inert fill gas as a design option
for improving lamp efficacy of IRLs. Specifically, xenon, due to its
low thermal conductivity, can greatly increase lamp efficacy and is
utilized in most covered standards-compliant IRLs. NEMA commented that
the availability of xenon is decreasing. If standards are set at a
level requiring the use of xenon, it will increase its use, driving up
prices and reducing availability, similar to the rare earth phosphor
shortage issue. (NEMA, Public Meeting Transcript, No. 30 at pp. 80-81)
NEMA noted that xenon is becoming increasingly scarce, and its loss is
an automatic 5-7 percent efficacy reduction in IRLs. The loss of xenon
will make it impossible to meet CSL 1. NEMA referred DOE to a February
2013 article in CryoGas International Magazine,\50\ which provides
additional information on the xenon supply and demand market. These
estimates show a 2013 increase in demand of 15-20 percent followed by
steady 10 percent demand growth in outyears, with a potential for
dramatic spike if emerging demands from technology related to
satellites, anesthesia and electronics are realized as anticipated.
NEMA stated that DOE should add an investigation of xenon availability
trends and pricing to its analysis. (NEMA, No. 36 at p. 3)
---------------------------------------------------------------------------
\50\ CryoGas International Magazine, February 4, 2013 ``Ever
Changing Rare Gas Market'' Richard Betzendahl.
---------------------------------------------------------------------------
NEEA and NPCC disagreed, stating that as there is no current
shortage of xenon fill gas, and a standard requiring it would not
demand a significant increase in xenon use, then xenon price and supply
should not be an issue for this rulemaking. (NEEA and NPCC, No. 34 at
p. 2, 5) The CA IOUs further noted that xenon is already being used as
the primary fill gas in virtually all IRLs, so a requirement of its use
would not especially impact any constraints on supply or price
instability in the market. (CA IOUs, No. 32 at pp. 9-10)
DOE acknowledges that xenon supply and prices are an important
factor for the lighting industry, including IRLs. Therefore, in the
preliminary analysis DOE conducted a market assessment of xenon supply,
demand, and prices as
[[Page 24116]]
well as an LCC sensitivity to determine the impact of increased end
user lamp prices due to increases in the price of xenon. DOE updated
this assessment for the NOPR analysis.
For the NOPR analysis, DOE examined various industry sources
relevant to the xenon market including the February 2013 article in
CryoGas International Magazine cited by NEMA. While, the article did
forecast increases in xenon demand in 2013 and 2014, it also stated
that it expected this to flatten out due to penetration of LEDs into
the market. A 2012 CryoGas International Magazine article noted that
xenon price increases predicted for 2012 did not occur to the extent
expected.\51\ DOE understands that fluctuations in xenon supply and
price are possible and difficult to predict. Based on its research, DOE
did not find that there was currently a major shortage of xenon. To
further inform the impact of xenon demand and prices, in the NOPR
analysis, DOE conducted an LCC sensitivity that determines how high the
xenon price would have to increase to result in zero LCC savings for
the consumer at the proposed level. Based on the results of this
analysis, DOE determined that EL 1 is achievable even with fluctuations
in xenon price. See appendix 7C of the NOPR TSD for complete details on
the xenon price sensitivity conducted in the LCC. Additionally, for
this NOPR analysis, a xenon price sensitivity was also conducted in the
NIA. Detailed results can be found in chapter 12 of the NOPR TSD.
---------------------------------------------------------------------------
\51\ Betzendahl, Richard. ``Still Bullish on Rare Gases: A
CryoGas International Market Report.'' CryoGas International,
February 2012. (Last accessed October 25, 2013.) <www.cryogas-digital.com/cryogas/201202?pg=30#pg30
---------------------------------------------------------------------------
i. Proposed Standard
DOE received several comments that no standards should be proposed
for IRLs. NEMA indicated that the CSL 1, which was also the max tech
level presented in the preliminary analysis should be eliminated.
(NEMA, No. 36 at p. 1, 9) GE suggested that the existing standard for
IRLs is appropriate, and DOE does not need to establish a higher
standard. (GE, Public Meeting Transcript, No. 30 at pp. 176-178) DOE
has identified that there are achievable efficacy levels higher than
the existing standard and has developed an EL based on the latest
catalog and certification information. See section VI.D.3.f for more
details.
NEMA, in general, did not believe that any increase in efficacy for
small diameter, modified spectrum, or greater than 125 V IRLs would be
warranted. (NEMA, No. 36 at p. 5) NEMA expanded on the 130 V IRL,
asserting that these lamps appear to have been eliminated by the 2009
Lamps Rule and arguing against further regulation. (NEMA, No. 36 at p.
1, 5) Further, NEMA found the lack of 130 V lamps on the market as
evidence that current standards for these lamps are technically or
economically infeasible. NEMA noted that there is still difficulty in
making these IRLs comply with the July 2012 standards. (NEMA, No. 36 at
p. 5) Therefore, NEMA strongly recommended that for IRLs with voltages
greater than or equal to 125 V the CSL be ``No New Standard,'' not CSL
0, which implies there are products to regulate rather than
acknowledging the inability to further raise efficiency requirements.
(NEMA, No. 36 at pp. 10-11)
GE also strongly disagreed with applying another 15 percent
increase on top of an already unachievable standard for the 130 V IRLs,
particularly when it was not clear how energy savings could be
justified and why products that don't meet existing standards would be
further regulated. (GE, Public Meeting Transcript, No. 30 at pp. 191-
193) EEI asked what percentage of the lighting market the 130 V lamps
represent and questioned what can be gained by additional analysis if
the standards adopted by the 2009 Lamps Rule have eliminated 130 V
lamps from the market. (EEI, Public Meeting Transcript, No. 30 at pp.
58-60, 68)
DOE has not found evidence that more efficacious small diameter,
modified spectrum, or 130 V IRLs are not technologically feasible or
practicable to manufacture. DOE research indicates that the basic
structure, components, and operating requirements of these lamps do not
prevent the application of design options considered in the engineering
analysis to achieve the proposed efficacy levels. Therefore, in this
NOPR analysis, DOE is proposing efficacy levels for these lamp types.
DOE requests comment on any technological barriers in manufacturing
more efficacious small diameter, modified spectrum, or 130 V rated
lamps for commercial production.
E. Product Pricing Determination
Typically, DOE develops manufacturer selling prices (MSPs) for
covered products and applies markups to create end-user prices to use
as inputs to the LCC analysis and NIA. Because GSFLs and IRLs are
difficult to reverse-engineer (i.e., not easily disassembled), DOE did
not use this approach to derive end-user prices for the lamps covered
in this rulemaking. In the preliminary analysis, DOE estimated end-user
prices for lamps by establishing discounts from manufacturer suggested
price lists (hereafter ``blue book prices''). DOE revised its
methodology for the NOPR, as described below, to account for additional
information that became available after publication of the preliminary
analysis.
For this NOPR analysis, DOE gathered publicly available lamp
pricing data after the compliance date of the July 2012 standards.
Based on feedback from manufacturer interviews, DOE determined that
GSFLs and IRLs are sold through three main channels (state procurement,
large distributors including DIY stores (i.e., Lowe's and Home Depot),
and Internet retailers). Using these main channels and the pricing
data, DOE developed three different end-user prices as representative
of a range of publicly available prices: Low, based on the state
procurement channel; medium, based on large distributors and DIY
stores; and high, based on Internet retailers. In the preliminary
analysis, the medium end-user prices were used in the main results of
the LCC and NIA analysis while the low and high end-user prices were
used in sensitivity analyses in the LCC. DOE received several comments
on this methodology and the resulting end-user prices. NEMA deferred
comment on product price determination to individual manufacturer
interviews. (NEMA, No. 36 at p. 13)
Stakeholders had specific comments regarding the IRL prices. ASAP
and the CA IOUs found the price estimates for IRL standards case lamps
provided by DOE to be higher than the typical pricing they found on the
market. (ASAP, Public Meeting Transcript, No. 30 at pp. 200-201; CA
IOUs, No. 32 at pp. 10-11) The CA IOUs stated that low, medium, and
high prices were provided for a 55 W IRL at 20 lm/W for CSL 1, however,
CSL 1 required an efficacy of only 18.3 lm/W for a 55 W lamp. The CA
IOUs suggested that DOE collect cost information more representative of
the minimum efficacy needed for each CSL analyzed. The CA IOUs asserted
high outlier price points should not be given equal weight in DOE's
analysis; with minimal shopping, consumers will find lower priced
products readily available. The CA IOUs provided a table showing some
end-user price information gathered by ASAP and the CA IOUs. The
information gathered includes price points for some of the higher
performing IRLs from the major manufacturers collected from seven
different retail outlets, including both online outlets
[[Page 24117]]
and brick and mortar stores, with the highest price at $16.49 and the
average price of $13.03. (CA IOUs, No. 32 at pp. 10-11) NEEA and NPCC
also questioned the high prices, specifically prices greater than $15
for 50-70 W halogen lamps with an efficacy of 20 lm/W or less. (NEEA
and NPCC, No. 34 at p. 6)
In the preliminary analysis, while the representative lamp at CSL 1
had a 20 lm/W catalog efficacy, its compliance values indicated a lower
tested efficacy, resulting in an adjustment of CSL 1 to the 6.2P\0.27\
coefficient that would result in an efficacy of 18.3 lm/W for a 55 W
lamp. Therefore, in the preliminary analysis, DOE determined prices of
a lamp that represented the minimum efficacy at CSL 1. Further, the
representative lamp prices at CSL 1 for IRLs were determined to be
$9.29 for the low price, $16.34 for the medium price, and $23.77 for
the high price in the preliminary analysis. These prices were based on
publicly available price data, including prices from available state
procurement contracts and a substantive number of Internet retailers.
Any lamp prices from only one Internet retailer or one state
procurement contract were removed from the pricing analysis, as were
any extremely high prices (i.e., extreme outliers in the price trend
observed for a lamp). DOE also examined the lamp prices cited by the CA
IOUs and ASAP by identifying prices for these lamps at generally known
lighting retailers, such as Home Depot, Lowe's, Grainger, and
eLightBulbs, and found average prices up to $20. Regarding the CA IOUs'
comment that consumers will find lower-priced products, DOE conducts
the high price sensitivity in the LCC in part to address scenarios
where consumers do not purchase lamps at the lowest price.
Several stakeholders provided general comments indicating that the
prices based on Internet retail presented in the preliminary analysis
were too high. ASAP questioned why the Internet prices were higher than
the DIY store prices that make up DOE's medium case. ASAP noted that
because such stores also sell products online, residential consumers
would find these medium prices on the Internet. Additionally, ASAP
mentioned that commercial customers would be educated enough to avoid
the higher Internet prices, making it unlikely for anyone to purchase
products at the high prices DOE presented. (ASAP, Public Meeting
Transcript, No. 30 at pp. 204-205) GE, however, noted that DOE found
the prices online, demonstrating that the channel does exist. GE also
stated that some retailers, small stores or online sites set their own
price points and these can be very high. (GE, Public Meeting
Transcript, No. 30 at p. 201)
For this NOPR analysis, DOE updated its pricing database and its
blue book information and developed updated high, medium, and low
prices for the IRL representative lamps at CSL 1. These prices were
slightly lower than those determined in the preliminary analysis
because of updated price data collected from online retailers and
updated blue book prices. DOE also received updated blue book prices
for lamps covered under this rulemaking. DOE's pricing analysis intends
to capture a full range of available prices. DOE believes that the
medium prices used in the main results are representative of the
average price paid by the consumer.
DOE also received comments regarding using a weighted price in its
main results. NEEA and ASAP urged DOE to weight the high, medium, and
low end-user prices rather than using sensitivities. (NEEA, Public
Meeting Transcript, No. 30 at pp. 202-203; ASAP, Public Meeting
Transcript, No. 30 at pp. 203-204) NEEA also emphasized the importance
of weighting the different market prices in rulemakings, such as this
one, where the nature of the product prohibits the typical markup
analysis methodology. (NEEA, Public Meeting Transcript, No. 30 at p.
232) While it may be possible for some markets sources to charge more
for the product, NEEA and NPCC contended that such pricing has nothing
to do with the cost efficiency and should not impact the analysis. An
ideal pricing proposal would be one based on sales-weighted average
pricing. NEEA and NPCC urged DOE to seriously revisit this part of the
analysis. (NEEA and NPCC, No. 34 at p. 6)
NEEA cautioned DOE to be careful in determining what fraction of
the market is paying what price at each channel, and ASAP suggested DOE
account for the end-user and volume of lamps specific to a channel.
(NEEA, Public Meeting Transcript, No. 30 at p. 232; ASAP, Public
Meeting Transcript, No. 30 at pp. 202-203) For the state procurement
channel, NEEA noted that in the lighting market in their service area,
state contract pricing is available for every government or semi-
government entity, and therefore many lamps are sold at the low price.
(NEEA, Public Meeting Transcript, No. 30 at pp. 231-232) ASAP also
noted that many lamps are being sold through each state procurement
contract but cautioned that accessibility to these contracts is limited
and therefore, the low price they offer is available to only a very
small number of consumers. (ASAP, Public Meeting Transcript, No. 30 at
pp. 202-203)
Additionally, ASAP remarked that if a consumer pays the high price,
they are probably doing so by choice, as the medium price is
accessible. ASAP likened the scenario to purchasing a book, where large
online retailers and bookstore chains will have the book significantly
marked down, but a consumer could choose to pay a high price in order
to support a small local bookstore. ASAP reasoned that very few lamps
would be sold at the high price and suggested DOE weight the prices
accordingly. (ASAP, Public Meeting Transcript, No. 30 at pp. 202-203)
Taking into consideration the above comments, in this NOPR analysis
DOE developed an end-user price weighted by distribution channel. Using
manufacturer feedback in interviews, DOE determined an aggregated
percentage of shipments that go through each of the main channels for
GSFLs and IRLs. The large distributors and DIY stores channel was
estimated at 85 percent, the state procurement channel at 10 percent,
and the Internet retail channel at 5 percent. DOE then applied these
percentages respectively to the average medium price determined for
large distributor and DIY stores, the average low price determined for
state procurement contracts, and the average high price determined for
Internet retailers. The sum of these weighted prices was used as the
average consumer price for GSFLs and IRLs in the main LCC analysis and
NIA. DOE continued to utilize the low prices and high prices in a
sensitivity analysis in the LCC analysis. See chapter 7 of the NOPR TSD
for further information on the pricing analysis. DOE welcomes feedback
on the pricing methodology used in this analysis.
F. Energy Use
For the energy use analysis, DOE estimated the energy use of lamps
in the field (i.e., as they are actually used by consumers). The energy
use analysis provided the basis for other DOE analyses, particularly
assessments of the energy savings and the savings in consumer operating
costs that could result from DOE's adoption of amended standard levels.
1. Operating Hours
To develop annual energy use estimates, DOE multiplied annual usage
(in hours per year) by the lamp power (in watts) for IRLs and the lamp-
and-ballast system input power (in watts) for GSFLs. DOE characterized
representative lamp or lamp-and-ballast systems in the engineering
analysis. To
[[Page 24118]]
characterize the country's average use of lamps for a typical year, DOE
developed annual operating hour distributions by sector, using data
published in the 2010 U.S. Lighting Market Characterization report
(2010 LMC),\52\ the Commercial Building Energy Consumption Survey
(CBECS),\53\ the Manufacturer Energy Consumption Survey (MECS),\54\ and
the Residential Energy Consumption Survey (RECS).\55\
---------------------------------------------------------------------------
\52\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy. Energy Conservation Program for Consumer Products:
2010 U.S. Lighting Market Characterization. 2012. Washington, DC.
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
\53\ U.S. Department of Energy, Energy Information
Administration. Commercial Building Energy Consumption Survey:
Micro-level data, file 2 Building Activities, Special Measures of
Size, and Multi-building Facilities. 2003. Washington, DC.
www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata.
\54\ U.S. Department of Energy, Energy Information
Administration. Manufacturing Energy Consumption Survey, Table 9.1:
Enclosed Floorspace and Number of Establishment Buildings. 2006.
Washington, DC. www.eia.gov/consumption/manufacturing/data/2006/xls/Table9_1.xlsl.
\55\ U.S. Department of Energy, Energy Information
Administration. RECS Public Use Microdata files. 2009. Washington,
DC. www.eia.gov/consumption/residential/data/2009/.
---------------------------------------------------------------------------
NEMA agreed with the considered operating profiles. (NEMA, No. 36
at p. 15) GE also stated that the operating hours looked reasonable.
(GE, Public Meeting Transcript, No. 30 at p. 212) However, EEI found
the similarity between the GSFL commercial and industrial operating
hours to be surprising. (EEI, Public Meeting Transcript, No. 30 at pp.
212-213)
In the preliminary analysis, DOE calculated weighted average
operating hours using the probability of a building type within each
sector using the data sources described above. These sources provide
the most accurate and recent data available on a national scale. DOE's
approach resulted in similar operating hours for the commercial and
industrial sectors.
DOE updated the methodology for determining operating hours in the
NOPR analysis. The weighted average operating hours are based on the
probability of a GSFL or IRL within a specific building type, rather
than based on the probability of the building type. DOE used the
average lamps per square foot and the percentage of lamps that are
linear fluorescent or halogen from the 2010 LMC to calculate these
values. The average operating hours using the revised methodology are
similar to those found in the preliminary analysis. For further details
on the operating hours, see chapter 6 of the NOPR TSD.
NEEA offered data from their residential sector energy use field
survey of 2,200 lighting fixtures in 1,400 houses. NEEA noted that DOE
could use the data to verify analyses and findings. NEEA also mentioned
their commercial sector energy use field survey, but stated that they
might not have those data in time for NOPR analyses. (NEEA, Public
Meeting Transcript, No. 30 at pp. 210, 212) DOE examined NEEA's
Residential Building Stock Assessment reports,\56\ but continued to use
the data sources described above in its analysis because NEEA's data is
limited to the northwest region. DOE did not find any recent NEEA
report regarding energy usage in the commercial sector at the
publication of this notice.
---------------------------------------------------------------------------
\56\ NEEA's Residential Building Stock Assessment available at
http://neea.org/resource-center/regional-data-resources/residential-building-stock-assessment.
---------------------------------------------------------------------------
2. Lighting Controls
DOE evaluated the impact of lighting controls on the energy use of
GSFLs and IRLs. Most lighting controls have one of two impacts:
Reducing operating wattage or reducing operating hours. DOE refers to
these two groups of controls as dimmers or light sensors, and occupancy
sensors, respectively. The calculated operating hours used in the
reference case already account for the use of occupancy sensors because
the 2010 LMC operating hour data are based on building surveys and
metering data. In the preliminary analysis, DOE accounted for the use
of dimmers or light sensors by modeling GSFLs and IRLs on dimmers and
developing associated energy use results for both types of covered
lamps as a sensitivity analysis. See appendix 6A of the NOPR TSD for
further information.
Regarding the dimming scenarios, NEMA noted that the dimming
systems save more energy than the standards considered in this
rulemaking. NEMA asserted that this furthered their arguments that this
rulemaking is unnecessary and a ``system approach'' would be more
advantageous for energy efficiency. NEMA contended that DOE pursues
diminishing returns through component standards and distracts resources
from more beneficial efficiency efforts. (NEMA, No. 36 at p. 15) DOE
did not consider a system approach in this rulemaking because EPCA
directs DOE to undertake a review of standards for GSFLs and IRLs and
determine if amended standards for these lamp types would result in
energy savings. (42 U.S.C. 6295(i)(1) and (3)-(5))
a. General Service Fluorescent Lamp Lighting Controls
In the preliminary analysis, DOE assessed the impacts of dimmers on
GSFLs by determining the reduction in system lumen output and system
input power as a result of using dimming ballasts. Based on product
research and manufacturer feedback, DOE analyzed dimming scenarios for
2-lamp 4-foot MBP systems, 4-lamp 4-foot MBP systems, 2-lamp 4-foot T5
MiniBP SO systems, and 2-lamp 4-foot T5 MiniBP HO systems operating in
the commercial and industrial sectors. DOE determined that the average
reduction of system lumen output for GSFLs was 33 percent based on
research and manufacturer input.
GE asked for clarification on how DOE was incorporating the
percentage to which the dimmed lamps were being dimmed. (GE, Public
Meeting Transcript, No. 30 at pp. 211) DOE incorporated this assumption
by decreasing the BF of the baseline ballast by 33 percent and
subsequently calculating the system mean lumen output of the baseline
lamp-and-ballast system. DOE then assumed that each higher efficacy
lamp-and-ballast system would be dimmed to equal the mean lumen output
of the baseline system and adjusted the BF accordingly. DOE calculated
the percentage each higher efficacy lamp-and-ballast system was dimmed
by dividing the BF at the dimmed light output by the catalog BF at full
light output. For more information, see appendix 6A of the NOPR TSD.
Several commenters supported DOE's analysis of dimming systems for
GSFLs, noting that dimming systems are growing in popularity and
provide the potential for significant energy savings. NEMA stated that
when it encourages high efficacy fluorescent retrofits through one of
its marketing programs, it always tries to encourage lighting controls.
Thus, when a retrofit results in increased brightness there is the
option to dim, which is where the largest amount of savings lies.
(NEMA, Public Meeting Transcript, No. 30 at pp. 108-109) Further,
Lutron stated that it agreed that the 33 percent energy savings from
dimming systems cited in the preliminary analysis is close to the
actual savings that can be expected as opposed to the savings estimated
from higher lamp efficacy. (Lutron, Public Meeting Transcript, No. 30
at pp. 73-74)
Commenters expressed concerns, however, regarding the calculated
energy consumption of a dimmed lamp-and-ballast system and the
inclusion of reduced wattage lamps in the dimming
[[Page 24119]]
analysis. Lutron noted that GSFL light output and input power do not
scale perfectly linearly from zero. Lutron explained that there is an
offset at the low end that accounts for the required electrode heating,
typically a few percent of the total maximum rated power. The light
output and input power scale linearly after this point. (Lutron, Public
Meeting Transcript, No. 30 at p. 220) NEMA referenced their white paper
LSD-345 and added that the need for cathode heat skews efficacy
calculations. The lower the light output, the more cathode heat power
increases, lowering the efficacy of the system. The systems are the
most efficacious at full power, but NEMA clarified that this does not
mean that they do not save energy when dimmed, only that it is not a
linear scale. (NEMA, No. 36 at p. 14)
DOE agrees that GSFL light output and input power do not scale
linearly from zero for dimming systems. In the preliminary analysis,
DOE utilized manufacturer-published performance characteristics of the
dimming systems to develop the relationship between light output and
input power. DOE plotted the minimum and maximum light output levels
and associated system input powers published in catalogs, and then fit
a linear equation to the points. The published system input power
values at minimum light output reflected the presence of cathode heat
at minimum light output and thus the linear equations did not originate
at zero. This approach was maintained in the NOPR analysis. For more
information, see appendix 6A of the NOPR TSD.
Regarding reduced wattage lamps, commenters noted that reduced
wattage lamps, which contain krypton, did not provide the same dimming
functionality as full wattage lamps. GE observed that if the GSFL
standard is set at a level requiring a heavier fill gas, namely
krypton, then the NES would start to decrease. GE and Lutron noted that
even though controls and dimmers are already becoming required in
buildings, the krypton eliminates the ability to control and dim the
lamps, negatively affecting the energy savings. (GE, Public Meeting
Transcript, No. 30 at pp. 220-221; Lutron, Public Meeting Transcript,
No. 30 at pp. 73-74) Philips stated that there is no published testing
of dimming with krypton fill gas and currently no standards for dimming
ballasts. (Philips, Public Meeting Transcript, No. 30 at p. 222) NEMA
further emphasized these points, cautioning DOE that reduced wattage 28
W lamps are less feasible to dim than 32 W lamps. NEMA suggested DOE
model a 32 W lamp for their dimming analyses. NEMA further stated that
CSLs should be set to retain the 32 W lamps. (NEMA, No. 36 at p. 14)
DOE acknowledges that reduced wattage lamps may dim unreliably in
certain applications. DOE discusses the dimmability of reduced wattage
lamps in VI.B.1. In the preliminary analysis and this NOPR analysis,
however, DOE identified several manufacturers that published
performance data of both 28 W and 25 W 4-foot MBP lamps when paired
with dimming ballasts. This data indicates that these reduced wattage
lamp types can be utilized in some dimming applications. For this
reason, DOE continues to analyze reduced wattage 4-foot MBP lamps in
its dimming analysis in addition to full wattage 4-foot MBP lamps.
Regarding T5 lamps, DOE found that catalog information generally did
not indicate that reduced wattage T5 lamps should be operated on
dimming ballasts. Therefore, as in the preliminary analysis, DOE does
not analyze reduced wattage T5 lamps in dimming systems. As noted in
section VI.D.2.g, DOE has ensured that the full wattage lamps in all
product classes meet the proposed ELs so that full wattage lamps are
available in situations where reduced wattage fluorescent lamps are
unacceptable.
b. Incandescent Reflector Lamp Lighting Controls
In the preliminary analysis, DOE research indicated that, on
average, consumers using dimmers reduce lamp wattage by 20 percent,
corresponding to a lumen reduction of 25 percent and an increase in
lifetime by a factor of 3.94. DOE analyzed two scenarios in LCC
sensitivity analyses: (1) The light output of the baseline lamp was
reduced by 25 percent and more efficient lamps were dimmed to the same
light output and (2) the characteristics of the lamps analyzed
represented the distribution of dimmers across the nation. For the
second scenario, DOE used the 2010 LMC to determine that 29 percent of
halogen IRLs operate on dimmers or light sensors in the residential
sector and 5 percent of halogen IRLs operate on dimmers in the
commercial sector and used these percentages to calculate weighted-
average performance characteristics. DOE received several comments on
its IRL dimming analysis.
Lutron stated that they did not have independent data, but the
estimate of five percent of lamps in the commercial sector operating on
dimmers seems reasonably accurate. (Lutron, Public Meeting Transcript,
No. 30 at p. 217) However, Lutron and NEMA disagreed with the value
used for the lifetime multiplier.
Lutron commented that the lifetime multiplier given for IRLs
appears to be based on the standard incandescent formula published in
the IESNA Lighting Handbook. Lutron stated that the multiplier that
should be used for halogen PAR lamps, while still between three and
four, is lower than the multiplier DOE used. (Lutron, Public Meeting
Transcript, No. 30 at pp. 214-215) NEMA also disagreed with DOE's
assumption that the lamp life for halogen products follows the
incandescent curve of ``Life ~ V-13,'' where V is the
voltage across the filament. Based on NEMA's research, NEMA put forward
the proper relationship as ``Life ~ V-10,'' which would
result in a multiplier of 3 rather than 4 for the reduction in light
output DOE considered. Therefore, NEMA recommended a multiplier of 3,
instead of the multiplier of 4 suggested in the preliminary TSD. (NEMA,
No. 36 at p. 15)
In the preliminary analysis, DOE did not use an equation in the
IESNA Lighting Handbook to calculate the lifetime multiplier and
therefore was not employing the incandescent curve referenced by NEMA
or Lutron. Rather, DOE used Lutron's Energy Savings Calculator,
available on the Lutron Web site.\57\ The values provided in this
calculator are based on experiments conducted on halogen lamps, which
provide the most accurate representation of the lifetime increase that
occurs as a result of dimming halogen IRLs because they are based on
halogen technology instead of incandescent technology and use
experimental data. In this NOPR analysis, DOE has continued to utilize
Lutron's Energy Savings Calculator to determine the lifetime multiplier
associated with various levels of dimmed light output.
---------------------------------------------------------------------------
\57\ www.lutron.com/en-US/Education-Training/Pages/Tools/EnergySavingCalc.aspx.
---------------------------------------------------------------------------
G. Life-Cycle Cost Analysis and Payback Period Analysis
In the preliminary analysis, DOE conducted LCC and PBP analyses to
evaluate the economic impacts of potential energy conservation
standards for GSFLs and IRLs on individual consumers. The LCC is the
total consumer expense over the life of a product, consisting of
purchase, installation, and operating costs (operating costs are
expenses for energy use, maintenance, and repair). To compute the
operating costs, DOE discounted future operating costs to the time of
purchase and summed them over the lifetime of the product. The
[[Page 24120]]
PBP is the estimated amount of time (in years) it takes consumers to
recover the increased purchase cost (including installation) of a more
efficient product through lower operating costs. DOE calculates the PBP
by dividing the change in purchase cost (normally higher) by the change
in average annual operating cost (normally lower) that results from the
more efficient standard. DOE used a ``simple'' PBP for this rulemaking,
which does not take into account other changes in operating expenses
over time or the time value of money.
For any given efficacy or energy use level, DOE measures the PBP
and the change in LCC relative to an estimated base-case product
efficacy or energy use level. The base-case estimate reflects the
market without new or amended mandatory energy conservation standards,
including the market for products that exceed the current energy
conservation standards.
Inputs to the calculation of total installed cost include the cost
of the product--which includes consumer product price and sales taxes--
and installation costs. Inputs to the calculation of operating expenses
include annual energy consumption, energy prices and price projections,
repair and maintenance costs, product lifetimes, discount rates, and
the year in which compliance with proposed standards would be required.
DOE also incorporated a residual value calculation to account for any
remaining lifetime of lamps at the end of the analysis period. The
residual value is an estimate of the product's value to the consumer at
the end of the LCC analysis period. In addition, this residual value
recognizes that a lamp may continue to function beyond the end of the
analysis period. DOE calculates the residual value by linearly
prorating the product's initial cost consistent with the methodology
described in the Life-Cycle Costing Manual for the Federal Energy
Management Program.\58\
---------------------------------------------------------------------------
\58\ Fuller, Sieglinde K. and Stephen R. Peterson. National
Institute of Standards and Technology Handbook 135 (1996 Edition);
Life-Cycle Costing Manual for the Federal Energy Management Program.
(Prepared for U.S. Department of Energy, Federal Energy Management
Program, Office of the Assistant Secretary for Conservation and
Renewable Energy.) February 1996. NIST: Gaithersburg, MD. Available
at: http://fire.nist.gov/bfrlpubs/build96/PDF/b96121.pdf.
---------------------------------------------------------------------------
As inputs to the PBP analysis, DOE used the total installed cost of
the product to the consumer for each efficacy level, as well as the
first-year annual operating costs for each efficacy level. The
calculation requires the same inputs as the LCC, except for energy
price trends and discount rates; only energy prices for the year in
which compliance with any new standard would be required (2017, in this
case) are needed.
To account for uncertainty and variability, DOE created value
distributions for inputs as appropriate, including operating hours,
electricity prices, discount rates and sales tax rates, and disposal
costs. For example, DOE created a probability distribution of annual
energy consumption in its energy use analysis, based in part on a range
of annual operating hours. The operating hour distributions capture
variation across census divisions and large states, building types, and
lamp or lamp-and-ballast systems for three sectors (commercial,
industrial, and residential).
DOE conducted the LCC and PBP analyses using a spreadsheet model
developed in Microsoft Excel. When combined with Crystal Ball (a
commercially available software program), the spreadsheet model
generates a Monte Carlo simulation \59\ to perform the analysis by
incorporating uncertainty and variability considerations. The Monte
Carlo simulations randomly sample input values from the probability
distributions and lamp user samples, performing 1,000 iterations per
simulation run.
---------------------------------------------------------------------------
\59\ Monte Carlo simulations model uncertainty by utilizing
probability distributions instead of single values for certain
inputs and variables.
---------------------------------------------------------------------------
NEMA commented on the general LCC methodology used in the
preliminary analysis, stating that it appears the 30-year payback
period for LCC analysis timeline, about which they had previously
expressed concern, has been stretched to a 70-year period for this
rulemaking. NEMA assumed the time period was chosen to justify
feasibility arguments that have miniscule payback estimates. NEMA
requested that DOE clarify the 70-year forecasting and related
analyses, and explain the justification for examining such a long
period. (NEMA, No. 36 at pp. 3-4)
The PBP is the amount of time it takes the consumer to recover the
assumed higher purchase cost of a more-efficacious product through
lower operating costs. DOE calculates and presents the payback period
for all LCC scenarios, regardless of the value of the payback period,
including the long payback periods referenced by NEMA. Payback periods
are one of the factors that DOE considers when weighing the benefits
and burdens of TSLs.
In the NOPR analysis, DOE generally maintained the methodology from
the preliminary analysis, with a few changes. Table VI.13 summarizes
the approach and data DOE used to derive inputs to the LCC and PBP
calculations for the preliminary analysis as well as the changes made
for this NOPR. The NOPR TSD chapter 8 and its appendices provide
details on the spreadsheet model and of all the inputs to the LCC and
PBP analyses. The NOPR TSD appendix 8B provides results of the
sensitivity analyses conducted using Monte Carlo simulation. The
subsections that follow discuss the comments regarding each initial
input and any changes made to them in the NOPR analysis.
Table VI.13--Summary of Inputs and Key Assumptions in the LCC and PBP
Analyses *
------------------------------------------------------------------------
Changes for the
Inputs Preliminary TSD proposed rule
------------------------------------------------------------------------
Consumer Product Price...... Applied discounts to Applied discounts to
manufacturer manufacturer
catalog (``blue catalog (``blue
book'') pricing in book'') pricing in
order to represent order to represent
low, medium, and low, medium, and
high prices for all high prices for all
lamp categories. lamp categories.
Used medium prices Used a weighted
in the main average price in
analysis. the main analysis
based on the
percentage of
shipments that go
through the
distribution
channel having low,
medium, or high
prices.
[[Page 24121]]
Sales Tax................... Derived population- Derived sector-
weighted-average specific average
tax values for each tax values based on
census division and the probability of
large state \60\ purchasing a GSFL
from data provided or IRL in each
by the Sales Tax census division and
Clearinghouse. large state from
data provided by
the Sales Tax
Clearinghouse.
Installation Cost........... Derived costs using No change.
the RS Means
Electrical Cost
Data and U.S.
Bureau of Labor
Statistics to
obtain average
labor times for
installation, as
well as labor rates
for electricians
and helpers based
on wage rates,
benefits, and
training costs.
Annual Operating Hours...... Determined operating Determined operating
hours by hours by
associating associating
building-type- operating hours for
specific operating a GSFL or IRL in a
hour data with specific building
regional type using the
distributions of average lamps per
various building square foot and the
types using the percentage of lamps
2010 LMC and EIA's of each type with
2003 CBECS, 2009 regional
RECS, and 2006 MECS. distributions of
various building
types using the
2010 LMC and EIA's
2003 CBECS, 2009
RECS, and 2006
MECS.
Product Energy Consumption Determined lamp No change.
Rate. input power for
IRLs based on
published
manufacturer
literature.
Calculated system
input power for
GSFLs. Used lamp
arc power, catalog
BF, number of lamps
per system, and
tested BLE (when
possible) to
calculate system
input power for
each unique lamp-
and-ballast
combination.
Electricity Prices.......... Electricity: Based Electricity: Based
on EIA's Form 861 on EIA's Form 861
data for 2011. data for 2011
scaled to 2012 (the
dollar year of the
analysis) using AEO
2013 and the
consumer price
index.
Variability: Variability:
Weighted average Weighted average
national price for national price for
each sector each sector and
calculated from the lamp type
probability of each calculated from the
building type probability of a
within each census GSFL or IRL
division or large purchased in each
state. census division or
large state
Electricity Price Forecasted using AEO Forecasted using AEO
Projections. 2012. 2013.
Replacement and Disposal Commercial and No change.
Costs. industrial:
Included labor and
materials costs for
lamp replacement,
and disposal costs
for failed GSFLs.
Residential:
Included only
materials cost for
lamps, with no lamp
disposal costs.
Product Lifetime............ Ballast lifetime No change.
based on average
ballast life of
49,054 from 2011
Ballast Rule. Lamp
lifetime based on
published
manufacturer
literature where
available.
Discount Rates.............. Commercial and No change.
industrial: Derived
discount rates
using the cost of
capital of publicly
traded firms in the
sectors that
purchase lamps,
based on data in
the 2003 CBECS,
Damodaran
Online,\61\ Office
of Management and
Budget (OMB)
Circular No. A-
94,\62\ and state
and local bond
interest rates \63\.
Residential: Derived
discount rates
using the finance
cost of raising
funds to purchase
lamps either
through the
financial cost of
any debt incurred
to purchase product
or the opportunity
cost of any equity
used to purchase
equipment, based on
the Federal
Reserve's Survey of
Consumer Finances
data \64\ for 1989,
1992, 1995, 1998,
2001, 2004, 2007,
and 2010.
Analysis Period............. IRLs and commercial IRLs and commercial
and industrial and industrial
GSFLs: Based on the GSFLs: No change.
baseline lamp life
in hours divided by
the annual
operating hours of
that lamp.
Residential GSFLs Residential GSFLs
lamp failure: Based lamp failure: Based
on the baseline on the lifetime of
lamp life in hours the ballast.
divided by the
annual operating
hours of that lamp.
[[Page 24122]]
Residential GSFLs Residential GSFLs
ballast failure and ballast failure and
new construction/ new construction/
renovation: Based renovation: No
on the lifetime of change.
the ballast.
Compliance Date of Standards 2017................ No change.
Lamp Purchase Events........ Assessed three No change.
events: lamp
failure, ballast
failure (GSFLs
only), and new
construction/
renovation.
------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided
in the sections following the table or in chapter 8 of the NOPR TSD.
---------------------------------------------------------------------------
\60\ The four large states are New York, California, Texas, and
Florida.
\61\ Damodaran Online, The Data Page: Historical Returns on
Stocks, Bonds, and Bills--United States (2013). Available at: http:/
/pages.stern.nyu.edu/~adamodar. (Last accessed September, 2013.)
\62\ U.S. Office of Management and Budget, Circular No. A-94
Appendix C (2012). Available at: www.whitehouse.gov/omb/circulars_a094/a94_appx-c.
\63\ Federal Reserve Board, Statistics: Releases and Historical
Data--Selected Interest Rates--State and Local Bonds (2013).
Available at: http://www.federalreserve.gov/pubs/oss/oss2/scfindex.html.
\64\ The Federal Reserve Board, Survey of Consumer Finances.
Available at: www.federalreserve.gov/PUBS/oss/oss2/scfindex.html.
---------------------------------------------------------------------------
1. Consumer Product Price
In the preliminary analysis, DOE used a variety of sources to
develop consumer product prices, including lamp prices from
manufacturers' blue books, state procurement contracts, large
electrical supply distributors, hardware and home improvement stores,
Internet retailers, and other similar sources. DOE then developed low,
medium, and high prices based on its findings. Medium prices were used
in the main analysis results. In the NOPR analysis, DOE maintained the
same methodology but calculated a weighted average price based on the
percentage of shipments going through the low discount (high price),
medium discount (medium price), and high discount (low price)
distribution channels. Because fluorescent lamps operate on a ballast
in practice, DOE analyzed lamp-and-ballast systems in the engineering
analysis and therefore also determined end-user prices for ballasts.
DOE utilized the end-user prices from the 2011 Ballast Rule converted
to 2012$ to develop prices for replacement ballasts.
On February 22, 2011, DOE published a notice of data availability
(NODA; 76 FR 9696) stating that DOE may consider whether its regulatory
analysis would be improved by addressing product price trends. Using
three decades of historic data on the quantities and values of domestic
shipments of fluorescent lamps and PAR lamps reported by the U.S.
Census Bureau in their Current Industrial Reports, DOE examined product
prices trends, fitting the data to an experience curve, as described in
chapter 11 of the NOPR TSD. DOE found that the data are well-
represented by the experience curve and consistent with price learning
theory. Therefore, consistent with the NODA, DOE incorporated price
trends into this rulemaking. In the LCC analysis, DOE adjusts prices
for each year using the experience curve.
2. Sales Tax
In the preliminary analysis, DOE obtained state and local sales tax
data from the Sales Tax Clearinghouse. The data represented weighted
averages that included county and city rates. DOE used the data to
compute population-weighted average tax values for each census division
and four large states (New York, California, Texas, and Florida).
EEI asked if DOE had any information on local sales taxes, such as
city or county taxes, which would be added to the state sales tax. EEI
noted that without considering the additional local taxes, especially
in urban areas with commercial buildings, DOE may be missing relevant
sales tax data. (EEI, Public Meeting Transcript, No. 30 at pp. 230-231)
NEEA added that there are some publicly available local tax data by
county. (NEEA, Public Meeting Transcript, No. 30 at p. 231)
In the preliminary analysis, DOE used the Sales Tax Clearinghouse
for sales tax data by state. Because the Sales Tax Clearinghouse
specifies that the aggregate rates are weighted averages that include
county and city rates, DOE accounts for the levels of taxes described
in the comments.
In this NOPR analysis, DOE used updated sales tax data from the
Sales Tax Clearinghouse.\65\ DOE recognized that a population-weighted
tax value may not accurately represent the probability of a lamp type
purchased in each census division and large state. Therefore, in the
NOPR analysis, DOE calculated a weighted average sales tax based on the
probability of a GSFL or IRL purchased for a particular building type
in each census division and large state. DOE used information in the
2010 LMC, such as the number of lamps per square feet and the
percentage of lamps within a building that are linear fluorescent or
halogen. In combination with this information, DOE used CBECS, MECS,
and RECS respectively, for commercial, industrial, and residential
building data on building types in each census division and large
state. Thus, in the preliminary analysis, the sales tax was averaged
based on the number of people in a region or state, whereas in the
NOPR, the sales tax is averaged based on how many people purchase a
GSFL or IRL in a region or state.
---------------------------------------------------------------------------
\65\ Sales Tax Clearinghouse. Aggregate State Tax Rates. (2013).
Available at: http://thestc.com/STrates.stm.
---------------------------------------------------------------------------
3. Installation Cost
The installation cost is the total cost to the consumer to install
the product, excluding the consumer product price. Installation costs
include labor, overhead, and any miscellaneous materials and parts. As
detailed in the preliminary analysis, DOE considered the total
installed cost of a lamp or lamp-and-ballast system to be the consumer
product price (including sales taxes) plus the installation cost. For
the commercial and industrial sectors, DOE assumed consumers must pay
to install the lamp or lamp-and-ballast system and assumed the
installation cost was the product of the average labor rate and the
time needed to install a lamp or lamp and ballast. In the residential
sector, DOE assumed that consumers must pay for only the installation
of a lamp-and-ballast system. Therefore, the installation cost assumed
was the product of the average labor rate and the time needed to
install the lamp-and-ballast system. DOE assumed that residential
consumers would install their own replacement lamps and, thus, would
incur no installation cost when replacing their own lamp.
[[Page 24123]]
DOE did not receive any comments on the installation cost. DOE
retained this methodology for determining installation costs in this
NOPR analysis.
4. Annual Energy Use
As discussed in section VI.F, DOE estimated the annual energy use
of representative lamp or lamp-and-ballast systems by multiplying input
power and sector operating hours. DOE maintained its methodology of
determining annual energy use inputs in this NOPR analysis.
5. Product Energy Consumption Rate
As in the preliminary analysis, DOE determined lamp input power for
IRLs based on published manufacturer literature. For GSFLs, DOE
calculated the system input power using published manufacturer
literature and test data. DOE used lamp arc power, catalog BF, number
of lamps per system, and tested BLE (when possible) to calculate system
input power for each unique lamp-and-ballast combination. The rated
system input power was then multiplied by the annual operating hours of
the system to determine the annual energy consumption. DOE did not
receive any comments on energy consumption rate calculations. DOE
retained this methodology for determining energy consumption in this
NOPR analysis.
6. Electricity Prices
For the LCC and PBP in the preliminary analysis, DOE derived
average energy prices for 13 U.S. geographic areas consisting of the
nine census divisions, with four large states (New York, Florida,
Texas, and California) treated separately. For census divisions
containing one of these large states, DOE calculated the regional
average excluding the data for the large state. The derivation of
prices was based on data from EIA Form 861, ``Annual Electric Power
Industry Database.'' DOE calculated a weighted average national
electricity price for each sector using the probability of each
building type within each census division or large state. DOE did not
receive any comments on this approach.
In the NOPR analysis, DOE calculated weighted average electricity
prices based on the probability of a GSFL or IRL purchased in each
census division and large state. The same methodology as noted
previously for determining average weighted sales tax was used to
calculate average weighted electricity prices. DOE used data published
in the 2010 LMC in combination with CBECS, MECS, and RECS to determine
an average weighted electricity price based on the probability of a
GSFL or IRL in a particular building type in each census division and
large state. DOE requests comment on its methodology of determining
average weighted electricity prices.
7. Electricity Price Projections
To estimate the trends in energy prices for the preliminary
analysis, DOE used the price forecasts in AEO 2012. To arrive at prices
in future years, DOE multiplied current average prices by the forecast
of annual average price changes in AEO 2012. In this NOPR analysis, DOE
used the same approach, but updated its energy price forecasts using
AEO 2013. DOE intends to update its energy price forecasts for the
final rule based on the latest available AEO. In addition, the
spreadsheet tools that DOE used to conduct the LCC and PBP analyses
allow users to select price forecasts from AEO's low-growth, high-
growth, and reference case scenarios to estimate the sensitivity of the
LCC and PBP to different energy price forecasts. DOE did not receive
any comments on its methodology for determining electricity price
projections.
8. Replacement and Disposal Costs
In its preliminary analysis, DOE addressed lamp replacements
occurring within the analysis period as part of installed costs for
considered lamp or lamp-and-ballast system designs. Replacement costs
in the commercial and industrial sectors included the labor and
materials costs associated with replacing a lamp at the end of its
lifetime, discounted to 2011$. For the residential sector, DOE assumed
that consumers would install their own replacement lamps and incur no
related labor costs.
Some consumers recycle failed GSFLs, thus incurring a disposal
cost. In its research, DOE found average disposal costs of 10 cents per
linear foot for GSFLs.\66\ A 2004 report by the Association of Lighting
and Mercury Recyclers noted that approximately 30 percent of lamps used
by businesses and 2 percent of lamps in the residential sector are
recycled nationwide.\67\ DOE considered the 30 percent lamp-recycling
rate to be significant and incorporated GSFL disposal costs into the
LCC analysis for commercial and industrial consumers. Given the very
low (2 percent) estimated lamp recycling rate in the residential
sector, DOE assumed that residential consumers would be less likely to
voluntarily incur the higher disposal costs. Therefore, DOE excluded
the disposal costs for lamps or ballasts from the LCC analysis for
residential GSFLs.
---------------------------------------------------------------------------
\66\ Environmental Health and Safety Online's fluorescent lights
and lighting disposal and recycling Web page--Recycling Costs.
Available at www.ehso.com/fluoresc.php. (Last accessed October 11,
2013.)
\67\ Association of Lighting and Mercury Recyclers, ``National
Mercury-Lamp Recycling Rate and Availability of Lamp Recycling
Services in the U.S.'' Nov. 2004.
---------------------------------------------------------------------------
DOE received no comments concerning these assumed recycling rates,
disposal costs, and their application in the LCC analysis. DOE
maintained this approach in the NOPR analysis.
9. Lamp Purchase Events
DOE designed the LCC and PBP analyses for this rulemaking around
scenarios where consumers need to purchase a lamp. Each of these events
may give the consumer a different set of lamp or lamp-and-ballast
designs and, therefore, a different set of LCC savings for a certain
efficacy level. In the preliminary analysis, DOE evaluated three types
of events that would prompt a consumer to purchase a lamp. These events
are described below. DOE requests comments on these lamp purchasing
events developed for this analysis. Though described primarily in the
context of GSFLs, lamp purchase events can be applied to IRLs as well.
However, considering that IRLs are not used with a ballast, the only
lamp purchase events applicable to IRLs are lamp failure (Event I) and
new construction and renovation (Event III).
Lamp Failure (Event I): This event reflects a scenario in
which a lamp has failed (spot relamping) or is about to fail (group
relamping). In the base case, identical lamps are installed as
replacements. In the standards case, the consumer installs a standards
compliant lamp that is compatible with the existing ballast.
Ballast Failure (Event II): This is a scenario in which
the failure of the installed ballast triggers a lamp and ballast
purchase.
New Construction and Renovation (Event III): This event
encompasses all fixture installations where the lighting design will be
completely new or can be completely changed. During new construction
and renovation, the spatial layout of fixtures in a building space is
not constrained to any previous configuration. However, because DOE's
higher efficacy replacements generally maintain lumen output within 10
percent of the baseline system, DOE did not assume that spacing was
changed.
DOE received comments stating that fixture spacing is adjusted
during new construction and renovation. NEEA related that during tenant
improvement in their market, the ceiling is the first
[[Page 24124]]
item to be stripped, and the lighting system is redesigned as part of
the regular renovation between tenant occupancies. Therefore, NEEA
contended, brand new ballasts and lamps are installed without regard to
the previous fixture locations. NEEA added that T8 lamps are the only
lighting element likely to be preserved in this scenario, and they
would be used in a new fixture with a new ballast. (NEEA, Public
Meeting Transcript, No. 30 at pp. 261-262) EEI commented that there are
minimum foot-candle requirements to light spaces, and scenarios that
result in lower lumen output from the baseline system will also include
adjustments to the fixture spacing to maintain those lumens. (EEI,
Public Meeting Transcript, No. 30 at pp. 257-258)
NEEA also argued that respacing would occur with a new renovation
because the space would likely gain a whole new control system with
daylighting and dimming fixtures not installed previously. Due to a
different number people in a different office configuration, everything
would have to be redesigned, making renovation more like new
construction. (NEEA, Public Meeting Transcript, No. 30 at p. 263)
However, Lutron stated that all the elements added in the described
renovation were the result of design and technical changes unrelated to
the lighting regulations. (Lutron, Public Meeting Transcript, No. 30 at
p. 263) Lutron noted that even if the lighting design of a space was
completely altered during renovation, there would still be the same
number of lamps and the same load. (Lutron, Public Meeting Transcript,
No. 30 at pp. 262-263)
DOE also received several comments indicating that the respacing of
fixtures, even in new construction or renovation, is unlikely due to
ceiling grid constraints. NEMA stated that respacing is not a practical
assumption for this rulemaking, and would not happen in practice other
than to existing ready-made dimensions. Spacing is effectively
constrained by existing practices and ceiling grid construction, and
not determined by the lighting selected. Further, NEMA clarified that
spacing is almost always based on the available 1 by 1, 2 by 2, or 2 by
4 ceiling grids, and that must be factored into the analysis. The
likelihood of other spacing is near zero. (NEMA, No. 36 at p. 16) GE
agreed that the standard 2 by 4 ceiling grids make it nearly impossible
to respace fixtures in response to a change of a few lumens per watt.
(GE, Public Meeting Transcript, No. 30 at pp. 258-289)
NEMA also noted that there is an interdependence among the ceiling
material, the modular wire strings, the fixtures, and the fixtures'
performance. (NEMA, Public Meeting Transcript, No. 30 at pp. 259-260)
Philips added that when adjusting fixture spacing, the hangers for the
lights will also have to be changed in many scenarios. Given that this
modification necessitates going into the ceiling, and the prevalence of
asbestos, it is unlikely the consumer would want to make this
adjustment. (Philips, Public Meeting Transcript, No. 30 at pp. 260-261)
If consumers were not installing new lamps, GE believed they would more
likely switch to a ballast with a better ballast factor rather than
respace fixtures. (GE, Public Meeting Transcript, No. 30 at pp. 258-
259)
NEMA further remarked that substantial changes in efficacy or lumen
output are necessary to warrant space changes. (NEMA, No. 36 at p. 16)
GE agreed that it would be very unlikely for users to respace fixtures
to accommodate compliant lamps' lumen output. (GE, Public Meeting
Transcript, No. 30 at pp. 258-289)
DOE agrees that spacing adjustments are not practical. Ceiling grid
systems typically come in fixed layouts, and lamp fixtures are sized to
be compatible with the commonly available grid options. Thus, DOE
believes that consumers are limited in the spacing of fixtures by the
ceiling grid and its associated components. DOE also agrees that
consumers would be more likely to change light output levels by
adjusting system components such as the ballast factor (i.e., use a
high BF or low BF ballast) or lamp lumen output levels (e.g., 32 W 4-
foot MBP high lumen lamp) rather than attempting to adjust fixture
spacing using non-standard ceiling grids. DOE acknowledges that fixture
spacing adjustments may be done in certain cases as cited by NEEA.
Based on available information and the other comments discussed above,
however, such adjustments are not a common practice nationwide. Thus,
DOE did not include spacing adjustments as part of the LCC analysis.
10. Product Lifetime
a. Lamp Lifetime
In the preliminary analysis, DOE used manufacturer literature to
determine lamp lifetimes. DOE also considered the impact of group
relamping practices on GSFL lifetime in the commercial and industrial
sectors. In the preliminary analysis, DOE assumed that a lamp subject
to group relamping operates for 75 percent of its rated lifetime, an
estimate obtained from the 2011 Ballast Rule. However, DOE received
information from manufacturers in interviews that consumer behavior has
changed and group relamping now occurs at 85-90 percent of rated life.
Therefore, in the NOPR analysis DOE assumes that a lamp subject to
group relamping operates for 85 percent of its rated lifetime. By
considering lamp rated lifetimes and the prevalence of group versus
spot relamping practices, DOE derived an average lifetime for a GSFL.
This ranged from 94 percent of rated lifetime for 8-foot SP slimline
lamps to 96 percent of rated lifetime for 4-foot MBP lamps. See chapter
8 of the NOPR TSD for further details. DOE requests comment on its spot
and group relamping assumptions, particularly the percent of rated life
at which group relamping occurs.
As stated above, DOE is using 15 years as the estimated fixture and
ballast lifetime in the residential sector for purposes of its
analyses. In the preliminary analysis, the lifetime of the baseline
GSFL in the residential sector was calculated by dividing the life in
hours by the average operating hours of a GSFL in the residential
sector (648 hours per year), which resulted in a lifetime of 37 years
for the baseline lamp. Because this lifetime of the baseline lamp was
longer than the average lifetime of a fixture and ballast, for the lamp
failure scenario, DOE assumed that residential sector GSFL consumers
were able to realize the full rated lifetime of their lamps. Therefore,
at the average operating hours of 648 hours per year, DOE utilized the
full lifetime of the baseline lamp (37 years) as the analysis period.
DOE assumed that when a ballast is removed in the middle of the
analysis period, these consumers preserve their lamps, purchase a new
ballast of the same type as the initial ballast, and then have the new
ballast installed with the preserved lamps (incurring a lamp-and-
ballast system installation cost). In contrast, for the ballast failure
and new construction and renovation events, DOE assumed that the
ballast or fixture lifetime limits the lifetime of an average lamp in
the residential sector. Under average operating hours of 648 hours per
year, DOE assumed that lamp lifetime of the baseline-case and
standards-case lamps is limited to 9,723 hours or 15 years, due to a
ballast or fixture failure. See section VI.G.9 and chapter 5 of the
NOPR TSD for a description of lamp purchase events. DOE requests
comment on its general approach to determining lamp lifetime for this
analysis.
NEMA disagreed with the assumption that lamps will be retained upon
ballast failure. NEMA stated that the most likely thing that occurs
when a light fixture in the residential sector fails to
[[Page 24125]]
provide light is that new lamps are purchased. The next step if the
fixture still does not work is to replace the whole fixture, not just
the ballast. As a result, NEMA contended that a failed ballast will
result in the lamps (new and old) being scrapped (or returned) when the
entire fixture is replaced. (NEMA, No. 36 at p. 16) GE explained that
when a ballast fails, it can operate in such a way that damages the
lamp, especially the cathodes. When a lamp goes out, a residential
consumer will likely assume that the problem is the lamp itself; very
rarely would a consumer understand that only the ballast needs to be
replaced and instead replace the entire fixture. (GE, Public Meeting
Transcript, No. 30 at pp. 235-237)
DOE evaluated the likely replacement scenarios suggested by
stakeholders and agrees that it is more likely for a residential
consumer to replace an entire lamp-and-ballast system rather than only
the ballast because consumers would not necessarily be aware that only
the ballast failed. Thus, in the NOPR analysis, DOE no longer assumes
that consumers retain their lamp when the ballast fails. See Appendix
8B of the NOPR TSD for more details. DOE requests comment on its
approach to determining lamp lifetime.
b. Ballast Lifetime
Chapter 8 of the preliminary analysis detailed DOE's development of
average ballast lifetimes, which were based on assumptions used in the
2011 Ballast Rule. For ballasts in the commercial and industrial
sectors, DOE used an average ballast lifetime of 49,054 hours.
Consistent with the 2011 Ballast Rule, DOE assumed an average ballast
lifetime of approximately 15 years in the residential sector. DOE
received no comments on this approach. In this NOPR analysis DOE
retained the ballast lifetimes used in the preliminary analysis.
11. Discount Rates
The calculation of consumer LCC requires the use of an appropriate
discount rate. DOE used the discount rate to determine the present
value of lifetime operating expenses. The discount rate used in the LCC
analysis represents the rate from an individual consumer's
perspective.\68\
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\68\ The consumer discount rate is in contrast to the discount
rates used in the NIA, which are intended to represent the rate of
return of capital in the U.S. economy as well as the societal rate
of return on private consumption.
---------------------------------------------------------------------------
In the preliminary analysis, for the residential sector, DOE
derived discount rates from estimates of the interest or ``finance
cost'' to purchase residential products. The finance cost of raising
funds to purchase these products can be interpreted as: (1) The
financial cost of any debt incurred to purchase products (principally
interest charges on debt), or (2) the opportunity cost of any equity
used to purchase products (principally interest earnings on household
equity). Household equity is represented by holdings in assets such as
stocks and bonds, as well as the return on homeowner equity. Much of
the data required, which involves determining the cost of debt and
equity, comes from the Federal Reserve Board's triennial ``Survey of
Consumer Finances.'' \69\ For the commercial and industrial sectors,
DOE derived discount rates from the cost of capital of publicly traded
firms in the business sectors that purchase lamps.
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\69\ The Federal Reserve Board. Survey of Consumer Finances
1989, 1992, 1995, 1998, 2001, 2004, 2007, 2010. Federal Reserve
Board: Washington, DC. Available at: www.federalreserve.gov/pubs/
oss/oss2/scfindex.html.
---------------------------------------------------------------------------
EEI pointed out residential consumers have a lower discount rate
than industrial customers do. EEI noted that if residential consumers
use any form of credit, the nominal interest rate typically will be
above 10 percent. Thus, EEI questioned why a well-capitalized
industrial company would have a higher discount rate than residential
consumers with varying incomes and credit card interest rates. (EEI,
Public Meeting Transcript, No. 30 at pp. 228-229)
The discount rate is the rate at which future expenditures are
discounted to estimate their present value. The discount rate accounts
for consumers placing a certain value on spending money now versus in
the future. For residential consumers, DOE estimated the discount rate
by looking across all possible debt or asset classes. Thus, the
residential discount rate is not limited to credit. The residential
discount rate analysis factors in 12 different methods to finance
purchases and the rates for these methods vary from 0 to 10.4 percent.
As DOE estimates the discount rate by looking across all 12 of these
debt and asset classes, and the discount rate is not limited to credit,
the average rate is lower than 10 percent. For the commercial and
industrial consumers, DOE estimated the cost of capital for commercial
and industrial companies by examining both debt and equity capital, and
developed an appropriate weighted average of the cost to the company of
equity and debt financing. After performing these calculations and
averaging each discount rate across various types of consumers, the
residential discount rate was calculated to be lower than the
industrial discount rate. Therefore, DOE believes it is appropriately
determining discount rates for all types of consumers and has
maintained this methodology in this NOPR analysis. For further details
on discount rates, see chapter 8 and appendix 8C of the NOPR TSD.
12. Analysis Period
The analysis period is the span of time over which the LCC is
calculated. In the preliminary analysis, DOE used the longest baseline
lamp life in a product class divided by the annual operating hours of
that lamp as the analysis period. During Monte Carlo simulations for
the LCC analysis, DOE selected the analysis period based on the longest
baseline lamp life divided by the annual operating hours chosen by
Crystal Ball. For GSFLs in the residential sector, the analysis period
is based on the useful life of the baseline lamp for a specific event.
DOE did not receive any comments on this methodology. DOE maintained
this approach for determining the analysis period in the NOPR analysis.
DOE requests comment on its LCC analysis period assumptions. In
particular, DOE requests comment on basing the analysis period on the
baseline lamp life divided by the annual operating hours of that lamp
for the IRL and commercial and industrial sector GSFL analyses. DOE
also requests comment on basing the analysis period on the useful life
of the baseline lamp for a specific event for residential GSFLs.
13. Compliance Date of Standards
The compliance date is the date when a covered product is required
to meet a new or amended standard. DOE expects to publish any amended
standards for GSFLs and IRLs in 2014. As a result, consistent with 42
U.S.C. 6295(i)(5), DOE expects the compliance date to be 2017, three
years after the publication of any final amended standards. DOE
received no comments on its expected standards compliance date of 2017
and calculated the LCC for all end users as if each one would purchase
a new lamp in the year compliance with the standard is required.
14. General Service Fluorescent Lamp Life-Cycle Cost Results in the
Preliminary Analysis
NEMA and EEI noted that in the tables presented at the public
meeting, the results for the GSFL LCC savings included instances of
``NR.'' (NEMA, No. 36 at pp. 15-16; EEI, Public Meeting Transcript, No.
30 at pp. 245-246) NEMA assumed NR indicated that the
[[Page 24126]]
energy savings were zero or negative and stated that figures should be
added to the results because missing data points would skew the
findings. NEMA stated that DOE should factor CSLs' negative impacts
into the analysis or give reasons why figures should not be included.
(NEMA, No. 36 at pp. 15-16) EEI attributed the ``NR'' to the baseline
and CSL 1 lamps having the same nominal and rated wattages. EEI urged
DOE to show the energy savings for every event, even if they are zero.
As the event is a possibility under standards, it will be an economic
cost to the consumer and the results need to be factored into the
analysis and reported numerically rather than ``NR.'' (EEI, Public
Meeting Transcript, No. 30 at pp. 245-246)
In the preliminary analysis for the lamp replacement scenario, DOE
utilized ``NR'' to indicate that no replacement option existed that
reduced energy consumption at a given efficacy level because the lamp
wattage at the higher efficacy level was the same as the baseline and
the higher efficacy lamp was operated on the same ballast. DOE revised
its NOPR engineering analysis to consider lamps that do not reduce
energy consumption. These were incorporated into the NOPR LCC analysis.
See section VI.D.2.e for further details on lamp-and-ballast systems
developed in the engineering analysis.
Regarding the instant start 4-foot MBP results, EEI also noted that
another lamp at CSL 2 had the same nominal and rated wattage as the
baseline lamp, but shows positive energy savings. EEI asked for an
explanation for the reported positive energy savings where EEI would
not expect there to be any. (EEI, Public Meeting Transcript, No. 30 at
pp. 245-246) For the 4-foot MBP instant start lamps at CSL 2 with the
same nominal and rated wattage as the baseline lamp, the BF of the
ballast on which the higher efficacy lamp was operating was lower than
the BF of the ballast on which the baseline lamp was operating. A lamp-
and-ballast system with a more efficacious, similar wattage lamp and
lower BF ballast will consume less energy while maintaining similar
light output compared to the baseline system. DOE considered ballasts
with varying BFs in the ballast failure event and new construction and
renovation event.
Lutron expressed concern that there were positive LCC savings only
for reduced wattage lamp replacements. Lutron questioned whether DOE
was taking into account the probable increased use of dimming systems
in the future, especially in new construction and renovation. As
reduced wattage lamps are not compatible with dimming, their LCC
savings would likely be lower than shown, but would be greater if total
energy use was taken into account. (Lutron, Public Meeting Transcript,
No. 30 at p. 251) DOE accounts for lighting controls in the LCC in a
sensitivity analysis. See section VI.F.2 and appendix 8B of the NOPR
TSD for more details.
NEEP provided information that some of the ballast failure
scenarios included in the analysis are very uncommon. For example, DOE
analyzed T8 programmed start ballasts when the vast majority of
existing ballasts are instant start. (NEEP, No. 33 at p. 3)
Although certain ballast scenarios may be less common, DOE's
research indicates that they are already in use and increasing in
market share. In the 2011 Ballast Rule,\70\ DOE analyzed programmed
start ballasts for 4-foot MBP lamps directly due to their increasing
market share. Programmed start ballasts are typically used in
applications with frequent switching such as those with occupancy
sensors. Because lighting controls are becoming more common, as
discussed in section I.A.1.a, the use of programmed start ballasts is
expected to increase. Additionally, DOE notes that the start year of
the analysis is 2017 and, therefore, it was appropriate to include
programmed start ballasts because of their expected increase in market
share. DOE continued to include these scenarios in the LCC NOPR
analysis.
---------------------------------------------------------------------------
\70\ The final rule amending energy conservation standards for
fluorescent lamp ballasts published in 2011 with a compliance date
of November 14, 2014. 76 FR 70548 (Nov. 14, 2011). The full text and
all related documents of the 2011 Ballast Rule can be found on
regulations.gov, docket number EERE-2007-BT-STD-0016 at
www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016.
---------------------------------------------------------------------------
CA Utilities questioned why DOE had not considered delamping
scenarios, using high ballast factors such as 1 or 1.15, adding
reflectors, or other kinds of optimized retrofits. (CA IOUs, Public
Meeting Transcript, No. 30 at pp. 253-254) The CA IOUs stated that
there would be scenarios where DOE could use such measures to optimize
cost-effectiveness. (CA IOUs, Public Meeting Transcript, No. 30 at p.
254) However, EEI reasoned that there are too many other options and
materials that could be included, and some of them would be
possibilities for the baseline lamps as well, such as reflectors and
ballasts with tandem wiring. EEI concluded that if DOE attempts to
account for all possible scenarios, the analysis may no longer reflect
what is actually happening with lamp efficacy or the most likely
retrofit or new construction scenario in the presence of amended
standards. (EEI, Public Meeting Transcript, No. 30 at pp. 254-256)
NEEA noted that delamping is a fairly common scenario, especially
if DOE considers lighting retrofit as renovation, and NEEA stated they
may have some data on such scenarios. (NEEA, Public Meeting Transcript,
No. 30 at pp. 256) GE agreed that delamping is a very typical situation
when moving from T12 to T8 systems. GE noted, however, that in a T8 to
T8 analysis, delamping would be much less likely. GE agreed that the
practice was common in the past, but did not anticipate it being that
common going forward. (GE, Public Meeting Transcript, No. 30 at pp.
256-257)
DOE did not analyze delamping in the preliminary analysis.
Available information indicates that delamping is not a common retrofit
for T8 fluorescent systems. DOE received feedback during manufacturer
interviews that delamping was previously very common with T12 systems
as these systems were typically designed such that spaces were overlit.
However, delamping is not common with T8 systems because lumen output
levels have already been reduced to comply with newer recommended
lighting levels and building codes. Therefore, DOE maintained its
assumption and did not considering delamping in the NOPR analysis.
DOE also received comments regarding rare earth oxide prices and
their impact on lamp prices and costs to the consumer. NEMA stated that
to make products conforming to the 2009 Lamps Rule, the most
efficacious rare earth phosphors are used. This leaves only the amount
of rare earth phosphors in each lamp as a design option for achieving
higher efficacy. Additionally, NEMA noted that while the phosphor
weight is increased linearly, the correlating efficacy gain diminishes.
NEMA pointed to the estimates for 4-foot T8 lamps, the most common GSFL
analyzed in this rulemaking. The estimates show that to achieve the
proposed 1.1 percent increase in efficacy from 89 lm/W (2009 Lamps
Rule) to 90 lm/W (CSL 1), nearly 10 percent more of the associated rare
earth oxide supply would be consumed. Further, to reach the CSL 2 level
of 93 lm/W, more than 40 percent additional rare earth phosphors will
be needed for GSFLs. NEMA anticipated that the increased demand for
this critical material will impact rare earth oxide prices and increase
the costs of GSFLs to U.S. consumers. (NEMA, No. 36 at p. 14)
In the preliminary analysis, DOE conducted a sensitivity analysis
in the LCC using low and high rare earth oxide
[[Page 24127]]
prices developed based on historical oxide price data to assess the
impact on the cost to consumer purchasing a GSFL. Because the rare
earth oxide prices have stabilized since hitting a peak in 2011, DOE
conducted a sensitivity analysis using only a forecasted high rare
earth oxide price in the NOPR analysis. See section VI.I and appendix
11B for further information on the methodology used to develop rare
earth oxide prices. DOE also utilized information provided by NEMA on
how the amount of phosphor varies with efficacy to develop rare earth
oxide costs attributable to different ELs. The results of this
sensitivity are presented in appendix 8B of the NOPR TSD. Further, DOE
also assessed the maximum possible increase in rare earth oxide prices
that would maintain positive LCC savings for consumers at each EL. See
appendix 7B of the NOPR TSD for results of this analysis.
15. Incandescent Reflector Lamp Life-Cycle Cost Results in the
Preliminary Analysis
A member of Congress commented that the July 2012 standards raised
consumer prices on IRLs from approximately $4.50 to $8. The member
anticipated that additional regulations would likely further increase
the price to $10-12, while the return on investment based on energy
savings would be 8 to 10 years. In this economic climate, the member
believed imposing additional regulations on IRL manufacturers would be
bad public policy. (Barr, No. 25 at p. 2)
The weighted average lamp prices that DOE calculated for IRLs in
this NOPR analysis are similar to the prices the member of Congress
provided. (See chapter 7 of the NOPR TSD for further information.) In
the LCC analysis, DOE calculates the payback period, which is the
amount of time it takes the consumer to recover the assumed higher
purchase cost of a more-efficacious product through lower operating
costs (i.e., energy savings). DOE considers the calculated payback
periods, as well as impacts on manufacturers when determining if a TSL
is economically justified. Please see section VII.C of this NOPR for
more details on the selection of the proposed TSL.
H. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended standards on
consumers, DOE evaluates the impact on identifiable sub-groups of
consumers (e.g., low-income households) that a national standard may
disproportionately affect. In the preliminary analysis, DOE stated it
was considering the following subgroups for analysis: Low-income
consumers, institutions of religious worship, and institutions serving
low-income consumers.
EEI generally agreed with the consumer subgroups considered, but
noted that how the current RECS data is structured would affect the
analysis. EEI specifically questioned whether RECS broke out energy
data specific to the poverty level. (EEI, Public Meeting Transcript,
No. 30 at pp. 352-353) DOE notes that RECS data specifies whether
consumers are at or below 100 percent of the poverty line. DOE believes
this data is appropriate to conduct an LCC analysis on the low-income
consumer subgroup.
In the NOPR analysis, DOE evaluated low-income consumers and
institutions that serve low-income populations (e.g., small nonprofits)
as subgroups. However, DOE did not evaluate institutions of religious
worship as a subgroup. In the 2009 Lamps Rule, DOE found that
institutions of religious worship operate for fewer hours per year than
any other building type in the commercial sector according to U.S. LMC:
Volume I \71\ data. DOE's review of the 2010 LMC data indicated that
the operating hours of institutions of religious worship are comparable
to other commercial building operating hours. Therefore, because they
do not have inputs to the LCC that would be different from the main LCC
analysis, DOE did not analyze them as subgroups. The NOPR TSD chapter 9
presents the results of the consumer subgroup analysis.
---------------------------------------------------------------------------
\71\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy. Energy Conservation Program for Consumer Products:
Final Report: U.S. Lighting Market Characterization, Volume I:
National Lighting Inventory and Energy Consumption Estimate. 2002.
Washington, DC <http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/lmc_vol1_final.pdf>.
---------------------------------------------------------------------------
I. Shipments Analysis
DOE uses projections of product shipments to calculate the national
impacts of standards on energy use, NPV, and future manufacturer cash
flows. DOE develops shipment projections based on historical data and
an analysis of key market drivers for each product. Historical
shipments data are used to build up an equipment stock and also to
calibrate the shipments model. The details of the shipments model are
described in chapter 11 of the NOPR TSD.
The shipments model projects shipments of GSFLs and IRLs over a
thirty-year analysis period for the base case (no standards) and for
all standards cases. DOE invites comment on this choice of analysis
period. Separate shipments projections are calculated for the
residential sector and for the commercial and industrial sectors. The
shipments model used to estimate GSFL and IRL lamp shipments for this
rulemaking has four main interacting elements: (1) A lamp demand module
that estimates the demand for GSFL and IRL lighting for each year of
the analysis period; (2) a price-learning module, which projects future
prices based on historic price trends; (3) substitution matrices, which
specify the product choices available to consumers (lamps as well as
lamp-and-ballast combinations for fluorescent lamps) depending on
whether they are renovating lighting systems, installing lighting
systems in new construction, or simply replacing lamps; and (4) a
market-share module that assigns shipments to product classes,
ballasts, and lamp options, based on consumer sensitivities to first
costs (prices) and operation and maintenance costs.
The lamp demand module first estimates the lumen demand for GSFL
and IRL lighting. The lumen demand calculation assumes that sector-
specific lighting capacity (maximum lumen output of installed lamps)
remains fixed per square foot of floor space over the analysis period.
Floor space changes over the analysis period according to the EIA's AEO
2013 projections of residential and commercial floor space; industrial
floor space is assumed to grow at the same rate as commercial floor
space. A lamp turnover calculation estimates shipments of lamps in each
year given the initial stock, the expected lifetimes of the lamps (and
ballasts for GSFLs), and sector-specific assumptions on operating
hours. The turnover model attempts to meet the lumen demand as closely
as possible, subject to the constraint that the areal density of
lighting fixtures is fixed for existing buildings that are not
renovated.
The lamp demand module accounts for the penetration of LED lighting
into the GSFL and IRL markets. The reference assumption for LED market
penetration is based on projections developed for DOE's Solid-State
Lighting (SSL) Program.\72\ The SSL Program projections extend only to
2030; DOE extrapolated to the end of the shipments forecast period. In
the preliminary analysis, DOE assumed an upper limit on market
penetration of 80
[[Page 24128]]
percent for IRLs, 70 percent for commercial GSFLs, and 60 percent for
residential GSFLs.
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\72\ Navigant Consulting, Inc. Energy Savings Potential of
Solid-State Lighting in General Illumination Applications. U.S. DOE
Solid State Lighting Program, January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_energy-savings-report_jan-2012.pdf.
---------------------------------------------------------------------------
Philips questioned why DOE did not expect LEDs to take over the
entire market. (Philips, Public Meeting Transcript, No. 30 at p. 270)
Given that LED technology has been progressing faster than expected,
DOE has revised its analysis and is now fitting the technology adoption
curve, allowing an entire market takeover by LEDs. Given the best fit
to the SSL forecast, DOE estimates that LEDs will achieve close to 100
percent penetration in both the GSFL and IRL markets by 2046.
The shipments model accounts for the use of lighting controls,
including dimming and on-off controls, because controls affect ballast
and lamp requirements and therefore lifetimes and shipments. The
reference assumption for lighting system controls for the commercial
sector is that state building energy code requirements for lighting
controls remain constant at current levels, as does the ratio of
voluntary to code-driven demand. Because code provisions are
implemented only in new construction and building renovations that meet
certain threshold requirements, code-driven implementation of lighting
controls grows in slowly over time.
GE noted that, in the future, an increasing number of fluorescent
systems will be controlled and dimmed in the commercial sector. GE
pointed to an increase of controls requirements in commercial building
codes and suggested that the initial five percent dimming population
assumed in the analysis increase over the analysis period. (GE, Public
Meeting Transcript, No. 30 at p. 217) EEI stated that, given the amount
of dimmers in office spaces, they expected the percentage of lamps in
the commercial sector that are on controls to be higher. (EEI, Public
Meeting Transcript, No. 30 at pp. 216-217) EEI noted that the next
edition of ASHRAE 90.1-2013, contains more control systems requirements
for more lighting fixtures. (EEI, Public Meeting Transcript, No. 30 at
p. 218)
DOE is aware that current building codes will lead to an increase
in the fraction of lamps coupled to lighting control systems.
Accordingly, DOE included a projection of growth in the fraction of
commercial floor space subject to such building codes. The result is
that the fraction of floor space utilizing various types of controls
grows from 30 percent today to a projected value of 80 percent in 2046.
The CA IOUs stated that dimming ballasts will become more common
with time. Specifically, the CA IOUs noted that California's Title 24
will require all new commercial buildings, and most lighting
renovations in existing commercial buildings, to install dimming
ballasts beginning January 2014. (CA IOUs, No. 32 at pp. 13-14) Lutron
asked if DOE took California's Title 24 into account. (Lutron, Public
Meeting Transcript, No. 30 at p. 218) The CA IOUs noted that Title 24
would not have been included in the 2010 LMC because the provision was
passed after the 2010 LMC was published. (CA IOUs, Public Meeting
Transcript, No. 30 at pp. 218-219)
DOE is aware that current building energy codes will lead to an
increase in the fraction of lamps coupled to lighting control systems
and dimming ballasts. Accordingly, in the shipments analysis and NIA,
DOE included a projection of growth in the fraction of commercial floor
space subject to such state codes, including California's Title 24
requirements, as renovations and new construction trigger compliance
requirements. As mentioned previously, the result is that the fraction
of floor space utilizing controls grows from 30 percent today to a
projected value of 80 percent in 2046. DOE assumed that 26 percent of
control systems for GSFL applications include dimming ballasts, based
on data in the 2010 LMC.\73\ Based on assumptions of the fraction of
each control type that relies on a dimming ballast, DOE projects that
the market share of dimming ballasts grows from an estimated 8 percent
at present to an estimated 20 percent in 2046. DOE seeks input on the
current fraction of GSFL ballast shipments that are dimming ballasts
and the likely rate of growth of dimming ballasts in the future. The
details of the analysis on controls and dimming are presented in
chapter 11 and appendix 11A of the NOPR TSD.
---------------------------------------------------------------------------
\73\ U.S. Department of Energy--Energy Efficiency & Renewable
Energy Building Technologies Program. 2010 U.S. Lighting Market
Characterization. January 2012. Washington, DC. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
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The price-learning module estimates lamp and ballast prices in each
year of the analysis period using a standard price-learning model.\74\
The model is calibrated using three decades of historic data on the
volume and value of fluorescent and PAR lamp shipments in the U.S.
market, from which cumulative shipments and average prices are derived.
Prices and cumulative shipments are fit to an experience curve. They
are then augmented in each subsequent year of the analysis based on the
shipments determined for the prior year by the module that assigns
shipments to product classes and ELs. The current year's shipments, in
turn, affect the subsequent year's prices. As shown in chapter 11 of
the NOPR TSD, because fluorescent and PAR lamps have been on the market
for decades, cumulative shipments are changing slowly, therefore
experience curve effects are relatively small--an effect that is
further constrained by the expected incursion of solid-state lighting
into the GSFL and IRL markets.
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\74\ For discussion of approaches for incorporating learning in
regulatory analysis, see Taylor, Margaret, and Sydny K. Fujita.
Accounting for Technological Change in Regulatory Impact Analyses:
The Learning Curve Technique. Berkeley: Lawrence Berkeley National
Laboratory, 2013. LBNL-6195E.
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The market-share module apportions the lamp and ballast shipments
in each year among the different product classes, ballast types, and
lamp options based on consumer sensitivities to first costs and
operation and maintenance costs. To determine the prices used as inputs
to the market-share module, DOE uses the ballast prices, weighted
average lamp prices, and installation costs developed in the
engineering and LCC analyses. The operation and maintenance costs are
based on the power required to operate a particular lamp-and-ballast
system, the price of electricity, and the annualized cost of lamp
replacements over the lifetime of that system. To enable a fair
comparison between systems with different light output, the module
considers the prices and operating and maintenance costs computed per
kilolumen of light output. For consumers replacing lamps on existing
ballasts, only the lamp-related prices and energy costs are considered
by the market share module. For consumers replacing an entire lamp-and-
ballast system, the full price of the system, as well as the energy and
annualized relamping costs, are considered. In this case, the
comparison between different ballast types and product classes is made
by considering a representative lamp-and-ballast combination.
The ballast types and lamp options considered in the shipments
model were determined in the engineering analysis. Whereas the earlier
analyses considered only lamp-and-ballast combinations that save energy
relative to the baseline system, the shipments analysis allows
consumers to choose among all different lamp-and-ballast systems. These
lamp-and-ballast combinations include full wattage and reduced wattage
lamps coupled to ballasts with high, normal, or low ballast factors,
and dimming ballasts. Programmed start and instant start ballasts are
also considered separately,
[[Page 24129]]
where appropriate. DOE limits or excludes lamp-and-ballast combinations
that DOE's research indicates would not provide acceptable performance
or would only do so in limited circumstances. The remaining
combinations allow for a variety of different energy-saving and non-
energy-saving options relative to the baseline. Details of the
selection of allowable lamp-and-ballast combinations are given in
chapter 11 of the NOPR TSD.
The market-share module allows for the possibility that consumers
will switch among the different product classes, ballast types, and
lamp options over time. Substitution matrices were developed to specify
the product choices available to consumers (lamps as well as lamp-and-
ballast combinations), depending on whether they are renovating
lighting systems, installing lighting systems in new construction, or
simply replacing lamps, and depending on the particular lighting
application. In this way, the module assigns market shares to the
different product classes, ballast types, and ELs based on historical
observations of consumer sensitivity to price and to operating and
maintenance costs.
The market-share module incorporates a limit on the diffusion of
new technology into the market using the widely accepted Bass adoption
model,\75\ the parameters of which are based on historic penetration
rates of new lighting technologies into the market. It also accounts
for other observed deviations from purely price- and cost-driven
behavior using an acceptance factor, which sets an upper limit on the
market share of certain product classes and lamp options that DOE
research indicates are acceptable only to a subset of the market. The
available options depend on the case under consideration; in each of
the standards cases corresponding to the different TSLs, only those
lamp options at or above the particular standard level in each product
class are considered to be available.
---------------------------------------------------------------------------
\75\ Bass, F.M. A New Product Growth Model for Consumer
Durables. Management. 1969. 15(5): pp. 215-227.
---------------------------------------------------------------------------
Because DOE executes the market-share module for the base case and
each of the standards cases independently, the shipments analysis
allows for the possibility that setting a standard on one product class
could shift market share toward a different product class. The costs
and benefits accruing to consumers from such market share shifts are
fully accounted for in the NIA.
When the shipments model selects lamps for replacement, renovation,
or new construction, it accepts only lamps or lamp-and-ballast
combinations that retain lumen capacity within acceptable bounds. DOE
received a number of comments on what consumers would find acceptable
in terms of changes in light levels.
NEMA stated that while, in the past, it was common practice to
reduce light levels by 10 percent or more when retrofitting from a T12
to a T8 lighting system, this was because the older lighting systems
were typically designed to higher light levels. NEMA commented that,
over the years, light level requirements specified by IESNA have been
reduced, so future 4-foot linear fluorescent systems will already be
operating at the appropriate lower light levels, and further light
level reductions of 6 percent to 14 percent cannot be justified against
the T8 systems operating in 2018. NEMA stated that DOE should seek to
match the existing light levels within a plus or minus 5 percent range.
(NEMA, No. 36 at p. 8)
The CA IOUs commented that scenarios in which lighting designers
would specify an increase in light output instead of a reduction in
system wattage will not be common in the commercial sector because (1)
commercial occupants are often very sensitive to changes in workplace
lighting and react negatively to light increases; and (2) commercial
building operators are very sensitive to operating costs. The CA IOUs
further stated that commercial building operators will prefer a
retrofit option that will result in energy cost savings (without
significantly reducing the light levels) over another option that
increases light and doesn't save energy (unless the space was known to
be underlit). The CA IOUs stated that, where DOE has a standards-case
modeling choice between a lighting retrofit that would result in an
increase of light levels of between 0 percent and 10 percent with no
energy cost savings, and another that would result in a decrease of
light levels of between 0 percent and 10 percent with energy cost
savings, DOE should model the energy-saving option as the most likely
scenario for consumers. (CA IOUs, No. 32 at p. 14) NEEA and NPCC
commented on the modeled lamp or lighting system replacement options in
which light output levels are increased 10 percent or more instead of
maintaining light levels with an appropriate reduction in system power
use. They contended that it is highly unlikely that a lighting retrofit
or lamp replacement project would be undertaken that would result in a
light output increase without using the opportunity to save energy
(which often pays for or helps pay for the retrofit). (NEEA and NPCC,
No. 34 at pp. 2, 4)
As discussed previously, based on manufacturer feedback, DOE
determined that consumers would not notice a change in light output
that is up to 10 percent, and that some consumers will choose to reduce
light levels beyond 10 percent to conserve energy. Accordingly, in the
shipments analysis, DOE assumes that consumers choose between lighting
systems within 10 percent of current light output by considering the
trade-off between first cost and operating costs, and not the relative
light output. In this approach, systems that save energy in a cost-
effective way will tend to be selected over systems that increase light
output without saving energy. DOE further assumes that the fraction of
the market that will accept larger reductions in lumen output is fixed
throughout the analysis period. The size of this market segment was
estimated from the current market share of reduced wattage lamps that
reduce light levels by more than 10 percent compared to the baseline
lamp. The model does now allow cumulative reductions in light levels.
The model retains national average light levels within 10 percent of
the average level at the beginning of the analysis period. No potential
standards considered in this analysis lead to average light levels
outside of this range.
The CA IOUs commented that there are a number of tools available to
lighting designers to reduce system wattage while maintaining
acceptable light levels. These options include installing lower wattage
lamps, reducing ballast factors, delamping, or installing dimming
ballasts. (CA IOUs, No. 32 at pp. 13-14) NEEA and NPCC commented that,
if a 32 W T8 lamp replacement is undertaken, there are options
available for maintaining acceptable light output while reducing energy
use, such as 30 W and 28 W T8s, ballasts with a lower ballast factor,
and dimming ballasts. (NEEA and NPCC, No. 34 at pp. 2, 4) NEMA
commented that the energy consumption of GSFL systems is highly
dependent on ballast selection and pairing, and asserted that NES of
lighting systems will not be affected significantly by this proposed
rulemaking on GSFL efficacy due to the overwhelming influence of
ballast selection on final performance. (NEMA, No. 36 at p. 1)
DOE is aware of the substantial impact of the ballast and lamp
choice on the energy consumption of a lamp-and-ballast system. As
discussed earlier in this section, the shipments analysis explicitly
models the possibility that
[[Page 24130]]
consumers will choose to reduce their ballast factor during a
renovation or retrofit or switch to reduced wattage lamps when
relamping an existing system. In addition, this analysis models the
growth of dimming ballasts in the market and allows a variety of lamps
to be coupled to dimming ballasts to achieve a fixed light output.
Thus, when high-efficacy lamps are coupled to dimming ballasts, the
overall energy savings are greater than those that are achieved when
lower-efficacy lamps are coupled to dimming ballasts. DOE assigns
market share to these lamp-and-ballast pairings using a model based on
historical consumer sensitivity to price and operating costs. When a
particular pairing saves energy in a cost-effective manner compared to
other pairings, its market share is increased compared to less cost-
effective options. Given that the lamp options considered in this
rulemaking represent a fairly narrow range in lumen output within each
product class, DOE does not consider delamping to be a likely means of
saving energy for consumers who are only replacing failed lamps (see
section VI.D.2.e for more information on delamping). The shipments
model, however, allows for the possibility that consumers will alter
the number of lamps per square foot during renovations to maintain
light levels.
NEMA commented that reduced wattage lamps have limited utility as a
substitute for full wattage lamps. NEMA noted that, while standard
fluorescent lamp technology dims reliably, more efficient krypton-
filled fluorescent lamps do not dim reliably in many applications.
(NEMA, No. 36 at p.6) The CA IOUs stated that California's Title 24
requirement for controls in new buildings will result in high efficacy,
full wattage T8s capable of dimming to custom light levels, ensuring
higher efficacy lamps yield greater energy savings. (CA IOUs, No. 32 at
p. 14) The Northeast Energy Efficiency Partnership (NEEP) also noted
that high efficacy lamps do not impede control capabilities. NEEP
commented that, while manufacturers had said that adding control
functionality to a fluorescent fixture was the next frontier of
efficiency for GSFLs, regional program administrators have not reported
concerns that high efficacy GSFLs sacrifice dimming capabilities.
(NEEP, No. 33 at p. 2)
DOE's research indicates that krypton gas is generally used to
reduce the wattage of lamps and that full wattage lamps can generally
be dimmed reliably. DOE notes that full wattage lamp options are
available for all product classes at all efficacy levelss considered in
this analysis. Also, as discussed previously, DOE found that dimming
ballasts for 4-foot MBP lamps are commonly marketed as compatible with
reduced wattage lamps, which are presumably krypton filled.
Accordingly, in the shipments analysis and the NIA, DOE allows all full
wattage lamp options to be coupled to dimming ballasts. DOE also
allowed reduced wattage options in the 4-foot MBP category to be
coupled to dimming ballasts, but, because the range of applications for
this combination is restricted, DOE limits its market share in the
analysis. DOE welcomes input on the assumption that a limited fraction
of reduced-wattage 4-foot MBP lamps may be coupled to dimming ballasts.
NEMA commented on the issue of lamp replacement upon ballast
failure. NEMA contends that when a residential ballast fails,
residential GSFL consumers tend to first try to replace the lamp, and
when that fails they replace the entire fixture, discarding the lamps
from the old fixture. The effect is to reduce the lamp's usage life
below its potential and therefore to increase shipments. (NEMA, No. 36
at p. 16) The shipments model assumes that when a residential ballast
fails, all associated lamps are assumed to be replaced.
Rare earth oxides are used in GSFL phosphors to increase their
efficiency. The shipments model considers the potential impact of
changes in rare earth oxide prices on fluorescent lamp prices and,
thereby, on GSFL shipments. Large increases in rare earth oxide prices
in 2010 and 2011 raised manufacturer concerns that future price
increases could have adverse impacts on the market. DOE developed
shipments scenarios in its preliminary analysis to reflect
uncertainties in the prices of rare earth oxides.
In the preliminary analysis, DOE assumed that the rare earth
phosphor content was the same at all considered efficacy levels for
each lamp type. NEMA stated that there is a relationship between rare
earth phosphor content and efficiency. Specifically, NEMA indicated
that to increase the efficacy of 4-foot MBP GSFLs from 89 to 90 lm/W
would require 10 percent more rare earth phosphor and to reach 93 lm/W
would require a 40 percent increase in rare earth phosphor. (NEMA, No.
36 at p. 14) Based on an examination of fluorescent lamp patents, DOE
agrees with NEMA's comment, and has adjusted its analysis accordingly,
as described in appendix 11B of the NOPR TSD.
In the preliminary analysis, DOE's reference case assumed that rare
earth phosphor prices would remain constant at the October 2012 level,
but DOE acknowledged the uncertainty about prices and included a
scenario with much higher prices. NEEP commented that DOE appropriately
addressed the variability of rare earth phosphor prices in the
preliminary analysis. (NEEP, No. 33 at pp. 2-3) NEMA commented that
rare earth phosphors are likely to remain critical (i.e., volatile),
that prices are more likely to go up than down, and suggested that DOE
consult Dr. Alex King of the Critical Materials Institute of the Ames
Laboratory on the subject. (NEMA, No. 36 at p. 14)
DOE examined the rare earth market and believes that the very large
reduction in rare earth prices seen since the 2011 peak may represent
some stabilization of the market, but it still considers future rare
earth prices significantly uncertain.\76\ DOE therefore considered two
price scenarios in its shipments modeling for GSFLs, as described in
appendix 11B of the NOPR TSD. The reference scenario assumes that rare
earth prices remain fixed at their September 2013 level. The high rare
earth price scenario assumes an average rare earth price 3.4 times the
reference level, representing a value that is half way between the low
pre-2010 baseline price and the 2011 peak price. This scenario
represents the average price of regular price fluctuations between the
peak and baseline amounts. The impact of the latter scenario on the
results is discussed in section 0. DOE invites comment on its
assumptions about future prices of rare earth elements.
---------------------------------------------------------------------------
\76\ DOE conferred with Dr. King, who indicated that a good
comparison can be made between rare earths and cobalt, which are
comparable (within about a factor of ten) in abundance in the
earth's crust. In 1978, world cobalt supplies were dominated by a
single source (Zaire). In 2010, rare earth supplies were dominated
by a single source (China). In 1978, the use of cobalt was growing
both in existing and emerging technologies. The same is true for
rare earths today. Following the 1978 crisis, new cobalt mines
opened, and substitute materials were developed. Markets are
pursuing the same paths for the rare earths today. DOE examined
inflation-adjusted cobalt prices from 1970 through 2012 and found
that cobalt prices did continue to remain volatile, although later
price fluctuations were less than half of the initial price peak
seen in 1978.
---------------------------------------------------------------------------
Stakeholders also commented on the possibility of future scarcity
in the supply of xenon gas, which could affect future prices of IRLs.
NEMA commented that xenon is becoming increasingly scarce and that its
loss would result in a 5 to 7 percent reduction in IRL efficacy, making
it impossible to meet CSL 1 of the preliminary analysis (20 lm/W). NEMA
advised DOE to investigate xenon availability trends and future prices.
(NEMA, No. 36 at p. 3)
[[Page 24131]]
The CA IOUs commented that xenon is already used as the primary gas
fill in most IRLs and that future efficacy standards should not be
affected by potential constraints on xenon supply or xenon price
fluctuations. (CA IOUs, No. 32 at p. 9) NEEA pointed out that there is
no current shortage of xenon gas fill and that a new standard would not
require any significant amount of increased xenon supply. Therefore,
the supply and price of xenon should not be an issue for the
rulemaking. (NEEA, No. 34 at p. 2)
To assess the need for further investigation, DOE conducted a
sensitivity analysis on the potential impact on the rulemaking of a
ten-fold increase in xenon prices. The impact of the latter scenario on
the results is discussed in section 0.. DOE welcomes input on its
assumptions regarding the future price of xenon gas.
J. National Impact Analysis--National Energy Savings and Net Present
Value Analysis
The NIA assesses the NES and the national NPV of total consumer
costs and savings expected to result from amended standards for GSFLs
and IRLs at specific efficacy levels. Analyzing impacts of potential
energy conservation standards for GSFLs and IRLs requires comparing
projections of U.S. energy consumption with amended energy conservation
standards against projections of energy consumption without the
standards (the base case).
Because the shipments model allows for substitutions across product
classes, to understand the impact of setting a standard at any given
level for any given product class, the impact on all other product
classes must be considered. Therefore, in addition to conducting the
analysis for the covered products as a whole, DOE evaluated the NPV and
NES by product class to determine the impact of consumer switching
between product classes. The NIA was developed in a Microsoft Excel
spreadsheet,\77\ allowing access to a broad range of scenario
assumptions for conducting sensitivity analyses on specific input
values.
---------------------------------------------------------------------------
\77\ Available at www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.
Table VI.14--Inputs for the National Impact Analysis
------------------------------------------------------------------------
Input Description
------------------------------------------------------------------------
Shipments......................... Annual shipments from shipments
model.
Compliance date of standard....... January 1, 2017.
Base case efficiencies............ Estimated by market-share module of
shipments model.
Standards case efficiencies....... Estimated by market-share module of
shipments model.
Annual energy consumption per unit Calculated for each efficacy level
and product class based on inputs
from the energy use analysis.
Total installed cost per unit..... Lamp prices by efficacy level,
ballast prices by ballast type, and
lamp and ballast installation
costs. The weighted average prices
and installation costs developed in
the engineering analysis and LCC
analysis were used.
Electricity expense per unit...... Annual energy use for each product
class is multiplied by the
corresponding average energy price.
Escalation of electricity prices.. AEO 2013 forecasts (to 2040) and
extrapolation beyond 2040.
Electricity site-to-primary energy A time series conversion factor;
conversion. includes electric generation,
transmission, and distribution
losses.
Discount rates.................... 3% and 7% real.
Present year...................... 2013.
------------------------------------------------------------------------
1. National Energy Savings
The inputs for determining the NES for each product class are: (1)
Lamp shipments; (2) annual energy consumption per unit; (3) installed
stocks of lamps (coupled to each analyzed ballast type for GSFLs) in
each year; and (4) site-to-primary energy and FFC conversion factors.
The lamp stocks were calculated by the shipments model for each year of
the analysis period from the prior year's stock, minus retirements,
plus new shipments, accounting for lamp and ballast lifetimes. DOE
calculated the national electricity consumption in each year by
multiplying the number of units of each product class and EL in the
stock by each unit's power consumption and operating hours. The power
consumption is determined by the lamp wattage and, for each GSFL, by
the ballast type to which each lamp is coupled. The operating hours are
given by taking a weighted average of the distributions developed in
the LCC analysis. The electricity savings are estimated from the
difference in national electricity consumption by GSFL between the base
case (without new standards) and each of the standards cases for lamps
shipped during the 2017-2046 period.
NEMA commented that DOE appears to be using a new (arbitrary) 70-
year period in its analysis and requested explanation and justification
for examining such a long stretch of time. (NEMA, No. 36 at pp. 2-3) In
the NIA, DOE accounts for the lifetime impacts of the products shipped
during a 30-year period. In the case of GSFLs and IRLs, most of the
products are retired from the stock within five years. The lifetime
distribution used by DOE shows a small number of lamps shipped for use
in homes at the end of the 30-year shipments analysis period survive
for much longer. While the energy use of these lamps is insignificant
to the overall results, the calculation period for the NIA is extended
to account for them.
DOE accounted for the impact of lighting system controls on
lighting energy use as well as on lamp shipments, as discussed in the
previous section. NEEA noted that as many as a third of commercial
building control systems do not achieve their design performance and
thus yield a smaller energy savings than expected. (NEEA, No. 30 at pp.
317-318) DOE understands that many lighting control systems may not
achieve the savings for which they were designed. Accordingly, the
estimated average energy reduction from controls is based on a meta-
analysis of studies on the performance of actual lighting controls
systems in the field.\78\
---------------------------------------------------------------------------
\78\ Williams, A., B. Atkinson, K. Garbesi, E. Page, and F.
Rubinstein (2012). Lighting controls in commercial buildings. Leukos
8(3): 161-180. www.ies.org/leukos/samples/1_Jan12.pdf.
---------------------------------------------------------------------------
NEMA pointed out that light output and input power do not scale
linearly for dimming GSFL systems due to the increasing importance of
cathode heat
[[Page 24132]]
power at reduced light levels. (NEMA, No. 36 at p. 14) DOE recognizes
the need for cathode heating in dimming ballast systems and has
included this effect in its energy consumption calculations. In
particular, the shipments analysis and NIA use power consumption
assumptions identical to those used in the engineering analysis, which
account for cathode heating in dimming systems.
NEMA expressed concern that the highest considered efficacy levels
would lead to the loss of reliable dimming and would have a negative
impact on NES. NEMA asserted that, in future years, most of the energy
savings from fluorescent lighting will be achieved through the
increased use of lighting controls, not through increasing the efficacy
of lamps, and that an aggressive standard on lamp efficacy could make
these savings unachievable. (NEMA, No. 36 at p.6) NEMA further
suggested that DOE perform and report an analysis of the impacts of the
loss of dimming savings for efficacy levels that they claimed will
drive out dimmable lamps in favor of low wattage versions. NEMA
asserted that this would show a negative impact on the market and
payback. They contended that increased efficiency and dimmability are
inversely proportional. (NEMA 36 at p.17)
As discussed in the previous section, DOE modeled the growth of
dimming ballasts in the shipments analysis and excluded or limited, as
appropriate, the coupling of reduced wattage lamps to these ballasts.
Therefore, the issues discussed in the previous comment are accounted
for, and the NES and NPV results include any potential loss of dimming
functionality.
DOE accounts for the direct rebound effect in its NES analyses.
Direct rebound reflects the idea that, as appliances become more
efficient, consumers use more of their service because their operating
cost is reduced. In the case of lighting, the rebound could be
manifested in increased hours of use or in increased lighting density
(fixtures per square foot). Based on information evaluated for the
preliminary analysis, DOE assumed no rebound for the residential or
commercial lighting in its reference scenario for the NOPR analysis.
DOE also conducted a sensitivity analysis on the rebound rate, which is
presented in chapter 12 of the NOPR TSD. DOE welcomes comment on its
assumptions and methodology for estimating the rebound effect for the
products covered in this NOPR, including potential magnitudes of
rebound effects.
DOE converted the site electricity consumption and savings to
primary energy (power sector energy consumption) using annual
conversion factors derived from the AEO 2013 version of NEMS.
Cumulative energy savings are the sum of the NES for each year in which
product shipped during 2017 through 2046 continue to operate.
In 2011, in response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Science,
DOE announced its intention to use FFC measures of energy use and GHG
and other emissions in the NIA and emissions analysis included in
future energy conservation standards rulemakings. 76 FR 51281 (August
18, 2011). While DOE stated in that notice that it intended to use the
Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation
(GREET) model to conduct the analysis, it also said it would review
alternative methods, including the use of EIA's NEMS. After evaluating
both models and the approaches discussed in the August 18, 2011 notice,
DOE published a statement of amended policy in the Federal Register in
which DOE explained its determination that NEMS is a more appropriate
tool for this specific use. 77 FR 49701 (August 17, 2012). Therefore,
DOE is using a NEMS-based approach to conduct FFC analyses. The
approach used for today's NOPR is described in appendix 12C of the NOPR
TSD.
2. Net Present Value of Consumer Benefit
The inputs for determining the NPV of the total costs and benefits
experienced by consumers of the considered product are: (1) Total
annual installed cost; (2) total annual savings in operating costs; and
(3) a discount factor to calculate the present value of costs and
savings. DOE calculated net savings each year as the difference between
the base case and each standards case in terms of total savings in
operating costs versus total increases in installed costs. DOE
calculated savings over the lifetime of products shipped during the
period starting January 1, 2017 and ending December 31, 2046. DOE
calculated NPV as the difference between the present value of operating
cost savings and the present value of total installed costs.
a. Total Annual Installed Cost
The total installed cost includes both the product price and the
installation cost. For each product class, DOE utilized weighted
average prices for each of the lamp and ballast options, as well as
installation costs, as developed in the engineering and LCC analyses.
DOE calculated the total installed cost for each lamp-and-ballast
option and determined annual total installed costs based on the annual
shipments of lamps and ballasts determined in the shipments model. As
noted in section VI.I, DOE assumed that GSFL and IRL prices decline
slowly over the analysis period according to a learning rate developed
from historical data.
As discussed in section VI.I, DOE considered two price scenarios in
its modeling for GSFLs. The reference scenario assumes that rare earth
prices remain fixed at their September 2013 level. The high rare earth
price scenario assumes that rare earth prices are 3.4 times higher than
the reference level, representing a value at the midpoint of the low
pre-2010 baseline price and the peak 2011 price. The impact of the
latter scenario on the NPV results is discussed in section 0.
For IRLs, DOE conducted a sensitivity analysis on the potential
impact on the rulemaking of a ten-fold increase in xenon prices. The
impact of the scenario on the results is discussed in section 0.
b. Total Annual Operating Cost Savings
The per-unit energy savings were derived as described in section
VI.I. To calculate future electricity prices, DOE applied the projected
trend in national average commercial and residential electricity prices
from the AEO 2013 Reference case, which extends to 2040, to the energy
prices derived in the LCC and payback period analysis. DOE used the
trend from 2030 to 2040 to extrapolate beyond 2040. In addition, DOE
analyzed scenarios that used the trends in the AEO 2013 Low Economic
Growth and High Economic Growth cases. These cases have energy price
trends that are, respectively, lower and higher in the long term
compared to the Reference case. These price trends, and the NPV results
from the associated cases, are described in chapter 12 of the NOPR TSD.
DOE estimated that annual maintenance costs do not vary with
efficiency within each product class, so they do not figure into the
annual operating cost savings for a given standards case. DOE utilized
the lamp disposal costs developed in the LCC analysis, along with the
shipments model forecast of the lamp retirements in each year, to
estimate the annual cost savings related to lamp disposal costs. In
this part of the analysis, DOE assumes that 30 percent of commercial
consumers are subject to disposal costs.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine
[[Page 24133]]
their present value. DOE estimates the NPV using both a 3 percent and a
7 percent real discount rate, in accordance with guidance provided by
the Office of Management and Budget (OMB) to federal agencies on the
development of regulatory analysis.\79\ The discount rates for the
determination of NPV are in contrast to the discount rates used in the
LCC analysis, which are designed to reflect a consumer's perspective.
The 7 percent real value is an estimate of the average before-tax rate
of return to private capital in the U.S. economy. The 3 percent real
value represents the ``social rate of time preference,'' which is the
rate at which society discounts future consumption flows to their
present value.
---------------------------------------------------------------------------
\79\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
K. Manufacturer Impact Analysis
1. Overview
DOE conducted separate MIAs for GSFLs and IRLs to estimate the
financial impact of amended energy conservation standards on
manufacturers of GSFLs and IRLs, respectively. The MIA has both
quantitative and qualitative aspects. The quantitative part of the MIA
relies on the GRIM, an industry cash-flow model customized for GSFLs
and IRLs covered in this rulemaking. The key GRIM inputs are data on
the industry cost structure, equipment costs, shipments, and
assumptions about markups and conversion costs. The key MIA output is
INPV. DOE used the GRIM to calculate cash flows using standard
accounting principles and to compare changes in INPV between a base
case and various TSLs (the standards case). The difference in INPV
between the base and standards cases represents the financial impact of
amended energy conservation standards on GSFL and IRL manufacturers.
Different sets of assumptions (scenarios) produce different INPV
results. The qualitative part of the MIA addresses factors such as
manufacturing capacity; characteristics of, and impacts on, any
particular sub-group of manufacturers; and impacts on competition.
DOE conducted the MIAs for this rulemaking in three phases. In the
first phase DOE prepared an industry characterization based on the
market and technology assessment, preliminary manufacturer interviews,
and publicly available information. In the second phase, DOE estimated
industry cash flows in the GRIMs using industry financial parameters
derived in the first phase and the shipment scenarios used in the NIAs.
In the third phase, DOE conducted interviews with a variety of GSFL and
IRL manufacturers that account for more than 90 percent of domestic
GSFL sales and more than 80 percent of domestic IRL sales covered by
this rulemaking. During these interviews, DOE discussed engineering,
manufacturing, procurement, and financial topics specific to each
company and obtained each manufacturer's view of the GSFL and IRL
industries as a whole. The interviews provided information that DOE
used to evaluate the impacts of amended standards on manufacturers'
cash flows, manufacturing capacities, and direct domestic manufacturing
employment levels. See section VII.B.2.b of this NOPR for the
discussion on the estimated changes in the number of domestic employees
involved in manufacturing GSFLs and IRLs covered by standards. See
section VI.K.4 of this NOPR for a description of the key issues
manufacturers raised during the interviews.
During the third phase, DOE also used the results of the industry
characterization analysis in the first phase and feedback from
manufacturer interviews to group manufacturers that exhibit similar
production and cost structure characteristics. DOE identified one
manufacturer sub-group for a separate impact analysis--small business
manufacturers--using the small business employee threshold of 1,000
total employees published by the Small Business Administration (SBA).
This threshold includes all employees in a business' parent company and
any other subsidiaries. Based on this classification, DOE identified 21
GSFL manufacturers that qualify as small businesses and 15 IRL
manufacturers that qualify as small businesses. The complete MIA is
presented in chapter 13 of the NOPR TSD, and the analysis required by
the Regulatory Flexibility Act, 5 U.S.C. 601, et seq., is presented in
section VIII.B of this NOPR and chapter 13 of the NOPR TSD.
2. GRIM Analysis and Key Inputs
DOE uses the GRIM to quantify the changes in cash flows over time
due to amended energy conservation standards. These changes in cash
flows result in either a higher or lower INPV for the standards case
compared to the base case (the case where a standard is not set). The
GRIM analysis uses a standard annual cash flow analysis that
incorporates manufacturer costs, markups, shipments, and industry
financial information as inputs. It then models changes in costs,
investments, and manufacturer margins that result from amended energy
conservation standards. The GRIM uses these inputs to calculate a
series of annual cash flows beginning with the base year of the
analysis, 2013, and continuing to 2046. DOE computes INPV by summing
the stream of annual discounted cash flows during the analysis period.
DOE used a real discount rate of 9.2 percent for both GSFL and IRL
manufacturers. The discount rate estimates were derived from industry
corporate annual reports to the Securities and Exchange Commission (SEC
10-Ks). During manufacturer interviews GSFL and IRL manufacturers were
asked to provide feedback on this discount rate. Most manufacturers
agreed that a discount rate of 9.2 was appropriate to use for both GSFL
and IRL manufacturers. Many inputs into the GRIM come from the
engineering analysis, the NIA, manufacturer interviews, and other
research conducted during the MIA. The major GRIM inputs are described
in detail in the sections below.
a. Capital and Product Conversion Costs
DOE expects amended energy conservation standards of GSFLs and IRLs
to cause manufacturers to incur conversion costs to bring their
production facilities and product designs into compliance with amended
standards. For the MIA, DOE classified these conversion costs into two
major groups: (1) Capital conversion costs and (2) product conversion
costs. Capital conversion costs are investments in property, plant, and
equipment necessary to adapt or change existing production facilities
such that new product designs can be fabricated and assembled. Product
conversion costs are investments in research, development, testing,
marketing, certification, and other non-capitalized costs necessary to
make product designs comply with amended standards.
Using feedback from manufacturer interviews, DOE conducted both
top-down and bottom-up analyses to calculate the capital and product
conversion costs for GSFL and IRL manufacturers. DOE then adjusted
these conversion costs if there were any discrepancies between the two
methods to arrive at a final capital and product conversion cost
estimate for each GSFL and IRL product class at each EL.
To conduct the top-down analysis, DOE asked manufacturers during
manufacturer interviews to estimate the total capital and product
conversion costs they would need to incur to be able to produce each
GSFL and IRL product class at specific ELs. DOE then summed these
values provided by manufacturers to arrive at total top-
[[Page 24134]]
down industry conversion costs for GSFLs and IRLs.
To conduct the bottom-up analysis, DOE used manufacturer input from
manufacturer interviews regarding the types and dollar amounts of
discrete capital and product expenditures that would be necessary to
convert specific production lines for GSFLs or IRLs to each EL. GSFL
manufacturers identified upgrading and recalibrating production
automation systems as the primary capital cost that would be necessary
to meet higher efficacy levels for GSFLs. IRL manufacturers identified
several potential capital costs that could be required to meet higher
efficacy levels for IRLs. These include purchasing new burner coating
machines, increasing the capacity of existing burner machines,
purchasing reflector coating machines, and purchasing coiling machines,
as well as other retooling costs. The two main types of product
conversion costs for GSFLs and IRLs that manufacturers shared with DOE
during manufacturer interviews were the engineering hours necessary to
redesign lamps to meet higher efficacy standards and the testing and
certification costs necessary to comply with higher efficacy standards.
Once DOE had compiled these capital and product conversion costs, DOE
then took average values (i.e., average number of hours or average
dollar amounts) based on the range of responses given by manufacturers
for each capital and product conversion cost at each ELs.
The bottom-up conversion costs estimates DOE created were
consistent with the manufacturer top-down estimates provided, so DOE
used these cost estimates as the final values for each GSFL and IRL
product class at each EL in the MIA.
See chapter 13 of the NOPR TSD for a complete description of DOE's
assumptions for the capital and product conversion costs.
b. Manufacturer Production Costs
Manufacturing more efficacious GSFLs or IRLs is typically more
expensive than manufacturing a baseline product due to the need for
more costly materials and components. One of the primary drivers behind
increased material costs is the need for enhanced reflectors and/or
burner coatings for IRLs or rare earth oxides (REOs) for GSFLs, as well
as the need for higher volumes of these materials. The higher
manufacturer production costs (MPCs) for these more efficacious
products can affect the revenue, gross margin, and lifetime of the
product, which will then affect total volume of future shipments, and
the cash flows of GSFL and IRL manufacturers. Typically, DOE develops
MPCs for the covered products and uses the prices as an input to the
LCC analysis and NIA. However, because GSFLs and IRLs are difficult to
reverse-engineer, DOE derived end-user prices for the lamps covered in
this rulemaking. DOE observed a range of end-user prices paid for GSFLs
and IRLs depending on the distribution channel through which the lamps
are purchased. DOE then developed three sets of discounts from the
manufacturer blue-book prices representing low (state procurement),
medium (electrical distributors and big box retailers), and high
(Internet retailers) lamp prices for both GSFLs and IRLs. For more
information about pricing, see section VI.E of this NOPR.
To calculate the MSP, the price at which manufacturers sell lamps
to their customer, DOE calculated the distribution chain markup for the
GSFL and IRL industries. DOE examined the SEC 10-Ks of publicly traded
big box retail stores to determine the average retail markup for the
medium end-user price distribution chain. DOE found the typical retail
markup for big box stores was 1.52. DOE divided the medium end-user
price for all GSFLs and IRLs by this value to arrive at MSPs for all
GSFLs and IRLs. DOE invites comment on its methodology of using a 1.52
distribution chain markup in combination with the medium end-user price
to estimate the MSP of all GSFLs and IRLs.
DOE also examined the SEC 10-Ks of all publicly traded GSFL and IRL
manufacturers to estimate the average GSFL and IRL manufacturer markup.
The manufacturer markup represents the markup lamp manufacturers apply
to their MPCs to arrive at the MSPs. This is different from the
distribution chain markup, which is the markup retail stores apply to
the MSP to arrive at the end user price. Based on SEC 10-Ks, DOE found
the typical manufacturer markup for GSFL and IRL manufacturers on a
corporate level was 1.58. During manufacturer interviews, DOE asked
manufacturers if 1.58 was an appropriate markup to use for GSFLs and
IRLs. Based on manufacturer feedback that the 1.58 manufacturer markup
was too high for both GSFLs and IRLs and should be lowered, DOE revised
the manufacturer markup for both GSFLs and IRLs to be 1.52. The 1.52
figure is the same manufacturer markup used for these products in the
2009 Lamps Rule.
For a complete description of the end-user prices, see the product
price determination in section VI.E of this NOPR.
c. Shipment Scenarios
INPV, the key GRIM output, depends on industry revenue, which
depends on the quantity and prices of GSFLs and IRLs shipped in each
year of the analysis period. Industry revenue calculations require
forecasts of: (1) Total annual shipment volume of GSFLs and IRLs; (2)
the distribution of shipments across product classes (because prices
vary by product class); and, (3) the distribution of shipments across
efficacy levels (because prices vary with lamp efficacy).
In the base case shipment analysis, DOE first established a lumen
capacity demand per square foot for commercial and residential spaces
serviced by GSFLs and IRLs. While this lumen capacity per square foot
demand is assumed to remain unchanged over the analysis period, the
total lumen demand grows proportionally with the growth of new
commercial and residential floor space, as projected by AEO 2013. DOE
also expects the lighting demand for GSFLs and IRLs to be eroded by
increased penetration of LEDs into the market. This LED penetration
rate for the reference shipment scenario is based on the rate
forecasted in DOE's Solid-State Lighting Program. (See section VI.I of
this NOPR for further information.) Overall, while demand for lighting
is expected to increase for the entire economy as the amount of floor
space increases, the demand for GSFL and IRL specific lighting is
projected to decline in the base case due to the increased penetration
of alternative lighting sources such as LEDs.
In the standards case for GSFLs, DOE used a consumer choice model
the shipments analysis and NIA to analyze how consumers would shift
between GSFL product classes in response to standards (e.g., consumers
might forgo purchases of 4-foot MBP GSFLs in favor of 4-foot T5 MiniBP
SO GSFLs in response to a higher 4-foot MBP GSFL standard). GSFL
consumers were not, however, assumed to increase the purchase of LEDs
in response to increased GSFL energy conservation standards. As
discussed in section VI.I of this NOPR, the transition from GSFLs to
LEDs is accounted for in the base case shipment analysis, and
additional shifting to LEDs due to GSFL standards was not modeled in
the standards case shipment analysis or in the NIA.
In the standards case for IRLs, the change in the number of
shipments from the base case is mainly due to the increase in IRL
lifetime at TSL 1 compared to the base case shipment lifetime. IRLs
that meet the efficacy level specified at TSL 1 have a longer
[[Page 24135]]
lifetime than the baseline IRLs. As a result, there are fewer shipments
of IRLs at TSL 1 than in the base case over the analysis period,
because the lamps at TSL1 last longer. The NIA also modeled an
alternative IRL shipment scenario where the lifetime of IRLs at TSL 1
is shorter than the base case lifetime. DOE examined the impacts of a
shortened lifetime scenario on manufacturers' cash flow as a
sensitivity analysis. The results of the sensitivity analysis are
presented in appendix 13C of the NOPR TSD. Also, similar to GSFLs, the
shipments analysis and the NIA for IRLs did not model standards induced
shifts to alternative lighting technologies, such as LEDs. Therefore,
the MIA did not examine the revenue from LEDs in the manufacturers'
cash flows as part of the IRL MIA. While the shipments analysis and the
NIA recognize that consumers are shifting to alternative lighting
technologies, which are accounted for in the base case shipments
projection, the shipments analysis and the NIA did not model an
accelerated shift to these alternative technologies specifically due to
increased standards of IRLs.
For a complete description of the shipments see the shipments
analysis discussion in section VI.I of this NOPR.
d. Markup Scenarios
As discussed in the manufacturer production costs section above,
the MPCs for each of the product classes of GSFLs and IRLs are the
manufacturers' factory costs for those units. These costs include
materials, direct labor, depreciation, and overhead, which are
collectively referred to as the cost of goods sold (COGS). The MSP is
the price received by GSFL and IRL manufacturers from their customers,
typically a distributor, regardless of the downstream distribution
channel through which the lamps are ultimately sold. The MSP is not the
cost the end-user pays for GSFLs and IRLs because there are typically
multiple sales along the distribution chain and various markups applied
to each sale. The MSP equals the MPC multiplied by the manufacturer
markup. The manufacturer markup covers all the GSFL and IRL
manufacturer's non-production costs (i.e., selling, general and
administrative expenses [SG&A], research and development [R&D], and
interest, etc.) as well as profit. Total industry revenue for GSFL and
IRL manufacturers equals the MSPs at each EL for each product class
multiplied by the number of shipments at that EL.
Modifying these manufacturer markups in the standards case yields a
different set of impacts on GSFL and IRL manufacturers than in the base
case. For the MIA, DOE modeled two standards case markup scenarios for
GSFLs and IRLs to represent the uncertainty regarding the potential
impacts on prices and profitability for GSFL and IRL manufacturers
following the implementation of amended energy conservation standards.
The two scenarios are: (1) A flat, or preservation of gross margin,
markup scenario and (2) a preservation of operating profit markup
scenario. Each scenario leads to different manufacturer markup values,
which, when applied to the inputted MPCs, result in varying revenue and
cash flow impacts on GSFL and IRL manufacturers.
The flat, or preservation of gross margin, markup scenario assumes
that the COGS for each product is marked up by a flat percentage to
cover SG&A expenses, R&D expenses, interest expenses, and profit. This
allows manufacturers to preserve the same gross margin percentage in
the standards case as in the base case. This markup scenario represents
the upper bound of the GSFL and IRL industries' profitability in the
standards case because GSFL and IRL manufacturers are able to fully
pass through additional costs due to standards to their consumers.
To derive the flat, or preservation of gross margin, markup
percentages for GSFLs and IRLs, DOE examined the SEC 10-Ks of all
publicly traded GSFL and IRL manufacturers to estimate the industry
average gross margin percentage. Manufacturers were then asked about
the industry gross margin percentage derived from SEC 10-Ks during
manufacturer interviews. GSFL and IRL manufacturers stated that this
average industry gross margin was too large and needed to be reduced.
In response to these comments, DOE used the manufacturer markups from
the 2009 Lamps Rule for GSFLs and IRLs, which was slightly less than
the average industry gross margin derived from SEC 10-Ks of GSFL and
IRL manufacturers.
DOE included an alternative markup scenario, the preservation of
operating profit markup, because manufacturers stated they do not
expect to be able to markup the full cost of production in the
standards case, given the highly competitive GSFL and IRL lighting
markets. The preservation of operating profit markup scenario assumes
that manufacturers are able to maintain only the base case total
operating profit in absolute dollars in the standards case, despite
higher product costs and investment. The base case total operating
profit is derived from marking up the COGS for each product by the flat
markup described above. In the standards case for the preservation of
operating profit markup scenario, DOE adjusted the GSFL and IRL
manufacturer markups in the GRIM at each TSL to yield approximately the
same earnings before interest and taxes in the standards case in the
year after the compliance date of the amended GSFL and IRL standards as
in the base case. Under this scenario, while manufacturers are not able
to yield additional operating profit from higher production costs and
the investments that are required to comply with amended GSFL and IRL
energy conservation standards, they are able to maintain the same
operating profit in the standards case that was earned in the base
case.
The preservation of operating profit markup scenario represents the
lower bound of industry profitability in the standards case. This is
because manufacturers are not able to fully pass through the additional
costs necessitated by GSFL and IRL energy conservation standards, as
they are able to do in the flat (preservation of gross margin) markup
scenario. Therefore, manufacturers earn less revenue in the
preservation of operating profit markup scenario than they do in the
flat markup scenario.
3. Discussion of Comments
Interested parties commented on the assumptions and results of the
preliminary analysis. Comments addressed several topics: the potential
shift to other lighting technologies in response to GSFL and IRL
standards, the overall cumulative regulatory burden facing lighting
manufacturers, the potential decrease in competition due to IRL
standards, and the potential required use of proprietary technologies
to achieve higher efficacy levels for IRLs. DOE addresses these
comments below.
a. Potential Shift to Other Lighting Technologies
NEMA commented that further investments in GSFL and IRL
technologies due to energy conservation standards will divert resources
away from LED technology development. NEMA states that continued
development of LEDs could lead to much great energy savings potential
than the lighting technologies included in this rulemaking. NEMA
recommends that DOE include in the MIA for GSFLs and IRLs the impact
that such diversion of resources will have on LED technology if the
lighting industry is required by a potential GSFL and IRL standard to
make additional investments in GSFL and IRL
[[Page 24136]]
technologies that are already experiencing diminishing returns on
investment and use. (NEMA, No. 36 at p. 1)
DOE recognizes the opportunity cost associated with any investment,
and agrees that manufacturers would need to spend capital to meet any
proposed GSFL and IRL standards that they would not have to spend in
the base case. The allocation of company resources among different
lighting technologies is a complex business decision that each
individual manufacturer will ultimately have to make. As a result,
manufacturers must determine the extent to which they will balance
investment in the GSFL and IRL markets with investment in emerging
technologies, such as LEDs. The companies will have to weigh tradeoffs
between deferring investments and deploying additional capital. DOE
includes the costs on manufacturers of meeting today's proposed
standards in its analysis.
NEEP commented that the MIA should account for any potential growth
in LED sales lighting manufacturers might experience if the GSFL and
IRL markets are projected to shrink throughout the years of the
analysis. Instead of only accounting for lost revenues associated with
a decrease in GSFL and IRL sales, NEEP suggests DOE also factor in the
benefits those same manufacturers are potential gaining in the growing
LED markets. (NEEP, No. 33 at p. 3)
Based on the shipment analysis DOE does not believe GSFL and IRL
markets will increasingly migrate from traditional GSFL and IRL
technologies to alternate lighting technologies, such as LEDs, in
direct response to GSFL and IRL energy conservation standards. While
DOE recognizes that LEDs are continuing to capture more and more of the
traditional lighting markets serviced by GSFLs and IRLs, DOE does not
believe that GSFL and IRL standards will increase this shift to LEDs.
Therefore, this market shift to LEDs is captured in the base case
shipment scenario and is not a standards-induced market shift. DOE
excludes the revenue from LEDs earned by manufacturers who produce
GSFLs and IRLs in the GRIM since the revenue stream would be present in
both the base case and the standards case, resulting in no net impact
on the change in INPV.
b. Cumulative Regulatory Burden
NEMA, along with some individual manufacturers, commented on the
cumulative regulatory burden of this rulemaking given there are several
DOE energy conservation standards that affect the major lighting
manufacturers of this rulemaking. NEMA stated that DOE does not
adequately address or quantify the cumulative regulatory burden. NEMA
urges DOE to adopt a more transparent and open decision-making process
to better address their continued concerns. (NEMA, No. 30 at pp. 338-
340; NEMA, No. 36 at pp. 18-19) The cumulative regulatory burden is
explained in greater detail in section VII.B.2.e of this NOPR, and a
complete description of the cumulative regulatory burden is included in
chapter 13 of the NOPR TSD. A complete description of the proposal
selection process is provided in section VII.C of this NOPR.
GE commented they are concerned about the speed of this amended
GSFL and IRL energy conservation standard, given that the 2009 Lamps
Rule was published in 2009 and required compliance in 2012. They
believe that it is difficult for manufacturers to recover their
previous investments made in new technologies in only five and a half
years. This potential loss in investments has a severe and negative
manufacturer impact when rulemakings covering the same products are so
close together. (GE, No. 30 at p. 188)
Philips similarly commented that they had invested millions of
dollars in incandescent technologies to meet EISA 2007's general
service lighting requirements, which could become obsolete due to
amended IRL energy conservation standards. (Philips, No. 30 at p. 187)
EEI also made similar comments stating that manufacturers who made
long-term investments to comply with the 2009 Lamps Rule might not have
had time to recover their investments in five or six years. (EEI, No.
30 at p. 187) A member of Congress commented that the OSI facility in
Kentucky recently underwent major retooling to bring the facility into
compliance with EISA's incandescent lighting requirements. Bringing
that facility into compliance with even more stringent IRL regulations
would require an increased capital outlay that is unavailable to the
company at this time. This could result in a reduction of U.S.
manufacturing jobs. (Barr, No. 25 at p. 1-2) As part of the cumulative
regulatory burden analysis in section VII.B.2.e of this NOPR, DOE
examines the investments manufacturers have made to comply with
previous rulemakings.
Philips also commented on the cumulative regulatory burden, asking
DOE to specify the criteria that determines if the proposed standards
constitute a cumulative regulatory burden on manufacturers. (Philips,
No. 30 at pp. 339-340; 347) DOE examines the cumulative regulatory
burden as one of the potential impacts of potential standard levels
before ultimately selecting an appropriate proposed standard. This
examination of the costs and benefits of potential proposed standards
is addressed in section VII.C of this NOPR.
c. Potential Decrease in Competition
EEI commented they are concerned that there could be a reduction in
competition as a result of more stringent GSFL and IRL energy
conservation standards. EEI stated they are especially concerned about
any amended standards for IRLs due to the fact that DOJ determined that
the 2009 Lamps Rule would have anti-competitive impacts on the IRL
industry. EEI contends that any increase in the efficacy of IRLs due to
amended standards could potentially increase these anti-competitive
impacts. (EEI, No. 30 at pp. 335-337)
NEEA stated there seems to be an increase in the number of brand
names available in the marketplace for IRLs. (NEEA, No. 30 at pp. 337-
338) In the 2009 Lamps Rule, DOJ had expressed concerns that the
proposed TSL 4 for IRLs could adversely affect competition noting that
only two of the three large manufacturers manufacture IRLs that would
meet the new standard and one of these manufacturers uses proprietary
technology to do so. However, DOE research showed that all three large
manufacturers had products that met TSL 4 and access to alternative
technology pathways to achieve this efficacy that did not require
propriety technology. Further, based on market research, analysis of
HIR burner production, and interviews with manufacturers and HIR burner
suppliers, DOE determined that manufacturers would not face any long-
term capacity constraints. Therefore, DOE concluded that the proposed
level in the 2009 Lamps rule for IRLs would not result in lessening
competition. 74 FR 34080, 34160 (July 14, 2009).
DOE examines the potential decrease in competition from amended
energy conservation standards in section VII.B.5 of this NOPR. DOE also
submits a copy of the NOPR to DOJ for review as part of the rulemaking
process and considers input from DOJ in developing any final standards.
4. Manufacturer Interviews
DOE conducted additional interviews with manufacturers following
the preliminary analysis in preparation for the NOPR analysis. In these
interviews, DOE asked manufacturers to describe their major concerns
with this GSFL and
[[Page 24137]]
IRL rulemaking. The following section describes the key issues
identified by GSFL and IRL manufacturers during these interviews.
a. Rare Earth Oxides in General Service Fluorescent Lamps
Several manufacturers are concerned that increasing the efficacy of
GSFLs in response to amended energy conservation standards will require
the use of significantly more REOs in GSFLs. This could expose GSFL
manufacturers to the risk of another significant increase in the price
of REOs. Over the past several years the price of REOs used in GSFLs
has been extremely volatile. In 2011, the price of REOs significantly
increased but has slowly been coming down over the past couple of
years. While the current price of many of these REOs has returned to
much lower levels than the peak prices experienced between 2010 and
2012, GSFL manufacturers are concerned that the price of REOs could
return to those peak prices in the future. GSFL manufacturers are also
concerned an increase in the demand for REOs due to amended energy
conservation standards could cause the price for these REOs to spike.
Several GSFL manufacturers also noted that amended energy
conservation standards for GSFLs could have adverse impacts on the
domestic production of GSFLs. China is currently the dominant miner and
producer of REOs worldwide and imposes quotas on the export of raw
REOs. This drives up the costs for manufacturers of products using REOs
that manufacture these products outside of China. As a result,
manufacturers pointed out that amended GSFL standards could make it
more attractive to manufacture GSFLs in China, rather than
domestically, because the price of REOs would likely be much lower in
China. See section VI.D.2.i of this NOPR for further discussion of the
assessments of rare earth phosphor impacts from amended standards
undertake in this NOPR analysis.
b. Unknown Impacts of the 2009 Lamps Rule
Several manufacturers expressed concern that amended energy
conservation standards for GSFLs and IRLs would be premature given that
the last round of DOE energy conservation standards for GSFLs and IRLs
required compliance in July 2012. Manufacturers are still unsure how
the standards from the 2009 Lamps Rule will ultimately affect their
future sales and shipments as consumer preferences shift since there
are a relatively large number of alternative lighting options available
on the market. Manufacturers noted that they have developed new
products to meet the 2009 Lamps Rule standards and are still waiting to
see which consumers purchase which types of lamps.
Furthermore, manufacturers stated they have already made
significant capital investments in order to be able to produce the more
efficacious GSFLs and IRLs required by the 2009 Lamps Rule standards.
Manufacturers are concerned that any additional increase in the
efficacy of those products due to amended energy conservation standards
could potentially strand the substantial capital investments made to
comply with the 2009 Lamps Rule, as manufacturers have not yet fully
recouped these capital investments. Manufacturers stated that a five
year time period between the compliance date of the 2009 Lamps Rule
(July 2012) and the estimated compliance date of the current GSFL and
IRL rulemaking (2017) is too short for most manufacturers to recoup
their capital investments, since manufacturing machinery typically has
a much longer useful lifetime than five years. See section VII.B.2 of
this NOPR for an analysis of the investments manufacturers must make to
comply with standards.
c. Technology Shift
Several manufacturers contended that regardless of amended energy
conservation standards, a technological shift away from GSFLs and IRLs
is already occurring. They pointed out that the market is already
moving toward LEDs, especially in the commercial sector. Manufacturers
are concerned that amended standards would force them to divert
resources away from the R&D of more efficacious lighting products, such
as LEDs, by forcing manufacturers to spend time and money on GSFLs and
IRLs, which have diminishing market shares. This increase in the
efficacy of GSFLs and IRLs would increase the end-user price of GSFLs
and IRLs which could ultimately drive consumers to purchase other
lighting technologies, like LEDs. This could result in a further
stranding of any capital investments made for GSFLs and IRLs. See
section VI.I of this NOPR for discussion on the LED market penetration
shipment scenario.
d. Impact on Residential Sector
Several manufacturers expressed concern that amended energy
conservation standards for GSFLs and IRLs would not achieve substantial
energy savings in the residential sector. Residential consumers do not
have long operating hours and manufacturers are concerned that they
will give up longer life to get a cheaper lamp. Furthermore,
manufacturers expressed concern that amended GSFL standards may be
overly burdensome by forcing some residential consumers of GSFLs to
switch out their entire lighting system (i.e., ballast and fixture) due
to replacement lamps being regulated out of production for only minimal
energy savings. DOE acknowledges that residential consumers could be
differentially impacted by GSFL and IRL standards compared to
commercial consumers. DOE analyzed residential and commercial consumers
separately in the LCC analysis for GSFLs and IRLs. These results are
presented in section VII.B.1.a of this NOPR.
L. Emissions Analysis
In the emissions analysis, DOE estimated the reduction in power
sector emissions of SO2, NOX, CO2, and
Hg from potential energy conservation standards for GSFLs and IRLs. In
addition, DOE estimates emissions impacts in production activities
(extracting, processing, and transporting fuels) that provide the
energy inputs to power plants. These are referred to as ``upstream''
emissions. Together, these emissions account for the FFC.
DOE conducted the emissions analysis using emissions factors for
CO2 and other gases derived from data in the EIA's AEO 2013,
supplemented by data from other sources. DOE developed separate
emissions factors for power sector emissions and upstream emissions.
EIA prepares the AEO using NEMS. Each annual version of NEMS
incorporates the projected impacts of existing air quality regulations
on emissions. AEO 2013 generally represents current legislation and
environmental regulations, including recent government actions, for
which implementing regulations were available as of December 31, 2012.
The method that DOE used to derive emissions factors is described in
chapter 14 of the NOPR TSD.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-trade
programs. Title IV of the Clean Air Act sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous states and the
District of Columbia (D.C.). SO2 emissions from 28 eastern
states and D.C. were also limited under the Clean Air Interstate Rule
(CAIR; 70 FR 25162 (May 12, 2005)), which created an allowance-based
trading program that operates along with the Title IV program. CAIR was
remanded to the U.S. Environmental
[[Page 24138]]
Protection Agency (EPA) by the U.S. Court of Appeals for the District
of Columbia Circuit but it remained in effect. See North Carolina v.
EPA, 550 F.3d 1176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d
896 (D.C. Cir. 2008). On July 6, 2011 EPA issued a replacement for
CAIR, the Cross-State Air Pollution Rule (CSAPR). 76 FR 48208 (August
8, 2011). On August 21, 2012, the D.C. Circuit issued a decision to
vacate CSAPR. See EME Homer City Generation, LP v. EPA, No. 11-1302,
2012 WL 3570721 at *24 (D.C. Cir. Aug. 21, 2012). The court ordered EPA
to continue administering CAIR. The AEO 2013 emissions factors used for
today's NOPR assumes that CAIR remains a binding regulation through
2040.
The attainment of emissions caps is typically flexible among EGUs
and is enforced through the use of emissions allowances and tradable
permits. Under existing EPA regulations, any excess SO2
emissions allowances resulting from the lower electricity demand caused
by the adoption of an efficacy standard could be used to permit
offsetting increases in SO2 emissions by any regulated EGU.
In past rulemakings, DOE recognized that there was uncertainty about
the effects of efficiency standards on SO2 emissions covered
by the existing cap-and-trade system, but it concluded that negligible
reductions in power sector SO2 emissions would occur as a
result of standards.
Beginning in 2015, however, SO2 emissions will fall as a
result of the Mercury and Air Toxics Standards (MATS) for power plants,
which were announced by EPA on December 21, 2011. 77 FR 9304 (Feb. 16,
2012). In the final MATS rule, EPA established a standard for hydrogen
chloride as a surrogate for acid gas hazardous air pollutants (HAP),
and also established a standard for SO2 (a non-HAP acid gas)
as an alternative equivalent surrogate standard for acid gas HAP. The
same controls are used to reduce HAP and non-HAP acid gas; thus,
SO2 emissions will be reduced as a result of the control
technologies installed on coal-fired power plants to comply with the
MATS requirements for acid gas. AEO 2013 assumes that, to continue
operating, coal plants must have either flue gas desulfurization or dry
sorbent injection systems installed by 2015. Both technologies, which
are used to reduce acid gas emissions, also reduce SO2
emissions. Under the MATS, NEMS shows a reduction in SO2
emissions when electricity demand decreases (e.g., as a result of
energy efficiency standards). Emissions will be far below the cap
established by CAIR, so it is unlikely that excess SO2
emissions allowances resulting from the lower electricity demand would
be needed or used to permit offsetting increases in SO2
emissions by any regulated EGU. Therefore, DOE believes that efficiency
standards will reduce SO2 emissions in 2015 and beyond.
CAIR established a cap on NOX emissions in 28 eastern
states and the District of Columbia. Energy conservation standards are
expected to have little effect on NOX emissions in those
states covered by CAIR because excess NOX emissions
allowances resulting from the lower electricity demand could be used to
permit offsetting increases in NOX emissions. However,
standards would be expected to reduce NOX emissions in the
states not affected by the caps, so DOE estimated NOX
emissions reductions from the standards considered in this NOPR for
these states.
The MATS limit mercury emissions from power plants, but they do not
include emissions caps and, as such, DOE's energy conservation
standards would likely reduce Hg emissions. DOE estimated Hg emissions
reduction using emissions factors based on AEO 2013, which incorporates
the MATS.
In accordance with DOE's FFC Statement of Policy (76 FR 51282 (Aug.
18, 2011)), the FFC analysis includes impacts on emissions of methane
(CH4) and nitrous oxide (N2O), both of which are
recognized as GHGs. For CH4 and N2O, DOE
calculated emissions reductions in tons and also in terms of units of
carbon dioxide equivalent (CO2eq). Gases are converted to
CO2eq by multiplying the emissions reduction in tons by the
gas' global warming potential (GWP) over a 100-year time horizon. Based
on the Fourth Assessment Report of the Intergovernmental Panel on
Climate Change,\80\ DOE used GWP values of 25 for CH4 and
298 for N2O.
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\80\ Forster, P., V. Ramaswamy, P. Artaxo, T. Berntsen, R.
Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J.
Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland. 2007:
Changes in Atmospheric Constituents and in Radiative Forcing. In
Climate Change 2007: The Physical Science Basis. Contribution of
Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change. S. Solomon, D. Qin, M.
Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller,
Editors. 2007. Cambridge University Press, Cambridge, United Kingdom
and New York, NY, USA. p. 212.
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M. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this proposed rule, DOE considered
the estimated monetary benefits from the reduced emissions of
CO2 and NOX expected to result from each of the
TSLs considered. To make this calculation similar to the calculation of
the NPV of consumer benefit, DOE considered the reduced emissions
expected to result over the lifetime of product shipped in the forecast
period for each TSL. This section summarizes the basis for the monetary
values used for each of these emissions and presents the values
considered in this rulemaking.
For today's NOPR, DOE is relying on a set of values for the social
cost of carbon (SCC) that was developed by an interagency process. A
summary of the basis for these values is provided below, and a more
detailed description of the methodologies used is provided in
appendices to chapter 15 of the NOPR TSD.
1. Social Cost of Carbon
The SCC is an estimate of the monetized damages associated with an
incremental increase in carbon emissions in a given year. It is
intended to include (but is not limited to) changes in net agricultural
productivity, human health, property damages from increased flood risk,
and the value of ecosystem services. Estimates of the SCC are provided
in dollars per metric ton of CO2. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in CO2 emissions, while a global SCC
value is meant to reflect the value of damages worldwide.
Under section 1(b)(6) of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993), agencies must, to
the extent permitted by law, assess both the costs and the benefits of
the intended regulation and, recognizing that some costs and benefits
are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation
justify its costs. The purpose of the SCC estimates presented here is
to allow agencies to incorporate the monetized social benefits of
reducing CO2 emissions into cost-benefit analyses of
regulatory actions that have small, or ``marginal,'' impacts on
cumulative global emissions. The estimates are presented with an
acknowledgement of the many uncertainties involved and with a clear
understanding that they should be updated over time to reflect
increasing knowledge of the science and economics of climate impacts.
As part of the interagency process that developed the SCC
estimates, technical experts from numerous agencies met on a regular
basis to consider public comments, explore the technical literature in
relevant fields, and discuss
[[Page 24139]]
key model inputs and assumptions. The main objective of this process
was to develop a range of SCC values using a defensible set of input
assumptions grounded in the existing scientific and economic
literatures. In this way, key uncertainties and model differences
transparently and consistently inform the range of SCC estimates used
in the rulemaking process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
CO2 emissions, the analyst faces a number of serious
challenges. A recent report from the National Research Council points
out that any assessment will suffer from uncertainty, speculation, and
lack of information about: (1) Future emissions of GHGs; (2) the
effects of past and future emissions on the climate system; (3) the
impact of changes in climate on the physical and biological
environment; and (4) the translation of these environmental impacts
into economic damages. As a result, any effort to quantify and monetize
the harms associated with climate change will raise serious questions
of science, economics, and ethics and should be viewed as provisional.
Despite the serious limits of both quantification and monetization,
SCC estimates can be useful in estimating the social benefits of
reducing CO2 emissions. Most Federal regulatory actions can
be expected to have marginal impacts on global emissions. For such
policies, the agency can estimate the benefits from reduced emissions
in any future year by multiplying the change in emissions in that year
by the SCC value appropriate for that year. The NPV of the benefits can
then be calculated by multiplying the future benefits by an appropriate
discount factor and summing across all affected years. This approach
assumes that the marginal damages from increased emissions are constant
for small departures from the baseline emissions path, an approximation
that is reasonable for policies that have effects on emissions that are
small relative to cumulative global CO2 emissions. For
policies that have a large (non-marginal) impact on global cumulative
emissions, there is a separate question of whether the SCC is an
appropriate tool for calculating the benefits of reduced emissions.
This concern is not applicable to this rulemaking, however.
It is important to emphasize that the interagency process is
committed to updating these estimates as the science and economic
understanding of climate change and its impacts on society improves
over time. In the meantime, the interagency group will continue to
explore the issues raised by this analysis and consider public comments
as part of the ongoing interagency process.
b. Social Cost of Carbon Values Used in Past Regulatory Analyses
Economic analyses for Federal regulations have used a wide range of
values to estimate the benefits associated with reducing CO2
emissions. In the final model year 2011 CAFE rule, the U.S. Department
of Transportation (DOT) used both a ``domestic'' SCC value of $2 per
metric ton of CO2 and a ``global'' SCC value of $33 per
metric ton of CO2 for 2007 emission reductions (in 2007$),
increasing both values at 2.4 percent per year. DOT also included a
sensitivity analysis at $80 per metric ton of CO2.\81\ A
2008 regulation proposed by DOT assumed a domestic SCC value of $7 per
metric ton of CO2 (in 2006$) for 2011 emission reductions
(with a range of $0 to $14 for sensitivity analysis), also increasing
at 2.4 percent per year.\82\ A regulation for packaged terminal air
conditioners and packaged terminal heat pumps finalized by DOE in
October of 2008 used a domestic SCC range of $0 to $20 per metric ton
CO2 for 2007 emission reductions (in 2007$). 73 FR 58772,
58814 (Oct. 7, 2008). In addition, EPA's 2008 Advance Notice of
Proposed Rulemaking on Regulating Greenhouse Gas Emissions Under the
Clean Air Act identified what it described as ``very preliminary'' SCC
estimates subject to revision. 73 FR 44354 (July 30, 2008). EPA's
global mean values were $68 and $40 per metric ton CO2 for
discount rates of approximately 2 percent and 3 percent, respectively
(in 2006$ for 2007 emissions).
---------------------------------------------------------------------------
\81\ See Average Fuel Economy Standards Passenger Cars and Light
Trucks Model Year 2011, 74 FR 14196 (March 30, 2009) (Final Rule);
Final Environmental Impact Statement Corporate Average Fuel Economy
Standards, Passenger Cars and Light Trucks, Model Years 2011-2015 at
3-90 (Oct. 2008) (Available at: www.nhtsa.gov/fuel-economy) (Last
accessed December 2012).
\82\ See Average Fuel Economy Standards, Passenger Cars and
Light Trucks, Model Years 2011-2015, 73 FR 24352 (May 2, 2008)
(Proposed Rule); Draft Environmental Impact Statement Corporate
Average Fuel Economy Standards, Passenger Cars and Light Trucks,
Model Years 2011-2015 at 3-58 (June 2008) (Available at:
www.nhtsa.gov/fuel-economy) (Last accessed December 2012).
---------------------------------------------------------------------------
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing CO2 emissions. To ensure consistency in how
benefits are evaluated across agencies, the Administration sought to
develop a transparent and defensible method, specifically designed for
the rulemaking process, to quantify avoided climate change damages from
reduced CO2 emissions. The interagency group did not
undertake any original analysis. Instead, it combined SCC estimates
from the existing literature to use as interim values until a more
comprehensive analysis could be conducted. The outcome of the
preliminary assessment by the interagency group was a set of five
interim values: Global SCC estimates for 2007 (in 2006$) of $55, $33,
$19, $10, and $5 per metric ton of CO2. These interim values
represented the first sustained interagency effort within the U.S.
government to develop an SCC for use in regulatory analysis. The
results of this preliminary effort were presented in several proposed
and final rules.
c. Current Approach and Key Assumptions
Since the release of the interim values, the interagency group
reconvened on a regular basis to generate improved SCC estimates.
Specifically, the group considered public comments and further explored
the technical literature in relevant fields. The interagency group
relied on three integrated assessment models commonly used to estimate
the SCC: The FUND, DICE, and PAGE models. These models are frequently
cited in the peer-reviewed literature and were used in the last
assessment of the Intergovernmental Panel on Climate Change. Each model
was given equal weight in the SCC values that were developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: Climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the interagency group used a range of scenarios for the
socio-economic parameters and a range of values for the discount rate.
All other model features were left unchanged, relying on the model
developers' best estimates and judgments.
In 2010, the interagency group selected four sets of SCC values for
use
[[Page 24140]]
in regulatory analyses.\83\ Three sets of values are based on the
average SCC from three integrated assessment models, at discount rates
of 2.5 percent, 3 percent, and 5 percent. The fourth set, which
represents the 95th-percentile SCC estimate across all three models at
a 3 percent discount rate, is included to represent higher-than-
expected impacts from climate change further out in the tails of the
SCC distribution. The values grow in real terms over time.
Additionally, the interagency group determined that a range of values
from 7 percent to 23 percent should be used to adjust the global SCC to
calculate domestic effects, although preference is given to
consideration of the global benefits of reducing CO2
emissions. Table VI.15 presents the values in the 2010 interagency
group report, which is reproduced in appendix 15A of the NOPR TSD.
---------------------------------------------------------------------------
\83\ Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. Interagency Working Group on Social Cost of
Carbon, United States Government, February 2010. www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
Table VI.15--Annual SCC Values From 2010 Interagency Report, 2010-2050
[In 2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for today's notice were generated using the
most recent versions of the three integrated assessment models that
have been published in the peer-reviewed literature.\84\ Table VI.16
shows the updated sets of SCC estimates from the 2013 interagency
update in five-year increments from 2010 to 2050. Appendix 15B of the
NOPR TSD provides the full set of values. The central value that
emerges is the average SCC across models at 3 percent discount rate.
However, for purposes of capturing the uncertainties involved in
regulatory impact analysis, the interagency group emphasizes the
importance of including all four sets of SCC values.
---------------------------------------------------------------------------
\84\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United States Government.
May 2013; revised November 2013. http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
Table VI.16--Annual SCC Values From 2013 Interagency Update, 2010-2050
[In 2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 11 32 51 89
2015............................................ 11 37 57 109
2020............................................ 12 43 64 128
2025............................................ 14 47 69 143
2030............................................ 16 52 75 159
2035............................................ 19 56 80 175
2040............................................ 21 61 86 191
2045............................................ 24 66 92 206
2050............................................ 26 71 97 220
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable since they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The National Research
Council report mentioned previously points out that there is tension
between the goal of producing quantified estimates of the economic
damages from an incremental ton of carbon and the limits of existing
efforts to model these effects. There are a number of concerns and
problems that should be addressed by the research community, including
research programs housed in many of the federal agencies participating
in the interagency process to estimate the SCC. The interagency group
intends to periodically review and reconsider those estimates to
reflect increasing
[[Page 24141]]
knowledge of the science and economics of climate impacts, as well as
improvements in modeling.
In summary, in considering the potential global benefits resulting
from reduced CO2 emissions resulting from today's rule, DOE
used the values from the 2013 interagency report, adjusted to 2012$
using the Gross Domestic Product price deflator. For each of the four
SCC cases specified, the values used for emissions in 2015 were $11.8,
$39.7, $61.2, and $117 per metric ton avoided (values expressed in
2012$). DOE derived values after 2050 using the relevant growth rates
for the 2040-2050 period in the interagency update. DOE invites comment
on the methodology used to estimate the social cost of carbon.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SCC value for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SCC values in each case.
2. Valuation of Other Emissions Reductions
As noted previously, DOE has taken into account how new or amended
energy conservation standards would reduce NOX emissions in
those 22 states not affected by the CAIR. DOE estimated the monetized
value of NOX emissions reductions resulting from each of the
TSLs considered for today's NOPR based on estimates found in the
relevant scientific literature. Estimates of monetary value for
reducing NOX from stationary sources range from $468 to
$4,809 per ton in 2012$.\85\ DOE calculated monetary benefits using a
medium value for NOX emissions of $2,639 per short ton (in
2012$) and real discount rates of 3 percent and 7 percent.
---------------------------------------------------------------------------
\85\ U.S. Office of Management and Budget, Office of Information
and Regulatory Affairs, 2006 Report to Congress on the Costs and
Benefits of Federal Regulations and Unfunded Mandates on State,
Local, and Tribal Entities, Washington, DC.
---------------------------------------------------------------------------
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. It has not included monetization in the current analysis.
N. Utility Impact Analysis
The utility impact analysis estimates several effects on the power
generation industry that would result from the adoption of new or
amended energy conservation standards. In the utility impact analysis,
DOE analyzes the changes in installed electricity capacity and
generation that would result for each trial standard level. The utility
impact analysis uses a variant of NEMS,\86\ which is a public domain,
multi-sectored, partial equilibrium model of the U.S. energy sector.
DOE uses a variant of this model, referred to as NEMS-BT, to account
for selected utility impacts of new or amended energy conservation
standards. DOE's analysis consists of a comparison between model
results for the most recent AEO Reference Case and for cases in which
energy use is decremented to reflect the impact of potential standards.
The energy savings inputs associated with each TSL come from the NIA.
Chapter 16 of the NOPR TSD describes the utility impact analysis in
further detail.
---------------------------------------------------------------------------
\86\ For more information on NEMS, refer to the U.S. Department
of Energy, Energy Information Administration documentation. A useful
summary is National Energy Modeling System: An Overview 2003, DOE/
EIA-0581 (2003) (March, 2003).
---------------------------------------------------------------------------
NEEP urged DOE to quantify the economic benefits of electricity
demand reductions for this rulemaking. (NEEP, No. 51 at p. 3)
For the NOPR, DOE used NEMS-BT, along with EIA data on the capital
cost of various power plant types, to estimate the reduction in
national expenditures for electricity generating capacity due to
potential GSFL-IRL energy efficiency standards. The method used and the
results are described in chapter 16 of the NOPR TSD.
DOE is evaluating whether parts of the cost reduction are a
transfer and, thus, according to guidance provided by OMB to Federal
agencies, should not be included in the estimates of the benefits and
costs of a regulation.\87\ Transfer payments are monetary payments from
one group to another that do not affect total resources available to
society (i.e., exchanges that neither decrease nor increase total
welfare). Benefits occur when savings to consumers result from real
savings to producers, which increase societal benefits. Cost savings
from reduced or delayed capital expenditure on power plants are a
benefit, and not a transfer, to the extent that the reduced expenditure
provides savings to both producers and consumers without affecting
other groups. There would be a transfer to the extent that the delayed
construction caused some other group (e.g., product suppliers or
landowners who might have assets committed to the projects) to realize
a lower return on those assets. DOE is evaluating these issues to
determine the extent to which the cost savings from delayed capital
expenditure on power plants are a benefit to society.\88\
---------------------------------------------------------------------------
\87\ OMB Circular A-4 (Sept. 17, 2003), p. 38.
\88\ Although delayed investment implies a savings in total
cost, the savings may be less than the savings in capital cost
because the delay may also cause increases in other costs. For
example, if the delayed investment was the replacement of an
existing facility with a larger, more efficient facility, the
increased cost of operating the old facility during the period of
delay might offset much of the savings from delayed investment. That
the project was delayed is evidence that doing so decreased overall
cost, but it does not indicate that the decrease was equal to the
entire savings in capital cost.
---------------------------------------------------------------------------
O. Employment Impact Analysis
Employment impacts from new or amended energy conservation
standards include direct and indirect impacts. Direct employment
impacts are any changes in the number of employees of manufacturers of
the product subject to standards; the MIA addresses those impacts.
Indirect employment impacts are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more efficient product. Indirect
employment impacts from standards consist of the jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, due to: (1) Reduced spending by end users on
energy; (2) reduced spending on new energy supply by the utility
industry; (3) increased consumer spending on the purchase of new
product; and (4) the effects of those three factors throughout the
economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (BLS). BLS regularly publishes its estimates of the
number of jobs per million dollars of economic activity in different
sectors of the economy, as well as the jobs created elsewhere in the
economy by this same economic activity. Data from BLS indicate that
expenditures in the utility sector generally create fewer jobs (both
directly and indirectly) than expenditures in other sectors of the
economy. There are many reasons for these differences, including wage
differences and the fact that the utility sector is more capital-
intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive
[[Page 24142]]
sector (i.e., the utility sector) to more labor-intensive sectors
(e.g., the retail and service sectors). Based on the BLS data, DOE
expects that net national employment may increase because of shifts in
economic activity resulting from amended standards.
For the standard levels considered in the NOPR, DOE estimated
indirect national employment impacts using an input/output model of the
U.S. economy called Impact of Sector Energy Technologies, Version 3.1.1
(ImSET). ImSET is a special-purpose version of the ``U.S. Benchmark
National Input-Output'' (I-O) model, which was designed to estimate the
national employment and income effects of energy-saving technologies.
The ImSET software includes a computer-based I-O model having
structural coefficients that characterize economic flows among the 187
sectors. ImSET's national economic I-O structure is based on a 2002
U.S. benchmark table, specially aggregated to the 187 sectors most
relevant to industrial, commercial, and residential building energy
use. DOE notes that ImSET is not a general equilibrium forecasting
model, and understands the uncertainties involved in projecting
employment impacts, especially changes in the later years of the
analysis. Because ImSET does not incorporate price changes, the
employment effects predicted by ImSET may over-estimate actual job
impacts over the long run. For the NOPR, DOE used ImSET only to
estimate short-term employment impacts. For more details on the
employment impact analysis, see chapter 17 of the NOPR TSD.
P. Other Comments
DOE received several comments that address the overall merits of
adopting amended standards for GSFLs and IRLs.
NEMA stated that existing voluntary incentives are already shifting
the market to higher-efficiency products and systems. (NEMA, No. 36 at
p. 17) Trends in the GSFL and IRL market are accounted for in DOE's
projection of the base case. The impacts estimated for potential
standards are above movement toward higher efficiency in the base case.
NEMA commented that standards are not justified for IRLs.
Specifically, NEMA stated that the miniscule energy savings estimated
for IRLs, combined with elimination of their market share by 2025,
demonstrate why this class should not be further regulated and DOE
should not adopt a new standard. (NEMA, No. 36 at pp. 2, 17) DOE's
analysis indicates that the market share of IRLs would decline under
the proposed standards, but the product would not be eliminated. The
reasons for DOE's decision to propose standards for IRLs are explained
in section VII.C of this notice.
NEMA also stated that, if DOE were to proceed with a higher
standard for T5 SO lamps, the projected shipments go up (compared with
the base case). It noted that, as the only competitor for T5 SO is LED,
increasing the demand for T5 SO takes market share away from LED, a
technology that is on the rise for reasons of popularity, lifetime, and
efficiency. It stated that decreasing demand for LED technology in
favor of an obsoleting technology that relies on critical materials
(rare earth phosphors) and mercury is not a sound decision. (NEMA, No.
36 at p. 17) As discussed in chapter 11 of the NOPR TSD, the model
accounts for the progressive and large incursion of LEDs into the GSFL
market. The model then apportions the remaining demand for GSFL lamps
among the product classes. The projected increase in shipments of T5 SO
lamps relative to the base case is at the expense of 4-foot MBP lamps,
not LEDs.
VII. Analytical Results
A. Trial Standard Levels
At the NOPR stage, DOE develops trial standard levels (TSLs) for
consideration. The GSFL and IRL TSLs are formed by grouping different
efficacy levels, which are potential standard levels for each product
class. TSL 5 is composed of the max tech efficacy levels. TSL 4 is
composed of the efficacy levels that, in combination, yield the maximum
NPV. TSL 3 is composed of the efficacy levels that yield the maximum
energy savings without using any of the EL 2 levels. TSL 2 is composed
of the efficacy levels that would bring all product classes to
approximately the same level of rare earth phosphor. TSL 1 is composed
of the levels that represent the least efficacious lamps currently
available on the U.S. market; currently there are no products in the
market at the baseline (EL 0) for 8-foot RDC HO lamps or T5 lamps. For
IRLs, DOE considered one TSL because only one efficacy level was
analyzed (Table VII.2).
DOE used data on the representative product classes from the
engineering and pricing analyses described in section VI.D.2.b for
GSFLs and section VI.D.3.b for IRLs to evaluate the benefits and
burdens of each of the GSFL and IRL TSLs. DOE analyzed the benefits and
burdens by conducting the analyses described in section VI for each
TSL. Table VII.1 presents the GSFL TSLs analyzed and the corresponding
efficacy level for each GSFL representative product class. Table VII.2
presents the IRL TSL analyzed and the corresponding efficacy level for
the representative IRL product class.
Table VII.1--Composition of TSLs for GSFLs by Efficacy Level
----------------------------------------------------------------------------------------------------------------
TSL 1 Current TSL 2 Same TSL 3 Best non-
Representative product class market min phosphor level EL 2 TSL 4 Max NPV TSL 5 Max tech
----------------------------------------------------------------------------------------------------------------
1. 4-foot medium bipin, CCT 0 0 1 2 2
<=4,500 K......................
2. 8-foot single pin slimline, 0 1 0 0 2
CCT <=4,500 K..................
3. 8-foot RDC high output, CCT 1 2 1 1 2
<=4,500 K......................
4. 4-foot T5, Mini bipin 1 1 1 1 2
standard output, CCT <=4,500 K.
5. 4-foot T5, Mini bipin high 1 1 1 1 1
output, CCT <=4,500 K..........
----------------------------------------------------------------------------------------------------------------
Table VII.2--Composition of TSLs for IRLs by Efficacy Level
------------------------------------------------------------------------
Representative product class TSL 1
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V.......... 1
------------------------------------------------------------------------
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on GSFL and IRL consumers by
looking at the effects standards would have on the LCC and PBP. DOE
also examined the impacts of potential standards on consumer subgroups.
These analyses are discussed below.
a. Life-Cycle Cost and Payback Period
Consumers affected by new or amended standards usually experience
[[Page 24143]]
higher purchase prices and lower operating costs. Generally, these
impacts on individual consumers are best captured by changes in LCCs
and by the payback period. DOE's LCC and PBP analyses provide key
outputs for each TSL, which are reported by product class in Table
VII.3-Table VII.15. DOE designed the LCC analysis around lamp
purchasing events and calculated the LCC savings relative to the
baseline for each lamp replacement event separately in each lamp
product class. Each table includes the average total LCC and the
average LCC savings, as well as the fraction of product consumers for
which the LCC will either decrease (net benefit), or increase (net
cost) relative to the base-case forecast. When an EL results in
``positive LCC savings,'' the LCC of the lamp or lamp-and-ballast
system is less than the LCC of the baseline lamp or lamp-and-ballast
system, and the consumer benefits economically. When an EL results in
``negative LCC savings,'' the LCC of the lamp or lamp-and-ballast
system is higher than the LCC of the baseline lamp or lamp-and-ballast
system, and the consumer is adversely affected economically. The last
outputs in the tables are the mean PBPs for the consumer that is
purchasing a design compliant with the TSL. Entries of ``NER'' indicate
standard levels that do not reduce operating costs, which prevents the
consumer from recovering the increased purchase cost. The PBP cannot be
calculated in those instances because the denominator of the PBP
equation is 0. Because LCC savings and PBP are not relevant at the
baseline level, results are ``N/A'' (not applicable) for the baselines.
Chapter 8 of the NOPR TSD provides a detailed description of the LCC
and PBP analysis and the results. Appendix 8B of the NOPR TSD presents
Monte Carlo simulation results performed by DOE as part of the LCC
analysis and also presents sensitivity results, such as LCC savings
under the AEO 2013 high-economic-growth and low-economic-growth cases.
The results for each TSL are relative to the energy use
distribution in the base case (no amended standards), based on energy
consumption under conditions of actual product use. The rebuttable
presumption PBP is based on test values under conditions prescribed by
the DOE test procedure, as required by EPCA. (42 U.S.C.
6295(o)(2)(B)(iii))
General Service Fluorescent Lamps
Table VII.3 through Table VII.11 present the results for each of
the five GSFL representative product classes that DOE analyzed.
Specifically, these were the 4-foot MBP product class, 4-foot MiniBP SO
product class, 4-foot MiniBP HO product class, 8-foot SP slimline
product class, and 8-foot RDC HO product class. For GSFLs, results for
the most common sector for each product class are presented. Chapter 8
of the NOPR TSD provides the LCC and PBP results for each product class
in all relevant sectors.
Table VII.3--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 17.19 116.96 134.33 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.88 BF 33.38 116.96 138.62 -4.29 100 0 NER
EL 2............... 93.0 Inst. 29.79 98.00 127.98 6.36 0.1 99.9 3.2
EL 2............... 95.4 26.6 W T8 & 0.88 BF 26.73 116.96 143.88 -9.55 100 0 NER
EL 2............... 96.0 Inst. 23.99 105.12 129.29 5.04 0 100 2.8
32.5 W T8 & 0.88 BF
Inst.
28.4 W T8 & 0.88 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 59.99 115.47 158.74 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 76.18 103.28 150.84 7.90 0 100 0.4
Replacement. EL 2............... 93.0 Inst. 72.59 96.70 152.58 6.17 0.1 99.9 3.3
EL 2............... 95.4 26.6 W T8 & 0.88 BF 69.53 101.06 153.88 4.87 0.1 99.9 3.2
EL 2............... 96.0 Inst. 66.79 101.96 152.03 6.72 0 100 2.4
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 62.78 115.47 160.44 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 78.97 103.28 152.53 7.90 0 100 0.4
Purchase. EL 2............... 93.0 Inst. 75.39 96.70 154.27 6.17 0.1 99.9 3.3
EL 2............... 95.4 26.6 W T8 & 0.88 BF 72.33 101.06 155.57 4.87 0.1 99.9 3.2
EL 2............... 96.0 Inst. 69.58 101.96 153.72 6.72 0 100 2.4
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24144]]
Table VII.4--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 17.19 178.88 196.22 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.88 BF 31.26 178.88 202.33 -6.11 100.0 0.0 NER
EL 2............... 93.0 Prog. 29.79 150.18 180.13 16.09 0.0 100.0 3.3
EL 2............... 95.4 26.6 W T8 & 0.88 BF 26.73 178.88 205.77 -9.55 100.0 0.0 NER
EL 2............... 96.0 Prog. 23.99 160.96 185.10 11.12 0.0 100.0 2.8
32.5 W T8 & 0.88 BF
Prog.
28.4 W T8 & 0.88 BF
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 61.19 178.88 234.11 N/A N/A N/A N/A
Prog.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.88 BF 75.27 178.88 240.22 -6.11 100.0 0.0 NER
Replacement. EL 1............... 90.0 Prog. 75.27 150.40 211.74 22.37 0.0 100.0 0.3
EL 2............... 93.0 32.5 W T8 & 0.72 BF 73.80 150.18 218.02 16.09 0.0 100.0 3.3
EL 2............... 95.4 Prog. 70.74 178.88 243.66 -9.55 100.0 0.0 NER
EL 2............... 95.4 26.6 W T8 & 0.88 BF 70.74 150.40 215.18 18.93 0.0 100.0 2.5
EL 2............... 96.0 Prog. 67.99 160.96 222.99 11.12 0.0 100.0 2.8
32.5 W T8 & 0.88 BF
Prog.
32.5 W T8 & 0.72 BF
Prog.
28.4 W T8 & 0.88 BF
Prog.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 63.98 178.88 236.52 N/A N/A N/A N/A
Renovation. Prog.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.88 BF 78.06 178.88 242.63 -6.11 100.0 0.0 NER
Purchase. EL 1............... 90.0 Prog. 78.06 150.40 214.15 22.37 0.0 100.0 0.3
EL 2............... 93.0 32.5 W T8 & 0.72 BF 76.59 150.18 220.43 16.09 0.0 100.0 3.3
EL 2............... 95.4 Prog. 73.53 178.88 246.06 -9.55 100.0 0.0 NER
EL 2............... 95.4 26.6 W T8 & 0.88 BF 73.53 150.40 217.59 18.93 0.0 100.0 2.5
EL 2............... 96.0 Prog. 70.79 160.96 225.40 11.12 0.0 100.0 2.8
32.5 W T8 & 0.88 BF
Prog.
32.5 W T8 & 0.72 BF
Prog.
28.4 W T8 & 0.88 BF
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.5--LCC and PBP Results for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-Cycle Cost Savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ Savings ---------------------- years
2012$ 2012$ 2012$ Net
Net Cost Benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 27.95 225.79 254.11 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.87 BF 55.06 225.79 261.52 -7.41 100.0 0.0 NER
EL 2............... 93.0 Inst. 53.17 188.99 242.52 11.58 0.2 99.8 3.3
EL 2............... 95.4 26.6 W T8 & 0.87 BF 47.05 225.79 273.20 -19.10 100.0 0.0 NER
EL 2............... 96.0 Inst. 41.56 202.80 244.72 9.39 0.0 100.0 2.9
32.5 W T8 & 0.87 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 86.30 223.94 287.56 N/A N/A N/A N/A
Inst.
[[Page 24145]]
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 113.40 202.45 273.49 14.07 0.0 100.0 0.5
Replacement. EL 2............... 93.0 Inst. 111.51 187.37 276.22 11.35 0.3 99.7 3.3
EL 2............... 95.4 26.6 W T8 & 0.87 BF 105.39 195.81 278.53 9.03 0.2 99.8 3.3
EL 2............... 96.0 Inst. 99.90 201.09 278.32 9.24 0.0 100.0 2.9
32.5 W T8 & 0.74 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 89.09 223.94 289.26 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 116.20 202.45 275.18 14.07 0.0 100.0 0.5
Purchase. EL 2............... 93.0 Inst. 114.31 187.37 277.91 11.35 0.3 99.7 3.3
EL 2............... 95.4 26.6 W T8 & 0.87 BF 108.19 195.81 280.23 9.03 0.2 99.8 3.3
EL 2............... 96.0 Inst. 102.70 201.09 280.02 9.24 0.0 100.0 2.9
32.5 W T8 & 0.74 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.6--LCC and PBP Results for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 27.95 354.89 383.16 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.89 BF 51.55 354.89 393.58 -10.42 100.0 0.0 NER
EL 2............... 93.0 Prog. 53.17 297.59 351.07 32.08 0.0 100.0 3.3
EL 2............... 95.4 26.6 W T8 & 0.89 BF 47.05 354.89 402.25 -19.10 100.0 0.0 NER
EL 2............... 96.0 Prog. 41.56 319.10 360.97 22.19 0.0 100.0 2.8
32.5 W T8 & 0.89 BF
Prog.
28.4 W T8 & 0.89 BF
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 88.14 354.89 434.98 N/A N/A N/A N/A
Prog.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.87 BF 111.73 339.09 429.60 5.38 0.4 99.6 1.0
Replacement. EL 2............... 93.0 Prog. 113.36 297.59 402.90 32.08 0.0 100.0 3.3
EL 2............... 95.4 26.6 W T8 & 0.89 BF 107.24 339.09 438.28 -3.29 81.9 18.1 9.0
EL 2............... 96.0 Prog. 101.75 304.62 398.32 36.66 0.0 100.0 2.0
32.5 W T8 & 0.87 BF
Prog.
28.4 W T8 & 0.87 BF
Prog.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 90.94 354.89 437.39 N/A N/A N/A N/A
Renovation. Prog.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.87 BF 114.53 339.09 432.01 5.38 0.4 99.6 1.0
Purchase. EL 2............... 93.0 Prog. 116.15 297.59 405.30 32.08 0.0 100.0 3.3
EL 2............... 95.4 26.6 W T8 & 0.89 BF 110.03 339.09 440.68 -3.29 81.9 18.1 9.0
EL 2............... 96.0 Prog. 104.54 304.62 400.73 36.66 0.0 100.0 2.0
32.5 W T8 & 0.87 BF
Prog.
28.4 W T8 & 0.87 BF
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24146]]
Table VII.7--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 10.48 46.85 57.34 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.87 BF 11.58 46.85 58.43 -1.09 100 0 NER
EL 2............... 93.0 Inst. 23.09 39.29 62.38 -5.05 94.8 5.2 17.6
EL 2............... 95.4 26.6 W T8 & 0.87 BF 20.03 46.85 66.88 -9.55 100 0 NER
EL 2............... 96.0 Inst. 17.29 42.13 59.41 -2.08 89.8 10.2 15.2
32.5 W T8 & 0.87 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 52.71 46.85 99.56 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.83 BF 53.80 44.48 98.28 1.28 1.1 98.9 4.9
Replacement. EL 2............... 93.0 Inst. 65.32 39.29 104.61 -5.05 94.8 5.2 17.6
EL 2............... 95.4 26.6 W T8 & 0.87 BF 62.26 44.48 106.73 -7.17 100 0 42.5
EL 2............... 96.0 Inst. 59.51 39.99 99.50 0.06 49 51 10.5
32.5 W T8 & 0.83 BF
Inst.
28.4 W T8 & 0.83 BF
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 55.51 46.85 102.36 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.83 BF 56.60 44.48 101.08 1.28 1.1 98.9 4.9
Purchase. EL 2............... 93.0 Inst. 68.11 39.29 107.40 -5.05 94.8 5.2 17.6
EL 2............... 95.4 26.6 W T8 & 0.87 BF 65.05 44.48 109.53 -7.17 100 0 42.5
EL 2............... 96.0 Inst. 62.31 39.99 102.30 0.06 49 51 10.5
32.5 W T8 & 0.83 BF
Inst.
28.4 W T8 & 0.83 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.8--LCC and PBP Results for a Two-Lamp 4-Foot 54 W T5 Miniature Bipin High Output System Operating in the Industrial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 18.58 181.10 199.85 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 26.60 181.10 207.87 -8.02 100.0 0.0 NER
EL 1.............. 102.0 49 W T5 & 1 BF Prog... 32.52 165.38 191.12 8.73 0.0 100.0 3.9
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 35.43 158.83 190.02 9.83 0.0 100.0 3.3
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 72.69 181.10 233.62 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 80.72 181.10 241.65 -8.02 100.0 0.0 NER
Replacement. EL 1.............. 102.0 49 W T5 & 1 BF Prog... 86.64 165.38 224.89 8.73 0.0 100.0 3.9
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 89.55 158.83 223.79 9.83 0.0 100.0 3.3
Event III: New Construction and Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 75.49 181.10 235.37 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 83.51 181.10 243.39 -8.02 100.0 0.0 NER
Purchase. EL 1.............. 102.0 49 W T5 & 1 BF Prog... 89.43 165.38 226.64 8.73 0.0 100.0 3.9
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 92.35 158.83 225.54 9.83 0.0 100.0 3.3
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24147]]
Table VII.9--LCC and PBP Results for a Two-Lamp 4-Foot 28 W T5 Miniature Bipin Standard Output System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 15.30 152.84 168.31 N/A N/A N/A N/A
Lamp Replacement...... EL 1............... 104.3 27.8 W T5 & 1 BF Prog 19.17 152.84 172.18 -3.87 100.0 0.0 NER
EL 2............... 109.7 27.8 W T5 & 1 BF Prog 21.52 152.84 174.54 -6.22 100.0 0.0 NER
EL 2............... 111.5 26 W T5 & 1 BF Prog.. 24.67 143.23 168.07 0.25 57.9 42.1 5.7
EL 2............... 116.0 25 W T5 & 1 BF Prog.. 27.41 137.88 162.64 5.68 0.2 99.8 4.8
Event II: Ballast Failure.......... Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 68.19 152.84 205.74 N/A N/A N/A N/A
Lamp & Ballast EL 1............... 104.3 27.8 W T5 & 0.85 BF 72.06 134.13 190.90 14.84 0.0 100.0 1.2
Replacement. EL 2............... 109.7 Prog. 74.41 134.13 193.25 12.49 0.0 100.0 2.0
EL 2............... 111.5 27.8 W T5 & 0.85 BF 77.56 125.79 188.05 17.69 0.0 100.0 2.0
EL 2............... 116.0 Prog. 80.30 121.15 183.32 22.42 0.0 100.0 2.2
26 W T5 & 0.85 BF
Prog.
25 W T5 & 0.85 BF
Prog.
Event III: New Construction and Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 70.99 152.84 207.72 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1............... 104.3 27.8 W T5 & 0.85 BF 74.86 134.13 192.88 14.84 0.0 100.0 1.2
Purchase. EL 2............... 109.7 Prog. 77.21 134.13 195.23 12.49 0.0 100.0 2.0
EL 2............... 111.5 27.8 W T5 & 0.85 BF 80.35 125.79 190.03 17.69 0.0 100.0 2.0
EL 2............... 116.0 Prog. 83.10 121.15 185.30 22.42 0.0 100.0 2.2
26 W T5 & 0.85 BF
Prog.
25 W T5 & 0.85 BF
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.10--LCC and PBP Results for a Two-Lamp 8-Foot 59 W T8 Single Pin Slimline System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 26.72 219.51 246.59 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 98.2 60.1 W T8 & 0.87 BF 29.40 219.51 249.27 -2.68 100.0 0.0 NER
EL 2............... 99.0 Inst. 34.52 219.51 254.39 -7.80 100.0 0.0 NER
EL 2............... 105.6 60.1 W T8 & 0.87 BF 43.51 208.16 252.02 -5.43 96.1 3.9 7.1
EL 2............... 108.0 Inst. 50.87 193.01 244.23 2.36 44.6 55.4 4.3
54 W T8 & 0.87 BF
Inst.
50 W T8 & 0.87 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 102.46 216.15 288.57 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 98.2 60.1 W T8 & 0.77 BF 105.14 193.01 268.11 20.46 0.0 100.0 0.6
Replacement. EL 2............... 99.0 Inst. 110.25 193.01 273.23 15.34 0.0 100.0 1.6
EL 2............... 105.6 60.1 W T8 & 0.77 BF 119.24 183.01 272.22 16.35 0.0 100.0 2.4
EL 2............... 108.0 Inst. 126.60 189.96 286.53 2.05 47.6 52.4 4.4
54 W T8 & 0.77 BF
Inst.
50 W T8 & 0.87 BF
Inst.
[[Page 24148]]
Event III: New Construction and Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 105.25 216.15 290.24 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 98.2 60.1 W T8 & 0.77 BF 107.93 193.01 269.78 20.46 0.0 100.0 0.6
Purchase. EL 2............... 99.0 Inst. 113.05 193.01 274.90 15.34 0.0 100.0 1.6
EL 2............... 105.6 60.1 W T8 & 0.77 BF 122.04 183.01 273.89 16.35 0.0 100.0 2.4
EL 2............... 108.0 Inst. 129.40 189.96 288.20 2.05 47.6 52.4 4.4
54 W T8 & 0.77 BF
Inst.
50 W T8 & 0.87 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.11--LCC and PBP Results for a Two-Lamp 8-Foot 86 W T8 Recessed Double Contact HO System Operating in the Industrial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 24.45 171.55 196.38 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 95.2 84 W T8 & 0.81 BF 34.01 171.55 205.94 -9.56 100.0 0.0 NER
EL 2............... 97.6 Inst. 41.22 171.55 213.15 -16.77 100.0 0.0 NER
84 W T8 & 0.81 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 100.34 171.55 233.59 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 95.2 84 W T8 & 0.81 BF 109.90 171.55 243.15 -9.56 100.0 0.0 NER
Replacement. EL 2............... 97.6 Inst. 117.11 171.55 250.36 -16.77 100.0 0.0 NER
84 W T8 & 0.81 BF
Inst.
Event III: New Construction and Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 103.14 171.55 234.96 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 95.2 84 W T8 & 0.81 BF 112.70 171.55 244.52 -9.56 100.0 0.0 NER
Purchase. EL 2............... 97.6 Inst. 119.91 171.55 251.73 -16.77 100.0 0.0 NER
84 W T8 & 0.81 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Incandescent Reflector Lamps
Table VII.12 through Table VII.15 present the commercial and
residential sector LCC results for the IRL representative product
class, the standard spectrum IRLs with diameters greater than 2.5
inches, input voltages less than 125 V.
[[Page 24149]]
Table VII.12--LCC and PBP Results for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 10.52 9.06 19.58 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 2500hrs, HIR.... 13.07 8.30 16.14 3.44 0.0 100.0 3.2
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.13--LCC and PBP Results for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 9.40 10.36 19.75 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 2500hrs, HIR.... 11.94 9.49 17.10 2.65 0.0 100.0 5.4
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.14--LCC and PBP Results for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 10.52 9.06 19.58 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 4200hrs, 14.94 8.30 13.64 5.94 0 100 5.6
New Lamp Purchase. Improved HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24150]]
Table VII.15--LCC and PBP Results for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 9.40 10.36 19.75 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 4200hrs, 13.81 9.49 15.26 4.49 0 100 9.4
New Lamp Purchase. Improved HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
b. Consumer Subgroup Analysis
Certain consumer subgroups may be disproportionately affected by
standards. Using the LCC spreadsheet model, DOE determined the impact
of the TSLs on the following consumer subgroups: low-income consumers
and institutions that serve low-income populations.
To reflect conditions faced by the identified subgroups, DOE
adjusted particular inputs to the LCC model. For low-income consumers,
DOE only used RECS data for consumers living below the poverty line.
For institutions serving low-income populations, DOE assumed that the
majority of these institutions are small nonprofits, and used a higher
discount rate of 9.6 percent (versus 5.1 percent for the main
commercial sector analysis). DOE found the differences between the LCC
and PBP results for the subgroups analyzed and the primary LCC and PBP
analysis to be minimal. See chapter 9 of the NOPR TSD further details
of the consumer subgroup analysis.
General Service Fluorescent Lamps
Table VII.16 through Table VII.24 below show the LCC impacts and
payback periods for the identified subgroups for GSFLs. Entries of
``NER'' indicate standard levels that do not reduce operating costs.
Table VII.16--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LCC experience period
lm/W cost cost 2012$ savings ---------------------- years
2012$ 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 17.19 102.28 119.60 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.88 BF 31.03 102.28 124.21 -4.61 100 0 NER
EL 2............... 93.0 Inst. 29.79 85.69 115.63 3.97 4.2 95.8 3.2
EL 2............... 95.4 26.6 W T8 & 0.88 BF 26.73 102.28 129.15 -9.55 100 0 NER
EL 2............... 96.0 Inst. 23.99 91.92 116.05 3.56 0 100 2.8
32.5 W T8 & 0.88 BF
Inst.
28.4 W T8 & 0.88 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 59.99 100.97 147.99 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 73.83 90.31 141.93 6.05 0 100 0.4
Replacement. EL 2............... 93.0 Inst. 72.59 84.55 144.18 3.81 6.6 93.4 3.3
EL 2............... 95.4 26.6 W T8 & 0.88 BF 69.53 88.37 144.93 3.06 3.6 96.4 3.2
EL 2............... 96.0 Inst. 66.79 89.15 142.97 5.02 0 100 2.4
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 62.78 100.97 149.93 N/A N/A N/A N/A
Renovation. Inst.
[[Page 24151]]
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 76.62 90.31 143.87 6.05 0 100 0.4
Purchase. EL 2............... 93.0 Inst. 75.39 84.55 146.12 3.81 6.6 93.4 3.3
EL 2............... 95.4 26.6 W T8 & 0.88 BF 72.33 88.37 146.87 3.06 3.6 96.4 3.2
EL 2............... 96.0 Inst. 69.58 89.15 144.91 5.02 0 100 2.4
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.17--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 17.19 146.45 163.74 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.88 BF 27.94 146.45 169.05 -5.31 100.0 0.0 NER
Prog.
EL 2............... 93.0 26.6 W T8 & 0.88 BF 29.79 122.95 152.85 10.89 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.88 BF 26.73 146.45 173.29 -9.55 100.0 0.0 NER
Prog.
EL 2............... 96.0 28.4 W T8 & 0.88 BF 23.99 131.77 155.87 7.87 0.0 100.0 2.8
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 61.19 146.45 203.56 N/A N/A N/A N/A
Prog.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.88 BF 71.94 146.45 208.87 -5.31 100.0 0.0 NER
Replacement. Prog.
EL 1............... 90.0 32.5 W T8 & 0.72 BF 71.94 123.13 185.56 18.01 0.0 100.0 0.3
Prog.
EL 2............... 93.0 26.6 W T8 & 0.88 BF 73.80 122.95 192.68 10.89 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.88 BF 70.74 146.45 213.11 -9.55 100.0 0.0 NER
Prog.
EL 2............... 95.4 32.5 W T8 & 0.72 BF 70.74 123.13 189.80 13.77 0.0 100.0 2.5
Prog.
EL 2............... 96.0 28.4 W T8 & 0.88 BF 67.99 131.77 195.69 7.87 0.0 100.0 2.8
Prog.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.88 BF 63.98 146.45 206.09 N/A N/A N/A N/A
Renovation. Prog.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.88 BF 74.73 146.45 211.40 -5.31 100.0 0.0 NER
Purchase. Prog.
EL 1............... 90.0 32.5 W T8 & 0.72 BF 74.73 123.13 188.09 18.01 0.0 100.0 0.3
Prog.
EL 2............... 93.0 26.6 W T8 & 0.88 BF 76.59 122.95 195.21 10.89 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.88 BF 73.53 146.45 215.64 -9.55 100.0 0.0 NER
Prog.
EL 2............... 95.4 32.5 W T8 & 0.72 BF 73.53 123.13 192.33 13.77 0.0 100.0 2.5
Prog.
EL 2............... 96.0 28.4 W T8 & 0.88 BF 70.79 131.77 198.22 7.87 0.0 100.0 2.8
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24152]]
Table VII.18--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 27.95 197.44 225.67 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.87 BF 51.18 197.44 233.62 -7.95 100.0 0.0 NER
Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 53.17 165.26 218.70 6.96 8.8 91.2 3.3
Inst.
EL 3............... 95.4 32.5 W T8 & 0.87 BF 47.05 197.44 244.76 -19.10 100.0 0.0 NER
Inst.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 41.56 177.33 219.17 6.50 0.1 99.9 2.9
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 86.30 195.81 264.52 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 109.52 177.03 253.68 10.84 0.0 100.0 0.5
Replacement. Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 111.51 163.84 257.76 6.76 9.4 90.6 3.3
Inst.
EL 2............... 95.4 32.5 W T8 & 0.74 BF 105.39 171.22 259.02 5.50 7.9 92.1 3.3
Inst.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 99.90 175.84 258.15 6.37 0.2 99.8 2.9
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 89.09 195.81 266.46 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.78 BF 112.32 177.03 255.62 10.84 0.0 100.0 0.5
Purchase. Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 114.31 163.84 259.70 6.76 9.4 90.6 3.3
Inst.
EL 2............... 95.4 32.5 W T8 & 0.74 BF 108.19 171.22 260.96 5.50 7.9 92.1 3.3
Inst.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 102.70 175.84 260.09 6.37 0.2 99.8 2.9
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.19--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 27.95 290.55 318.71 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.89 BF 46.06 290.55 327.82 -9.11 100.0 0.0 NER
Prog.
EL 2............... 93.0 26.6 W T8 & 0.89 BF 53.17 243.64 297.02 21.70 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.89 BF 47.05 290.55 337.81 -19.10 100.0 0.0 NER
Prog.
EL 2............... 96.0 28.4 W T8 & 0.89 BF 41.56 261.25 303.02 15.70 0.0 100.0 2.8
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 88.14 290.55 373.19 N/A N/A N/A N/A
Prog.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.87 BF 106.25 277.61 369.36 3.83 4.6 95.4 1.0
Replacement. Prog.
EL 2............... 93.0 26.6 W T8 & 0.89 BF 113.36 243.64 351.49 21.70 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.87 BF 107.24 277.61 379.35 -6.16 96.0 4.0 9.0
Prog.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 101.75 249.39 345.64 27.55 0.0 100.0 2.0
Prog.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.89 BF 90.94 290.55 375.72 N/A N/A N/A N/A
Renovation. Prog.
[[Page 24153]]
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.87 BF 109.04 277.61 371.89 3.83 4.6 95.4 1.0
Purchase. Prog.
EL 2............... 93.0 26.6 W T8 & 0.89 BF 116.15 243.64 354.02 21.70 0.0 100.0 3.3
Prog.
EL 2............... 95.4 32.5 W T8 & 0.87 BF 110.03 277.61 381.88 -6.16 96.0 4.0 9.0
Prog.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 104.54 249.39 348.17 27.55 0.0 100.0 2.0
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.20--LCC and PBP Subgroup Results for Low-Income Consumers for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 10.49 46.83 57.32 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 90.0 32.5 W T8 & 0.87 BF 11.59 46.83 58.42 -1.09 100 0 NER
Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 23.11 39.27 62.38 -5.06 94.9 5.1 17.6
Inst.
EL 2............... 95.4 32.5 W T8 & 0.87 BF 20.05 46.83 66.88 -9.56 100 0 NER
Inst.
EL 2............... 96.0 28.4 W T8 & 0.87 BF 17.30 42.11 59.41 -2.09 90.3 9.7 15.2
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 52.73 46.83 99.56 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.83 BF 53.82 44.45 98.28 1.28 1.1 98.9 4.9
Replacement. Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 65.35 39.27 104.62 -5.06 94.9 5.1 17.6
Inst.
EL 2............... 95.4 32.5 W T8 & 0.83 BF 62.29 44.45 106.74 -7.18 100 0 42.5
Inst.
EL 2............... 96.0 28.4 W T8 & 0.83 BF 59.54 39.97 99.51 0.05 49.9 50.1 10.5
Inst.
Event III: New Construction and Baseline.............. Baseline........... 89.2 32.5 W T8 & 0.87 BF 55.53 46.83 102.35 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 90.0 32.5 W T8 & 0.83 BF 56.62 44.45 101.07 1.28 1.1 98.9 4.9
Purchase. Inst.
EL 2............... 93.0 26.6 W T8 & 0.87 BF 68.14 39.27 107.41 -5.06 94.9 5.1 17.6
Inst.
EL 2............... 95.4 32.5 W T8 & 0.83 BF 65.08 44.45 109.54 -7.18 100 0 42.5
Inst.
EL 2............... 96.0 28.4 W T8 & 0.83 BF 62.33 39.97 102.30 0.05 49.9 50.1 10.5
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 24154]]
Table VII.21--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a Two-Lamp 4-Foot 54 W T5 Miniature Bipin High Output System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 83.6 53.8 W T5 & 1 BF Prog 18.57 219.84 238.55 N/A N/A N/A N/A
Lamp Replacement...... EL 1............... 92.9 53.8 W T5 & 1 BF Prog 26.59 219.84 246.57 -8.02 100.0 0.0 NER
EL 1............... 102.0 49 W T5 & 1 BF Prog.. 32.51 200.77 227.96 10.60 0.0 100.0 3.2
EL 1............... 102.1 47 W T5 & 1 BF Prog.. 35.42 192.81 224.90 13.65 0.0 100.0 2.7
Event II: Ballast Failure.......... Baseline.............. Baseline........... 83.6 53.8 W T5 & 1 BF Prog 72.68 219.84 276.70 N/A N/A N/A N/A
Lamp & Ballast EL 1............... 92.9 53.8 W T5 & 1 BF Prog 80.70 219.84 284.72 -8.02 100.0 0.0 NER
Replacement.
EL 1............... 102.0 49 W T5 & 1 BF Prog.. 86.62 200.77 266.11 10.60 0.0 100.0 3.2
EL 1............... 102.1 47 W T5 & 1 BF Prog.. 89.53 192.81 263.05 13.65 0.0 100.0 2.7
Event III: New Construction and Baseline.............. Baseline........... 83.6 53.8 W T5 & 1 BF Prog 75.47 219.84 278.68 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1............... 92.9 53.8 W T5 & 1 BF Prog 83.49 219.84 286.69 -8.02 100.0 0.0 NER
Purchase.
EL 1............... 102.0 49 W T5 & 1 BF Prog.. 89.41 200.77 268.08 10.60 0.0 100.0 3.2
EL 1............... 102.1 47 W T5 & 1 BF Prog.. 92.32 192.81 265.03 13.65 0.0 100.0 2.7
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.22--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a Two-Lamp 4-Foot 28 W T5 Miniature Bipin Standard Output System Operating in the Commercial
Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 15.30 130.31 145.74 N/A N/A N/A N/A
Lamp Replacement...... EL 1............... 104.3 27.8 W T5 & 1 BF Prog 19.17 130.31 149.61 -3.87 100.0 0.0 NER
EL 2............... 109.7 27.8 W T5 & 1 BF Prog 21.52 130.31 151.96 -6.22 100.0 0.0 NER
EL 2............... 111.5 26 W T5 & 1 BF Prog.. 24.67 122.12 146.91 -1.17 75.3 24.7 5.7
EL 2............... 116.0 25 W T5 & 1 BF Prog.. 27.41 117.56 142.99 2.75 11.4 88.6 4.8
Event II: Ballast Failure.......... Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 68.19 130.31 187.13 N/A N/A N/A N/A
Lamp & Ballast EL 1............... 104.3 27.8 W T5 & 0.85 BF 72.06 114.36 175.05 12.08 0.0 100.0 1.2
Replacement. Prog.
EL 2............... 109.7 27.8 W T5 & 0.85 BF 74.41 114.36 177.40 9.73 0.0 100.0 2.0
Prog.
EL 2............... 111.5 26 W T5 & 0.85 BF 77.56 107.25 173.43 13.70 0.0 100.0 2.0
Prog.
EL 2............... 116.0 25 W T5 & 0.85 BF 80.30 103.29 170.11 17.02 0.0 100.0 2.2
Prog.
Event III: New Construction and Baseline.............. Baseline........... 94.6 27.8 W T5 & 1 BF Prog 70.99 130.31 189.32 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1............... 104.3 27.8 W T5 & 0.85 BF 74.86 114.36 177.23 12.08 0.0 100.0 1.2
Purchase. Prog.
EL 2............... 109.7 27.8 W T5 & 0.85 BF 77.21 114.36 179.59 9.73 0.0 100.0 2.0
Prog.
EL 2............... 111.5 26 W T5 & 0.85 BF 80.35 107.25 175.62 13.70 0.0 100.0 2.0
Prog.
[[Page 24155]]
EL 2............... 116.0 25 W T5 & 0.85 BF 83.10 103.29 172.30 17.02 0.0 100.0 2.2
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.23--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a Two-Lamp 8-Foot 59 W T8 Single Pin Slimline System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 26.72 192.30 219.30 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 98.2 60.1 W T8 & 0.87 BF 29.40 192.30 221.98 -2.68 100.0 0.0 NER
Inst.
EL 2............... 99.0 60.1 W T8 & 0.87 BF 34.52 192.30 227.10 -7.80 100.0 0.0 NER
Inst.
EL 2............... 105.6 54 W T8 & 0.87 BF 43.51 182.36 226.14 -6.84 99.6 0.4 7.1
Inst.
EL 2............... 108.0 50 W T8 & 0.87 BF 50.87 169.08 220.23 -0.92 67.7 32.3 4.3
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 102.46 189.36 268.51 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1............... 98.2 60.1 W T8 & 0.77 BF 105.14 169.09 250.92 17.59 0.0 100.0 0.6
Replacement. Inst.
EL 2............... 99.0 60.1 W T8 & 0.77 BF 110.25 169.09 256.04 12.47 0.0 100.0 1.6
Inst.
EL 2............... 105.6 54 W T8 & 0.77 BF 119.24 160.33 256.27 12.24 0.0 100.0 2.4
Inst.
EL 2............... 108.0 50 W T8 & 0.87 BF 126.60 166.42 269.71 -1.20 68.7 31.3 4.4
Inst.
Event III: New Construction and Baseline.............. Baseline........... 96.5 60.1 W T8 & 0.87 BF 105.25 189.36 270.44 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 98.2 60.1 W T8 & 0.77 BF 107.93 169.09 252.84 17.59 0.0 100.0 0.6
Purchase. Inst.
EL 2............... 99.0 60.1 W T8 & 0.77 BF 113.05 169.09 257.96 12.47 0.0 100.0 1.6
Inst.
EL 2............... 105.6 54 W T8 & 0.77 BF 122.04 160.33 258.19 12.24 0.0 100.0 2.4
Inst.
EL 2............... 108.0 50 W T8 & 0.87 BF 129.40 166.42 271.64 -1.20 68.7 31.3 4.4
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.24--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a Two-Lamp 8-Foot 86 W T8 Recessed Double Contact HO System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 24.45 214.21 238.99 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1............... 95.2 84 W T8 & 0.81 BF 34.00 214.21 248.54 -9.56 100.0 0.0 NER
Inst.
EL 2............... 97.6 84 W T8 & 0.81 BF 41.21 214.21 255.75 -16.76 100.0 0.0 NER
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 100.33 214.21 280.62 N/A N/A N/A N/A
Inst.
[[Page 24156]]
Lamp & Ballast EL 1............... 95.2 84 W T8 & 0.81 BF 109.89 214.21 290.18 -9.56 100.0 0.0 NER
Replacement. Inst.
EL 2............... 97.6 84 W T8 & 0.81 BF 117.09 214.21 297.38 -16.76 100.0 0.0 NER
Inst.
Event III: New Construction and Baseline.............. Baseline........... 92.0 84 W T8 & 0.81 BF 103.13 214.21 282.16 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1............... 95.2 84 W T8 & 0.81 BF 112.68 214.21 291.71 -9.56 100.0 0.0 NER
Purchase. Inst.
EL 2............... 97.6 84 W T8 & 0.81 BF 119.89 214.21 298.92 -16.76 100.0 0.0 NER
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Incandescent Reflector Lamps
Table VII.25 through Table VII.28 below show the LCC impacts and
payback periods for the identified subgroups for IRLs.
Table VII.25--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 10.52 8.68 19.21 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 2500hrs, HIR.... 13.07 7.96 15.80 3.41 0.0 100.0 3.2
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.26--LCC and PBP Subgroup Results for Low-Income Consumers for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 9.40 10.21 19.62 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
[[Page 24157]]
Lamp Replacement or EL 1............... 18.5 55W, 2500hrs, HIR.... 11.95 9.36 16.98 2.64 0.0 100.0 5.5
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.27--LCC and PBP Subgroup Results for Institutions Serving Low Income Populations for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 10.52 8.68 19.21 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 4200hrs, 14.94 7.96 13.30 5.91 0.0 100.0 5.6
New Lamp Purchase. Improved HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.28--LCC and PBP Subgroup Results for Low-Income Consumers for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Lamp option Installed Discounted LCC experience period
lm/W cost operating LCC 2012$ savings ---------------------- years
2012$ cost 2012$ 2012$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline........... 17.8 60W, 1500hrs, 9.40 10.21 19.62 N/A N/A N/A N/A
III: New Construction and Improved Halogen.
Renovation.
Lamp Replacement or EL 1............... 18.5 55W, 4200hrs, 13.82 9.36 15.13 4.48 0 100 9.5
New Lamp Purchase. Improved HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
c. Rebuttable Presumption Payback
EPCA establishes a rebuttable presumption that an energy
conservation standard is economically justified if the increased
purchase cost for a product that meets the standard is less than three
times the value of the first-year energy savings resulting from the
standard. DOE's LCC and PBP analyses generate values that calculate the
payback period for consumers of potential energy conservation
standards, which include, but are not limited to, the 3-year payback
period contemplated under the rebuttable presumption test. However, DOE
routinely conducts a full economic analysis that considers the full
range of impacts--including those on consumers, manufacturers, the
nation, and the environment--as required under 42 U.S.C.
6295(o)(2)(B)(i). The results of this analysis serve as the basis for
DOE to evaluate the economic justification for a potential standard
level (thereby supporting or rebutting the results of
[[Page 24158]]
any preliminary determination of economic justification).
Table VII.29 shows the GSFL payback periods that are less than 3
years for the most common sector for each product class. There are no
IRL payback periods less than 3 years.
Table VII.29--GSFL Efficacy Levels With Rebuttable Payback Period Less Than Three Years
--------------------------------------------------------------------------------------------------------------------------------------------------------
Mean
Efficacy Rated lamp payback
Lamp description Sector Event Response level efficacy Design option period
lm/W years
--------------------------------------------------------------------------------------------------------------------------------------------------------
2-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.88 BF 2.8
Instant Start. Failure. Inst.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.4
Failure. Replacement. Inst.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.4
Inst.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.4
Construction and Purchase. Inst.
Renovation.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.4
Inst.
2-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.88 BF 2.8
Programmed Start. Failure. Prog.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.72 BF 0.3
Failure. Replacement. Prog.
EL 2 95.4 32.5 W T8 & 0.72 BF 2.5
Prog.
EL 2 96.0 28.4 W T8 & 0.88 BF 2.8
Prog.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.72 BF 0.3
Construction and Purchase. Prog.
Renovation.
EL 2 95.4 32.5 W T8 & 0.72 BF 2.5
Prog.
EL 2 96.0 28.4 W T8 & 0.88 BF 2.8
Prog.
4-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.87 BF 2.9
Instant Start. Failure. Inst.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.5
Failure. Replacement. Inst.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.9
Inst.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.5
Construction and Purchase. Inst.
Renovation.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.9
Inst.
4-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.89 BF 2.8
Programmed Start. Failure. Prog.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.87 BF 1.0
Failure. Replacement. Prog.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.0
Prog.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.87 BF 1.0
Construction and Purchase. Prog.
Renovation.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.0
Prog.
T5 Miniature Bipin Standard Commercial......... Event II: Ballast Lamp & Ballast EL 1 104.3 27.8 W T5 & 0.85 BF 1.2
Output. Failure. Replacement. Prog.
[[Page 24159]]
EL 2 109.7 27.8 W T5 & 0.85 BF 2.0
Prog.
EL 2 111.5 26 W T5 & 0.85 BF 2.0
Prog.
EL 2 116.0 25 W T5 & 0.85 BF 2.2
Prog.
Event III: New New Lamp & Ballast EL 1 104.3 27.8 W T5 & 0.85 BF 1.2
Construction and Purchase. Prog.
Renovation.
EL 2 109.7 27.8 W T5 & 0.85 BF 2.0
Prog.
EL 2 111.5 26 W T5 & 0.85 BF 2.0
Prog.
EL 2 116.0 25 W T5 & 0.85 BF 2.2
Prog.
T8 Single Pin Slimline.......... Commercial......... Event II: Ballast Lamp & Ballast EL 1 98.2 60.1 W T8 & 0.77 BF 0.6
Failure. Replacement. Prog.
EL 2 99.0 60.1 W T8 & 0.77 BF 1.6
Prog.
EL 2 105.6 54 W T8 & 0.77 BF 2.4
Prog.
Event III: New New Lamp & Ballast EL 1 98.2 60.1 W T8 & 0.77 BF 0.6
Construction and Purchase. Prog.
Renovation.
EL 2 99.0 60.1 W T8 & 0.77 BF 1.6
Prog.
EL 2 105.6 54 W T8 & 0.77 BF 2.4
Prog.
--------------------------------------------------------------------------------------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed MIAs to estimate the impact of amended energy
conservation standards on manufacturers of GSFLs and IRLs. The section
below describes the expected impacts on GSFL and IRL manufacturers at
each TSL. Chapter 13 of the NOPR TSD explains the MIA in further
detail.
a. Industry Cash-Flow Analysis Results
The tables below depict the financial impacts (represented by
changes in INPV) of amended energy standards on GSFL and IRL
manufacturers as well as the conversion costs that DOE estimates GSFL
and IRL manufacturers would incur at each TSL. DOE breaks out the
impacts on GSFL and IRL manufacturers separately. To evaluate the range
of cash flow impacts on the GSFL and IRL industries, DOE modeled two
markup scenarios that correspond to the range of anticipated market
responses to amended standards. Each scenario results in a unique set
of cash flows and corresponding industry values at each TSL.
In the following discussion, the INPV results refer to the
difference in industry value between the base case and the standards
case that result from the sum of discounted cash flows from the base
year (2013) through the end of the analysis period. The results also
discuss the difference in cash flows between the base case and the
standards case in the year before the compliance date for amended
energy conservation standards. This figure represents the size of the
required conversion costs relative to the cash flow generated by the
GSFL and IRL industries in the absence of amended energy conservation
standards.
Cash-Flow Analysis Results by TSL for General Service Fluorescent Lamps
To assess the upper (less severe) end of the range of potential
impacts on GSFL manufacturers, DOE modeled a flat, or preservation of
gross margin, markup scenario. This scenario assumes that in the
standards case, manufacturers would be able to pass along all the
higher production costs required for more efficacious products to their
consumers. Specifically, the industry would be able to maintain its
average base case gross margin (as a percentage of revenue) despite the
higher product costs in the standards case. In general, the larger the
product price increases, the less likely manufacturers are to achieve
the cash flow from operations calculated in this scenario because it is
less likely that manufacturers would be able to fully mark up these
larger cost increases.
[[Page 24160]]
To assess the lower (more severe) end of the range of potential
impacts on the GSFL manufacturers, DOE modeled the preservation of
operating profit markup scenario. This scenario represents the lower
end of the range of potential impacts on manufacturers because no
additional operating profit is earned on the higher production costs,
eroding profit margins as a percentage of total revenue.
Table VII.30 and Table VII.31 present the projected results for
GSFLs under the flat and preservation of operating profit markup
scenarios. DOE examined results for all five product classes (4-foot
MBP, 8-foot SP slimline, 8-foot RDC HO, 4-foot T5 MiniBP SO, and 4-foot
T5 MiniBP HO) together.
Table VII.30--Manufacturer Impact Analysis for General Service Fluorescent Lamps--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 1,542.5 1,584.4 1,580.3 1,663.1 1,901.1 1,939.7
Change in INPV................................ (2012$ millions)................ .......... 41.8 37.8 120.5 358.5 397.1
(%)............................. .......... 2.7% 2.5% 7.8% 23.2% 25.7%
Product Conversion Costs...................... (2012$ millions)................ .......... 0.9 2.0 5.3 7.5 9.1
Capital Conversion Costs...................... (2012$ millions)................ .......... 1.0 11.0 3.0 5.5 29.5
Total Conversion Costs........................ (2012$ millions)................ .......... 1.9 13.0 8.3 13.0 38.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.31--Manufacturer Impact Analysis for General Service Fluorescent Lamps--Preservation of Operating Profit Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 1,542.5 1,541.7 1,533.4 1,531.0 1,519.6 1,502.6
Change in INPV................................ (2012$ millions)................ .......... (0.9) (9.2) (11.5) (22.9) (39.9)
(%)............................. .......... -0.1% -0.6% -0.7% -1.5% -2.6%
Product Conversion Costs...................... (2012$ millions)................ .......... 0.9 2.0 5.3 7.5 9.1
Capital Conversion Costs...................... (2012$ millions)................ .......... 1.0 11.0 3.0 5.5 29.5
Total Conversion Costs........................ (2012$ millions)................ .......... 1.9 13.0 8.3 13.0 38.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 1 sets the efficacy level at baseline for two product classes
(4-foot MBP and 8-foot SP slimline) and EL 1 for three product classes
(8-foot RDC HO, 4-foot T5 MiniBP SO, and 4-foot T5 MiniBP HO). EL 1 for
the 4-foot T5 MiniBP HO product class represents the max tech efficacy
level. At TSL 1, DOE estimates impacts on INPV range from $41.8 million
to -$0.9 million, or a change in INPV of 2.7 percent to -0.1 percent.
At TSL 1, industry free cash flow (operating cash flow minus capital
expenditures) is estimated to decrease by approximately 0.5 percent to
$156.9 million, compared to the base case value of $157.7 million in
2016, the year leading up to proposed energy conservation standards.
Percentage impacts on INPV are slightly positive to slightly
negative at TSL 1. DOE does not anticipate that manufacturers would
lose a significant portion of their INPV at this TSL. This is because
the vast majority of shipments already meets or exceeds the efficacy
levels prescribed at TSL 1. DOE projects that in the expected year of
compliance (2017), 100 percent of 4-foot MBP and 8-foot SP slimline
shipments would meet or exceed the efficacy levels at TSL 1. DOE
estimates that these lamps account for 88 percent of GSFL shipments in
2017. Meanwhile, in 2017, 33 percent of 8-foot RDC HO shipments, 45
percent of 4-foot T5 MiniBP SO, and 37 percent of 4-foot T5 MiniBP HO
shipments would meet the efficacy levels at TSL 1. Because these
products comprise a very small percentage of total GSFL shipments in
2017, a very small percentage of total GSFL shipments would need to be
converted at TSL 1 to meet these efficacy standards.
DOE expects conversion costs to be small compared to the industry
value because most of the GSFL shipments, on a total volume basis,
already meet or exceed the efficacy levels analyzed at this TSL. DOE
expects GSFL manufacturers to incur $0.9 million in product conversion
costs for lamp redesign and testing. DOE estimates manufacturers will
have minimal capital conversion costs associated with TSL 1, as most
efficacy gains will be achieved through increasing the amount of REOs
used to coat the lamps, not through any major equipment upgrades or
capital investments. DOE expects $1 million in capital conversion costs
for manufacturers to upgrade and recalibrate production line
automation.
At TSL 1, under the flat markup scenario, the shipment-weighted
average MPC increases by approximately 5 percent relative to the base
case MPC. Manufacturers are able to fully pass on this cost increase to
consumers by design in this markup scenario. This slight price increase
would mitigate the $1.9 million in conversion costs estimated at TSL 1,
resulting in slightly positive INPV impacts at TSL 1 under the flat
markup scenario.
Under the preservation of operating profit markup scenario,
manufacturers earn the same operating profit as would be earned in the
base case, but manufacturers do not earn additional profit from their
investments. The 5 percent MPC increase is slightly outweighed by a
lower average markup of 1.51 (compared to the flat markup of 1.52) and
$1.9 million in conversion costs, resulting in small negative impacts
at TSL 1.
TSL 2 sets the efficacy level at baseline for one product class (4-
foot MBP), EL 1 for three product classes (8-foot SP slimline, 4-foot
T5 MiniBP SO, and 4-foot T5 MiniBP HO), and EL 2 for one product class
(8-foot RDC HO). EL 1 for the 4-foot T5 MiniBP HO product class and EL
2 for the 8-foot RDC HO product class represent the max tech efficacy
levels. At TSL 2, DOE estimates
[[Page 24161]]
impacts on INPV to range from $37.8 million to -$9.2 million, or a
change in INPV of 2.5 percent to -0.6 percent. At this proposed level,
industry free cash flow is estimated to decrease by approximately 4
percent to $152.1 million, compared to the base case value of $157.7
million in 2016.
Percentage impacts on INPV are slightly positive to slightly
negative at TSL 2. DOE does not anticipate that manufacturers would
lose a significant portion of their INPV at this TSL because the vast
majority of shipments already meets or exceeds the efficacy levels
prescribed at TSL 2. DOE projects that in 2017, 100 percent of 4-foot
MBP shipments would meet or exceed the efficacy levels at TSL 2. DOE
estimates that shipments of this product classes will comprise 86
percent of GSFL shipments in 2017. Meanwhile, in 2017, 57 percent of 8-
foot SP slimline lamps shipments, 10 percent of 8-foot RDC HO
shipments, 45 percent of 4-foot T5 MiniBP SO, and 37 percent of 4-foot
T5 MiniBP HO shipments would meet or exceed the efficacy levels at TSL
2.
DOE expects conversion costs to be small compared to the industry
value because most of the GSFL shipments, on a total volume basis,
already meet or exceed the efficacy levels analyzed at this TSL. DOE
expects that product conversion costs will rise from $0.9 million at
TSL 1 to $2.0 million at TSL 2 for lamp redesign and testing. Capital
conversion costs will increase from $1.0 million at TSL 1 to $11.0
million at TSL 2. This is driven by the fact that both 8-foot product
classes would have to meet higher efficacy levels at this TSL. DOE
believes this will result in higher capital conversion costs related to
upgrading and recalibrating production line automation.
At TSL 2, under the flat markup scenario, the shipment-weighted
average MPC increases by 5 percent relative to the base case MPC. In
this scenario, INPV impacts are slightly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $13.0 million in conversion costs. Under the preservation
of operating profit markup scenario, the 5 percent MPC increase is
slightly outweighed by a lower average markup of 1.51 (compared to the
flat markup of 1.52) and $13.0 million in conversion costs, resulting
in slightly negative impacts at TSL 2.
TSL 3 sets the efficacy level at baseline for one product class (8-
foot SP slimline) and EL 1 for four product classes (4-foot MBP, 8-foot
RDC HO, 4-foot T5 MiniBP SO, and 4-foot T5 MiniBP HO). EL 1 for the 4-
foot T5 MiniBP HO product class represents the max tech efficacy level.
At TSL 3, DOE estimates impacts on INPV to range from $120.5 million to
-$11.5 million, or a change in INPV of 7.8 percent to -0.7 percent. At
this proposed level, industry free cash flow is estimated to decrease
by approximately 2 percent to $154.7 million, compared to the base case
value of $157.7 million in 2016.
While more significant than the impacts at TSL 2, the impacts on
INPV at TSL 3 are still relatively minor compared to the total industry
value. Percentage impacts on INPV are slightly positive to slightly
negative at TSL 3. DOE does not anticipate that manufacturers would
lose a significant portion of their INPV TSL 3. While less than the
previous TSLs, a large percentage of total shipments still already meet
or exceed the efficacy levels prescribed at TSL 3. DOE projects that in
2016, 56 percent of the 4-foot MBP, 100 percent of 8-foot SP slimline,
33 percent of 8-foot RDC HO shipments, 45 percent of 4-foot T5 MiniBP
SO, and 37 percent of 4-foot T5 MiniBP HO shipments would meet or
exceed the efficacy levels at TSL 3.
DOE expects conversion costs to remain small at TSL 3 compared to
the industry value because a significant percentage of the GSFL
shipments, on a total volume basis, already meet or exceed the efficacy
levels proposed at this TSL. TSL 3 is the first TSL that increases the
efficacy requirement for 4-foot MBP, which as previously noted,
comprise a large majority of GSFL shipments. Efficacy gains for these
products, however, would likely be achieved with additional REOs, which
would not require any significant capital investments. At TSL 3, DOE
expects product conversion costs to increase from TSL 2 to $5.3
million. DOE, however, estimates that capital conversion costs will
decrease from TSL 2 to $3.0 million at TSL 3 since no amended efficacy
standards would be set at TSL 3 for 8-foot SP slimline products and the
8-foot RDC HO product class has a lower EL at TSL 3 than at TSL 2. The
lower ELs for these two product classes outweigh the increase in EL of
the 4-ft MBP product class and would cause manufacturers to invest less
in capital conversion costs at TSL 3 than at TSL 2.
At TSL 3, under the flat markup scenario, the shipment-weighted
average MPC increases by 16 percent relative to the base case MPC. In
this scenario, INPV impacts are slightly positive because
manufacturers' ability to pass the higher production costs to consumers
outweighs the $8.3 million in conversion costs. Under the preservation
of operating profit markup scenario, the 16 percent MPC increase is
slightly outweighed by a lower average markup of 1.51 (compared to the
flat markup scenario markup of 1.52) and $8.3 million in conversion
costs, resulting in negative impacts at TSL 3.
TSL 4 sets the efficacy level at baseline for one product class (8-
foot SP slimline), EL 1 for three product classes (8-foot RDC HO, 4-
foot T5 MiniBP SO, and 4-foot T5 MiniBP HO), and EL 2 for one product
class (4-foot MBP). EL 1 for the 4-foot T5 MiniBP HO product class and
EL 2 for the 4-foot MBP product class represent the max tech efficacy
levels. At TSL 4, DOE estimates impacts on INPV to range from $358.5
million to -$22.9 million, or a change in INPV of 23.2 percent to -1.5
percent. At this proposed level, industry free cash flow is estimated
to decrease by approximately 3 percent to $152.9 million, compared to
the base case value of $157.7 million in the year leading up to energy
conservation standards.
Percentage impacts on INPV are moderately positive to slightly
negative at TSL 4. DOE projects that in 2017, 21 percent of 4-foot MBP,
100 percent of 8-foot SP slimline, 33 percent of 8-foot RDC HO
shipments, 45 percent of 4-foot T5 MiniBP SO, and 37 percent of 4-foot
T5 MiniBP HO shipments would meet or exceed the efficacy levels at TSL
4.
While DOE expects conversion costs to increase from TSL 3 to TSL 4,
DOE estimates the costs will still be small compared to the total
industry value. DOE expects product conversion costs for GSFL
manufacturers to increase from $5.3 million at TSL 3 to $7.5 million at
TSL 4. DOE expects capital conversion costs to increase from $3.0
million at TSL 3 to $5.5 million at TSL 4. While a higher percentage of
shipments would need to be converted to meet the efficacy requirements
at TSL 4, increasing the efficacy of GSFLs will not likely be a very
capital-intensive process. Instead, increasing GSFL efficacy will
likely be more focused around increasing the amount of REOs in the
lamps.
At TSL 4, under the flat markup scenario the shipment-weighted
average MPC increases by 52 percent relative to the base case MPC. In
this scenario, INPV impacts are slightly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $13.0 million in conversion costs. Under the preservation
of operating profit markup scenario, the 52 percent MPC increase is
slightly outweighed by a lower average markup of 1.51 (compared to the
flat markup scenario markup of 1.52) and $13.0 million in conversion
costs, resulting in negative impacts at TSL 4.
[[Page 24162]]
TSL 5 sets the efficacy level at max tech for all product classes.
This represents EL 1 for one product class (4-foot T5 MiniBP HO) and EL
2 for five product classes (4-foot MBP, 8-foot SP slimline, 8-foot RDC
HO, and 4-foot T5 MiniBP SO). At TSL 5, DOE estimates impacts on INPV
to range from $397.1 million to -$39.9 million, or a change in INPV of
25.7 percent to -2.6 percent. At this proposed level, industry free
cash flow is estimated to decrease by approximately 10 percent to
$143.4 million, compared to the base case value of $157.7 million in
2016.
Percentage impacts on INPV are significantly positive to slightly
negative at TSL 5. DOE projects that in 2017, 21 percent of the 4-foot
MBP, 25 percent of 8-foot SP slimline, 10 percent of 8-foot RDC HO
shipments, 14 percent of 4-foot T5 MiniBP SO, and 37 percent of 4-foot
T5 MiniBP HO shipments would meet the efficacy levels at TSL 5.
DOE expects conversion costs to increase from TSL 4 to TSL 5 due to
the 8-foot slimline, 8-foot RDC HO, and 4-foot T5 MiniBP HO product
classes moving to max tech ELs at TSL 5. DOE estimates that capital
conversion costs will be $29.5 million at TSL 5 as a result of
manufacturers having to upgrade all of their production lines to
manufacture max tech products. DOE expects GSFL manufacturers to incur
$9.1 million in product conversion costs for lamp redesigns and
testing. However, these larger total conversion costs at TSL 5, $38.6
million remain relatively small compared to the almost $2 billion total
GSFL industry value at TSL 5.
At TSL 5, under the flat markup scenario, the shipment-weighted
average MPC increases by 57 percent relative to the base case MPC. In
this scenario, INPV impacts are slightly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $38.6 million in conversion costs. Under the preservation
of operating profit markup scenario, the 57 percent MPC increase is
slightly outweighed by a lower average markup of 1.51 (compared to the
flat markup scenario markup of 1.52) and $38.6 million in conversion
costs, resulting in negative impacts at TSL 5.
Cash Flow Analysis Results by TSL for Incandescent Reflector Lamps
DOE incorporated the same markup scenarios to represent the upper
and lower bounds of industry impacts for IRLs as was done for GSFLs:
the flat, or preservation of gross margin, markup scenario and the
preservation of operating profit markup scenario. DOE, however,
analyzed one TSL for IRLs in addition to the baseline levels. DOE also
analyzed an alternative shipment scenario for IRLs, the shortened
lifetime scenario, in addition to the reference case. DOE acknowledges
that to meet the proposed IRL energy conservation standards, IRL
manufacturers may choose to shorten the lifetime of some of their IRLs,
rather than make the investments to increase the efficacy of the lamps.
DOE presents the results of this analysis in appendix 13C of the NOPR
TSD.
Table VII.32 and Table VII.33 present the projected results for
IRLs under the flat and preservation of operating profit scenarios. DOE
examined results for one representative product class for IRLs.
Table VII.32--Manufacturer Impact Analysis for Incandescent Reflector Lamps--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard
Units Base case level 1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 176.0 128.6
Change in INPV................................ (2012$ millions)................ .............. (47.5)
(%)............................. .............. -27.0%
Product Conversion Costs...................... (2012$ millions)................ .............. 6.1
Capital Conversion Costs...................... (2012$ millions)................ .............. 65.4
Total Conversion Costs........................ (2012$ millions)................ .............. 71.5
----------------------------------------------------------------------------------------------------------------
Table VII.33--Manufacturer Impact Analysis for Incandescent Reflector Lamps--Preservation of Operating Profit
Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard
Units Base case level 1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2012$ millions)................ 176.0 124.2
Change in INPV................................ (2012$ millions)................ .............. (51.8)
(%)............................. .............. -29.5%
Product Conversion Costs...................... (2012$ millions)................ .............. 6.1
Capital Conversion Costs...................... (2012$ millions)................ .............. 65.4
Total Conversion Costs........................ (2012$ millions)................ .............. 71.5
----------------------------------------------------------------------------------------------------------------
TSL 1 sets the efficacy level at EL 1, max tech, for the IRL
representative unit. At TSL 1, DOE estimates impacts on INPV to range
from -$47.5 million to -$51.8 million, or a change in INPV of -27.0
percent to -29.5 percent. At TSL 1, industry free cash flow is
estimated to decrease by approximately 131 percent to -7.5 million,
compared to the base case value of $23.8 million in 2016.
INPV impacts are negative at TSL 1 regardless of the markup
scenario chosen. DOE estimates that in 2017, 41 percent of IRL
shipments would meet the efficacy requirements proposed at TSL 1. The
majority of shipments would need to be converted to meet the standards
proposed at this TSL.
DOE expects substantial conversion costs for IRL manufacturers at
TSL 1 associated with increasing the efficacy of IRLs. Manufacturers
would have to invest in retooling burner machines, increasing coating
capacity, and upgrading their production lines to allow for enhanced
reflector coating. Some manufacturers expressed concern that they do
not currently possess the technology required at the analyzed standard
level and could exit the market entirely. Overall, DOE expects these
capital conversion costs to total $65.4 million for the industry. DOE
estimates that IRL manufacturers will also incur
[[Page 24163]]
$6.1 million in product conversion costs for lamp and production line
redesign, as well as testing and certification.
At TSL 1, under the flat markup scenario, the shipment-weighted
average MPC increases by 13 percent relative to the base case MPC. In
this scenario, INPV impacts are negative because the manufacturers'
ability to pass the higher production costs to consumers does not
outweigh $71.5 million in conversion costs. Under the preservation of
operating profit markup scenario, the 13 percent MPC increase is
outweighed by a lower average markup of 1.50 (compared to the flat
markup scenario markup of 1.52) and $71.5 million in conversion costs,
resulting in negative impacts at TSL 1. The significant capital and
product conversion costs that IRL manufacturers must make at TSL 1
cause INPV to be negative regardless of the markup chosen.
DOE also analyzed a shortened lifetime sensitivity scenario where
manufacturers shorten the lifetime of IRLs to mitigate the costs of
complying with the proposed standard. By shortening the lifetime of
IRLs manufacturers reduce the capital conversion costs they must make
to comply with the proposed standard. DOE presents the INPV results of
this analysis in appendix 13C of this NOPR TSD. DOE requests comment on
the $6.1 product conversion costs and $65.4 capital conversion costs
necessary for manufacturers to comply with the proposed standards.
b. Impacts on Employment
DOE quantitatively assessed the impacts of potential amended energy
conservation standards on direct employment. DOE used the GRIM to
estimate the domestic labor expenditures and number of domestic
production workers in the base case and at each TSL from 2013 to 2046.
DOE used statistical data from the U.S. Census Bureau's 2011 Annual
Survey of Manufacturers (ASM), the results of the engineering analysis,
and interviews with manufacturers to determine the inputs necessary to
calculate industry-wide labor expenditures and domestic employment
levels. Labor expenditures involved with the manufacture of the product
are a function of the labor intensity of the product, the sales volume,
and an assumption that wages remain fixed in real terms over time.
In the GRIM, DOE used the labor content of each product and the
manufacturing production costs to estimate the annual labor
expenditures in the industry. DOE used census data and interviews with
manufacturers to estimate the portion of the total labor expenditures
that is attributable to domestic labor.
The production worker estimates in this section cover only workers
up to the line-supervisor level directly involved in fabricating and
assembling a product within a manufacturing facility. Workers
performing services that are closely associated with production
operations, such as material handing with a forklift, are also included
as production labor. DOE's estimates account for production workers who
manufacture only the specific products covered of this rulemaking. For
example, a worker on a fluorescent lamp ballast production line would
not be included with the estimate of the number of GSFL or IRL workers.
The employment impacts shown in Table VII.34 and Table VII.35 below
represent the potential production employment that could result
following amended energy conservation standards. The upper bound of the
results estimates the maximum change in the number of production
workers that could occur after compliance with amended energy
conservation standards when assuming that manufacturers continue to
produce the same scope of covered products in the same production
facilities. It also assumes that domestic production does not shift to
lower labor-cost countries. Because there is a real risk of
manufacturers evaluating sourcing decisions in response to amended
energy conservation standards, the lower bound of the employment
results includes the estimated total number of U.S. production workers
in the industry who could lose their jobs if some or all existing
production were moved outside of the United States. While the results
present a range of employment impacts following 2017, the sections
below also include qualitative discussions of the likelihood of
negative employment impacts at the various TSLs. Finally, the
employment impacts shown are independent of the employment impacts from
the broader U.S. economy, documented in chapter 17 of the NOPR TSD. DOE
seeks comment on the potential domestic employment impacts to GSFL and
IRL manufacturers at the proposed efficacy levels.
Employment Impacts for General Service Fluorescent Lamps
Using 2011 ASM data and interviews with manufacturers, DOE
estimates that approximately three quarters of the GSFLs sold in the
United States are manufactured domestically. With this assumption, DOE
estimates that in the absence of amended energy conservation standards,
there would be approximately 1,800 domestic production workers involved
in manufacturing GSFLs in 2017. The table below shows the range of the
impacts of potential amended energy conservation standards on U.S.
production workers in the GSFL industry.
Table VII.34--Potential Changes in the Total Number of Domestic General Service Fluorescent Lamp Production Workers in 2017
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Base case --------------------------------------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total Number of Domestic Production Workers in 2017 (without 1,848 1,848 1,847 1,844 1,814 1,817
changes in production locations)................................
Potential Changes in Domestic Production Workers in 2017 *....... ........... 0 (1) (4)-(1,848) (34)-(1,848) (31)-(1,848)
--------------------------------------------------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
At the upper end of the range, all examined TSLs show slight
negative impacts on domestic employment levels. DOE believes that
manufacturers could face slight negative impacts on domestic employment
levels because there would be an increase in the shipments of products
typically not manufactured domestically, such as 4-foot T5 MiniBP
lamps, and a decrease of products typically manufactured domestically,
such as 4-foot MBP lamps.
[[Page 24164]]
Several manufacturers emphasized that it is difficult to predict
employment impacts of energy conservation standards. One potential
uncertainty is the future price of REOs and these employment decisions
become more complex when more REOs are required for higher efficacious
products.
DOE does not expect any significant changes in domestic employment
at TSLs 1 or 2 because standards would not be amended for 4-foot MBP
lamps, which comprise approximately 86 percent of GSFL shipments in
2017. While DOE does not anticipate the entire, or even a large portion
of, domestic employment to move abroad at TSLs 3, 4 or 5, DOE
acknowledges that there could be a loss of domestic employment at these
TSLs due to the required increase in efficacy of 4-foot MBP lamps. The
potential loss of domestic employment would most likely be a result of
a possible increase in the price of REOs. Based on the REO prices
modeled in the reference case, DOE does not estimate a significant loss
of domestic employment at TSLs 3, 4, or 5. Overall, manufacturers were
uncertain about how amended energy conservation standards would affect
domestic employment and sourcing decisions. Ultimately, both employment
and sourcing decisions could be determined by the stability and
predictability of REO prices.
Employment Impacts for Incandescent Reflector Lamps
Using 2011 ASM data and interviews with manufacturers, DOE
estimates that approximately half of the IRLs sold in the United States
are manufactured domestically. With this assumption, DOE estimates that
in the absence of amended energy conservation standards, there would be
approximately 300 domestic production workers involved in manufacturing
IRLs in 2017. The table below shows the range of the impacts of
potential amended energy conservation standards on U.S. production
workers in the IRL industry.
Table VII.35--Potential Changes in the Total Number of Domestic
Incandescent Reflector Lamp Production Workers in 2017
------------------------------------------------------------------------
Trial standard
level
Base case ---------------
1
------------------------------------------------------------------------
Total Number of Domestic Production 308 335
Workers in 2017 (without changes in
production locations)..................
Potential Changes in Domestic Production .............. 27-(308)
Workers in 2017 *......................
------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in
parentheses indicate negative numbers.
At the upper end of the range TSL 1 shows a slight positive impact
on domestic employment levels. The increasing product cost at TSL 1
would result in higher labor expenditures per-unit, which could cause
manufacturers to hire more domestic workers to meet this added labor
demand, assuming IRL production remains in domestic facilities.
Manufacturers are concerned that higher prices for IRLs will drive
consumers to alternate technologies and it may not make economic sense
for them to continue to produce IRLs. Increasing the efficacy of IRLs
would cost manufacturers millions in capital conversion costs. Some
stated that they do not have the technology to meet the proposed energy
conservation standards and said it is possible they would not spend
their limited resources to convert all IRL production to meet efficacy
levels at TSL 1. Ultimately, the high costs associated with increasing
the efficacy of IRLs could cause some IRL manufacturers to exit the
market.
c. Impacts on Manufacturing Capacity
GSFL manufacturers stated that they did not anticipate any capacity
constraints outside of the availability of REOs. One manufacturer
pointed out that moving the industry to max tech efficacy levels could
triple the amount of REOs demanded by GSFL manufacturers. Tripling the
demand for REOs that are already difficult to come by could trigger
some capacity concerns by creating extra volatility in the market. The
sharp increase in demand for REOs could cause wide variations in the
price and availability of REOs, making production costs more
unpredictable.
A few IRL manufacturers expressed concern about the capacity of
their IR coating machines and that the companies that manufacture those
machines might not be able to respond to the demand for IR coating
machines necessary to manufacture higher efficacious IRLs. DOE,
however, received a comment from ADLT, a company that manufactures IR
coating machines, that they estimate the current global capacity of IR
coatings for IRLs to be over 50 million units annually. ADLT claims
this IR coating capacity is supported by three different coating
processes and provided by at least five different companies. ADLT
stated they are in a position to increase their IR coating capacity by
20 million units annually using existing equipment within a two-year
time period. ADLT believes that additional coating capacity can be
generated from one or more of at least five IR coating facilities owned
and operated by other companies worldwide. Given a three-year period
between the ruling and its effective date, ADLT believes there is ample
time available for various companies to react to the potential increase
in IR coating demand. Given that DOE estimated approximately 65 million
IRLs may be sold in 2017 in the preliminary analysis, ADLT believes
that IR coating capacity in excess of 70 million units in total can
readily be made available. (ADLT, No. 31 at p. 3) While this exceeds
DOE's NOPR IRL shipment estimate of approximately 32 million units to
be sold in 2017, ADLT did not provide a source for their claim that the
current IR coating capacity is 50 million units annually or for the
potential to increase this IR coating capacity to 70 million units
annually in 2017. Therefore, it is unclear if this additional IR
coating capacity or current IR coating capacity is sufficient to meet
the potential U.S. demand for IRLs at the higher EL.
d. Impacts on Sub-Groups of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche product
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE analyzed the impacts to small businesses in
section VIII.B and did not identify any other adversely impacted
subgroups for GSFLs or IRLs for this
[[Page 24165]]
rulemaking based on the results of the industry characterization.
e. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or impending regulations
may have serious consequences for some manufacturers, groups of
manufacturers, or an entire industry. Assessing the impact of a single
regulation may overlook this cumulative regulatory burden. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and lead companies
to abandon product lines or markets with lower expected future returns
than competing products. For these reasons, DOE conducts a cumulative
regulatory burden analysis as part of its rulemakings pertaining to
lighting efficacy.
During previous stages of this rulemaking, DOE identified a number
of requirements, in addition to amended energy conservation standards
for GSFLs and IRLs, that manufacturers will face for products they
manufacture three years prior to and three years after the compliance
date of the amended standards. The following section briefly addresses
comments DOE received with respect to cumulative regulatory burden and
summarizes other key related concerns that manufacturers raised during
interviews.
Several manufacturers expressed concern that GSFLs and IRLs face
several regulations and that they have not had time to fully assess the
effects of the 2009 Lamps Rule, compliance with which was required in
2012. Several manufacturers also expressed concern about the overall
volume of DOE's energy conservation standards with which they must
comply. Most GSFL and IRL manufacturers also make a full range of
lighting products and share engineering and other resources with these
other internal manufacturing divisions for different products
(including certification testing for regulatory compliance).
Manufacturers cited current DOE rulemakings for high intensity
discharge (HID) lamps, metal halide fixtures, LEDs, and CFLs. Some
manufacturers also raised concerns about other existing regulations
separate from DOE's energy conservation standards that manufacturers of
GSFLs and IRLs must meet. These include: the Restriction of Hazardous
Substances (RoHS) Directive, California Title 20, FTC labeling
requirements, Interstate Mercury Education and Reduction Clearinghouse
(IMERC) labeling requirements, the Minamata Convention on Mercury, and
disclosure of procurement methods of conflict minerals mandated by the
Wall Street Reform and Consumer Protection Act, among others. DOE seeks
comment on GSFL manufacturers potentially increasing the amount of
mercury in GSFLs in order to comply with the proposed GSFL standards.
DOE discusses these and other requirements in chapter 13 of the
NOPR TSD, which lists the estimated compliance costs of those
requirements when available. In considering the cumulative regulatory
burden, DOE evaluates the timing of regulations that impact the same
product because the coincident requirements could strain financial
resources in the same profit center and consequently impact capacity.
DOE also identified several ongoing rulemakings that could potentially
impact other business units of GSFL and IRL manufacturers in general,
but the impacts of those ongoing rulemakings remain speculative and are
therefore not included in the analysis for today's proposed rule. DOE
did not receive any data on other regulatory costs that affect the
industry modeled in the cash-flow analysis. To the extent DOE receives
specific costs associated with other regulations affecting those profit
centers (GSFL and IRL) modeled in the GRIM, DOE can incorporate that
information into its cash-flow analysis. The cash-flow scenarios
analyzed for today's proposed rule include the impacts of the 2009
Lamps Rule, as the levels established in that rule have become the
baseline for the proposed standards and the lamp prices estimated in
the engineering analysis reflect the investments that manufacturers
made to comply with the 2009 Lamps Rule. DOE seeks comment on the
compliance costs of any other regulations GSFL or IRL manufacturers
must make, especially if compliance with those regulations is required
three years before or after the estimated compliance date of these
proposed standards (2017).
3. Shipments Analysis and National Impact Analysis
Projections of shipments are an important input to the NIA. As
discussed in section VI.I, DOE developed a shipments model that
incorporated substitution matrixes, which specify the product choices
available to consumers (lamps as well as lamp-and-ballast combinations
for fluorescent lamps) depending on whether they are renovating
lighting systems, installing lighting systems in new construction, or
simply replacing lamps; and a module that assigns shipments to product
classes and efficacy levels based on consumer sensitivities to first
costs and operation and maintenance costs. The model estimates the
shipments of each lamp type in the base case and under the conditions
set by each TSL. Table VII.36 and Table VII.37 present the estimated
cumulative shipments in the base case and the relative change under
each TSL.
Table VII.36--Effect of Standard Cases on Cumulative Shipments of GSFL in 2017-2046
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
-----------------------------------------------------------------------------------------------------
Change in Change in Change in Change in Change in
Lamp type Cumulative shipments shipments shipments shipments shipments
shipments relative to relative to relative to relative to relative to
millions base case base case base case base case base case
(percent) (percent) (percent) (percent) (percent)
--------------------------------------------------------------------------------------------------------------------------------------------------------
4-foot MBP........................................ 5,700 0.0 0.34 -2.7 -24 -18
8-foot SP slimline................................ 110 0.0 -13 8.6 71 24
8-foot RDC HO..................................... 21 0.0 -8.5 0.0 0.0 -8.5
4-foot T5, MiniBP SO.............................. 410 0.0 0.83 28 250 210
4-foot T5, MiniBP HO.............................. 660 0.0 0.27 -0.01 -0.12 0.17
2-foot U-shaped................................... 230 0.0 0.0 -0.0 -0.0 -0.0
-----------------------------------------------------------------------------------------------------
Total GSFL*................................... 7,100 0.0 0.13 -0.39 -3.4 -2.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
* May not sum due to rounding.
[[Page 24166]]
As shown in the preceding Table, depending on TSL, the consumer
choice model projects significant shifts across product classes, in
particular, it projects significant shifts to 4-foot T5 standard output
lamps in the TSL 4 and TSL 5 standards cases. DOE requests comment on
the reasonableness of its assumption that first cost is a significant
driver of consumers' choice of product class, which results in the
shipments analysis projecting a rapid shift from 4-foot MBP T8s to
standard output T5s in the TSL 5 standards case. The TSL5 standards
case substantially increases first cost for 4-foot MBP T8s.
Noting that DOE projects a sharp decrease in total GSFL shipments
both with and without standards during the rulemaking period because of
the projected sharp incursion of LEDs into the GSFL market, DOE also
seeks comment on the reasonableness of the shipments model projection
for TSL 5. Specifically, DOE seeks comment on whether standard output
T5 lamps could increase from 3 to 4 percent of the standard output GSFL
market presently, to approximately 13 percent of the same market by
2020, and to approximately 30 percent of the much attenuated standard
output GSFL market by 2046.
Table VII.37--Effect of Standard Cases on Cumulative Shipments of IRL in 2017-2046
----------------------------------------------------------------------------------------------------------------
Base case TSL 1
---------------------------------
Change in
Lamp Type Cumulative shipments
shipments relative to
millions base case
(percent)
----------------------------------------------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V................................. 230 -20
----------------------------------------------------------------------------------------------------------------
a. Significance of Energy Savings
For each TSL, DOE projected energy savings for GSFLs and IRLs
purchased in the 30-year period that begins in the year of anticipated
compliance with amended standards (2017-2046). The savings are measured
over the entire lifetime of product purchased in the 30-year period.
DOE quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
base case, accounting for the effects of the standards on product
switching and shipments. Table VII.38 presents the estimated energy
savings for each considered GSFL TSL, and Table VII.39 presents the
estimated energy savings for each IRL TSL. The approach for estimating
shipments and NES is further described in sections V.I and V.J and is
detailed in chapter 11 and 12 of the TSD of the NOPR TSD.
Table VII.38--Cumulative Energy Savings for GSFL Trial Standard Levels for Units Sold in 2017-2046
----------------------------------------------------------------------------------------------------------------
Trial standard level
--------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Quads
----------------------------------------------------------------------------------------------------------------
Primary Energy..................................................... 0.20 0.20 0.86 2.9 3.3
(Power Sector Consumption).........................................
FFC Energy......................................................... 0.21 0.21 0.89 3.0 3.5
----------------------------------------------------------------------------------------------------------------
Table VII.39--Cumulative Energy Savings for IRL Trial Standard Levels
for Units Sold in 2017-2046
------------------------------------------------------------------------
------------------------------------------------------------------------
Trial
standard
level
-------------
1
-------------
Quads
------------------------------------------------------------------------
Primary Energy (Power Sector Consumption)................. 0.012
FFC Energy................................................ 0.013
------------------------------------------------------------------------
Circular A-4 requires agencies to present analytical results,
including separate schedules of the monetized benefits and costs that
show the type and timing of benefits and costs. Circular A-4 also
directs agencies to consider the variability of key elements underlying
the estimates of benefits and costs. For this rulemaking, DOE undertook
a sensitivity analysis using nine, rather than 30, years of product
shipments. The choice of a nine-year period is a proxy for the timeline
in EPCA for the review of certain energy conservation standards and
potential revision of and compliance with such revised standards.\89\
The review timeframe established in EPCA is generally not synchronized
with the product lifetime, product manufacturing cycles, or other
factors specific to GSFLs and IRLs. Thus, this information is presented
for informational purposes only and is not indicative of any change in
DOE's analytical methodology. The NES results based on nine years of
shipments are presented in Table VII.40 and Table VII.41. The impacts
are counted over the lifetime of GSFL and IRL purchased in 2017-2025.
---------------------------------------------------------------------------
\89\ Section 325(m) of EPCA requires DOE to review its standards
at least once every 6 years, and requires, for certain products, a
3-year period after any new standard is promulgated before
compliance is required, except that in no case may any new standards
be required within 6 years of the compliance date of the previous
standards. While adding a 6-year review to the 3-year compliance
period adds up to 9 years, DOE notes that it may undertake reviews
at any time within the 6 year period and that the 3-year compliance
date may yield to the 6-year backstop. A 9-year analysis period may
not be appropriate given the variability that occurs in the timing
of standards reviews and the fact that for some consumer products,
the compliance period is 5 years rather than 3 years.
[[Page 24167]]
Table VII.40--Cumulative Energy Savings for GSFL Trial Standard Levels for Units Sold in 2017-2025
----------------------------------------------------------------------------------------------------------------
Trial standard level
--------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Quads
----------------------------------------------------------------------------------------------------------------
Primary Energy (Power Sector Consumption).......................... 0.10 0.10 0.42 1.3 1.5
FFC Energy......................................................... 0.10 0.10 0.44 1.4 1.5
----------------------------------------------------------------------------------------------------------------
Table VII.41--Cumulative Energy Savings for IRL Trial Standard Levels
for Units Sold in 2017 -2025
------------------------------------------------------------------------
------------------------------------------------------------------------
Trial
standard
level
-------------
1
-------------
Quads
------------------------------------------------------------------------
Primary Energy (Power Sector Consumption)................. 0.008
FFC Energy................................................ 0.008
------------------------------------------------------------------------
b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the TSLs considered for GSFLs and
IRLs. DOE quantified the costs and benefits attributable to each TSL as
the difference in total product costs and total operating costs between
each standards case and the base case, accounting for the effects of
the standards on product switching and shipments.
In accordance with OMB's guidelines on regulatory analysis,\90\ DOE
calculated the NPV using both a 7 percent and a 3 percent real discount
rate. The 7 percent rate is an estimate of the average before-tax rate
of return on private capital in the U.S. economy; it reflects the
returns on real estate and small business capital as well as corporate
capital. This discount rate approximates the opportunity cost of
capital in the private sector. The 3 percent rate reflects the
potential effects of standards on private consumption (e.g., through
higher prices for product and reduced purchases of energy). This rate
represents the rate at which society discounts future consumption flows
to their present value. It can be approximated by the real rate of
return on long-term government debt (i.e., yield on United States
Treasury notes), which has averaged about 3 percent for the past 30
years.
---------------------------------------------------------------------------
\90\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
www.whitehouse.gov/omb/circulars_a004_a-4.
---------------------------------------------------------------------------
Table VII.42 shows the consumer NPV results for each TSL considered
for GSFLs, and Table VII.43 shows the consumer NPV results for each TSL
considered for IRL. In each case, the impacts cover the lifetime of
product purchased in 2017-2046.
Table VII.42--Net Present Value of Consumer Benefits for GSFL Trial Standard Levels for Units Sold in 2017-2046
----------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
7% discount rate.............................................. -0.39 -0.48 0.23 3.2 3.1
3% discount rate.............................................. -0.49 -0.63 1.0 8.1 8.1
----------------------------------------------------------------------------------------------------------------
Table VII.43--Net Present Value of Consumer Benefits for IRL Trial
Standard Levels for Units Sold in 2017-2046
------------------------------------------------------------------------
TSL 1
-----------------
Billion 2012$
------------------------------------------------------------------------
7% discount rate...................................... 0.18
3% discount rate...................................... 0.28
------------------------------------------------------------------------
[[Page 24168]]
The NPV results based on the afore-mentioned nine-year shipments
period are presented in Table VII.44 and Table VII.45. The impacts are
counted over the lifetime of product purchased in 2017-2025. As
mentioned previously, this information is presented for informational
purposes only and is not indicative of any change in DOE's analytical
methodology or decision criteria.
Table VII.44--Net Present Value of Consumer Benefits for GSFL Trial Standard Levels for Units Sold in 2017-2025
----------------------------------------------------------------------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Billion 2012$
-------------------------------------------------
7% discount rate.............................................. -0.26 -0.33 0.04 1.1 1.1
3% discount rate.............................................. -0.29 -0.39 0.37 2.5 2.7
----------------------------------------------------------------------------------------------------------------
Table VII.45--Net Present Value of Consumer Benefits for IRL Trial
Standard Levels for Units Sold in 2017-2025
------------------------------------------------------------------------
TSL 1
-----------------
Billion 2012$
------------------------------------------------------------------------
7% discount rate...................................... 0.13
3% discount rate...................................... 0.18
------------------------------------------------------------------------
c. Impact of Product Class Switching
As discussed at the beginning of section VII.B.3, consumer
switching between product classes yields an increase in shipments for
some GSFL product classes, with corresponding reductions in shipments
in other product classes (see Table VII.36). Therefore, a portion of
the energy savings for some of the TSLs is due to consumers' switching
between product classes to more energy efficient products with lower
operating costs. Similarly, the increase in product costs for some of
the TSLs is substantially impacted by product-class switching. For the
standard level proposed for GSFL's in this rulemaking, increases in the
typical cost of 4-foot MBP GSFLs relative to 8-foot SP slimline or 4-
foot MiniBP T5s is expected to drive some consumers to shift toward the
latter two product classes, yielding a reduction in energy consumption
relative to the base case, with a lower increase in purchase costs than
would be obtained without the product-class switching. Conversely, as
is true for TSL1, potential standard level that increases the typical
purchase prices of the latter two product classes above would reduce
migration to these product classes, yielding a net reduction in the
energy savings relative to the base case, with a greater increment in
product costs. This is true for example with TSL1 where the efficiency
requirements are increased for product classes which are already
relatively efficient (e.g., 4 foot T5 miniBP) while not increased for
product classes which are relatively inefficient (e.g., 4 foot MBP). In
this case, there is no product class switching as consumers are
forecasted to continue purchasing the less costly and less efficient
technology (4 foot MBP).
Because of these assumed shifts in shipments between product
classes, the NES and monetized cost and benefit values computed for a
single product class, considered in isolation, may yield negative
energy savings and associated benefits as well as negative associated
costs . For the proposed standard level, the increased shipments of
MiniBP T5 lamps and 8-foot SP slimline lamps will lead to negative
energy savings and costs for both of those product classes, when viewed
in isolation, simply because significantly more lamps from those
product classes are purchased and operated in the standards case than
in the base case. Those negative values, however, do not represent an
actual reduction in consumer benefit for the service being delivered to
the consumer since the negative values for the particular product
classes are more than offset by the large positive contributions to the
aggregate energy savings and monetized benefits across all product
classes partially due to the corresponding reduction in shipments of 4-
ft MBP T8s. DOE requests comment on the consumer choice model that
projects shifts in shipments between product classes and whether there
are other factors (e.g. utility, costs to replace light fixtures,
design incompatibility) that may preclude or limit that shifting that
may not be considered in DOE's analysis. For informational purposes,
chapter 12 of the TSD presents NES and NPV values computed for each
product class individually.
d. Alternative Scenario Analyses
As discussed in section VI.I and VI.J, DOE conducted several
sensitivity analyses to determine the potential impact of uncertain
future prices for materials that are important to the manufacture of
efficient GSFL and IRL products.
In the case of GSFLs, DOE considered the possibility that the price
of rare earth oxides rises again. As mentioned in section V.I, rare
earth oxides, used in GSFL phosphors to improve lamp efficiency,
underwent a large price spike in 2010 and 2011, but their prices have
since lowered to almost their pre-spike level. To assess the effect of
higher rare earth prices on the impact of energy conservation standards
for GSFLs, DOE performed an alternative analysis in which the average
price of rare earth oxides was assumed to be midway between the peak of
the 2011 price spike and the pre-spike level, and was assumed to remain
at that elevated level throughout the analysis period. The details of
the price model that DOE used for this analysis are given in appendix
11B of the NOPR TSD. The impacts of the modeled rare earth oxide price
increase on the NES and NPV of this rulemaking were small to moderate
and did not affect the ranking of the TSLs (see chapter 12 of the NOPR
TSD).
In the case of IRLs, DOE considered the possibility of a
significant increase in the price of xenon gas, which DOE believes is
now used as a fill gas in all standards-compliant IRL products. Demand
for xenon gas has been rising recently, which may lead to price
increases in the future. To assess the effect of a significant xenon
price increase on the impact of an energy conservation standard for
IRL, DOE performed an alternative analysis in which the price of xenon
is assumed to increase by a factor of ten in the near future and remain
at these elevated levels throughout the analysis period. The details of
the xenon market assessment used to inform this analysis are given in
appendix 7C of the TSD for the NOPR. The impacts of the modeled xenon
price increase on the NES and NPV of this rulemaking were minimal and
did not affect the ranking of the TSLs (see chapter 12 of the NOPR
TSD).
e. Indirect Impacts on Employment
DOE expects energy conservation standards for GSFLs and IRLs to
reduce energy costs for product owners, and the resulting net savings
to be redirected to
[[Page 24169]]
other forms of economic activity. Those shifts in spending and economic
activity could affect the demand for labor. As described in section
VI.O, DOE used an input/output model of the U.S. economy to estimate
indirect employment impacts of the TSLs that DOE considered in this
rulemaking. DOE understands that there are uncertainties involved in
projecting employment impacts, especially changes in the later years of
the analysis. Therefore, DOE generated results for near-term time
frames, where these uncertainties are reduced.
The results suggest that the proposed standards are likely to have
negligible impact on the net demand for labor in the economy. The net
change in jobs is so small that it would be imperceptible in national
labor statistics and might be offset by other, unanticipated effects on
employment. Chapter 17 of the NOPR TSD presents detailed results.
4. Impact on Utility or Performance
DOE believes that the standards it is proposing today will not
lessen the utility or performance of GSFLs and IRLs. DOE reached this
conclusion based on the analyses conducted to develop the proposed GSFL
and IRL efficacy levels. In the engineering analysis, DOE considered
only technology options that would not have adverse impacts on product
utility. See section VI.B and chapter 4 of this TSD for further details
regarding the screening analysis. DOE also divided products in to
classes based on performance-related features that justify different
standard levels such as those impacting consumer utility. DOE then
developed separate standard levels for each product class. See section
VI.C and chapter 3 of this TSD for further details regarding product
classes selected and consumer utility.
Further, DOE's evaluation shows that products meeting proposed
efficacy levels are not of lesser utility or performance than products
at existing standard levels. DOE considered several characteristics
when evaluating utility and performance of GSFLs including physical
constraints (i.e., shape and size), diameter, lumen package, color
quality (i.e., CCT and CRI), lifetime, and ability to dim. DOE
determined that these GSFL performance characteristics were not
diminished for any proposed standard level. For IRLs, DOE considered
lumen package, lifetime, shape, and diameter when evaluating utility
and performance. DOE determined that these IRL performance
characteristics were not diminished for any proposed standard level.
DOE did not assess CRI or CCT for IRLs because they are intended as a
measure of the light quality of non-incandescent/halogen lamps when
compared with incandescent/halogen lamps. See section VI.D and chapter
5 of this TSD for further details on the selection of more efficacious
substitutes for the baseline and development of proposed efficacy
levels.
DOE requests comment on its assumption that there will be no
lessening of utility or performance such that the performance
characteristics, including physical constraints, diameter, lumen
package, color quality, lifetime, and ability to dim, would be
adversely affected for the GSFL efficacy levels. Similarly, DOE also
requests comment on its assumption that there will be no lessening of
utility or performance such that the performance characteristics,
including lumen package, lifetime, shape, diameter, and light quality,
would be adversely affected for the IRL efficacy levels.
5. Impact of Any Lessening of Competition
DOE considers any lessening of competition that is likely to result
from amended standards. The Attorney General determines the impact, if
any, of any lessening of competition likely to result from a proposed
standard, and transmits such determination to the Secretary, together
with an analysis of the nature and extent of such impact.
To assist the Attorney General in making such determination, DOE
will provide DOJ with copies of the NOPR and the TSD for review. DOE
will consider DOJ's comments on the proposed rule in preparing the
final rule, and DOE will publish and respond to DOJ's comments in that
document.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the nation's energy security, strengthens the economy, and reduces the
environmental impacts or costs of energy production. Reduced
electricity demand due to energy conservation standards is also likely
to reduce the cost of maintaining the reliability of the electricity
system, particularly during peak-load periods. As a measure of this
reduced demand, chapter 16 in the NOPR TSD presents the estimated
reduction in generating capacity for the TSLs that DOE considered in
this rulemaking.
Energy savings from standards for GSFLs and IRLs could also produce
environmental benefits in the form of reduced emissions of air
pollutants and GHGs associated with electricity production. Table
VII.46 and Table VII.47 provide DOE's estimate of cumulative emissions
reductions projected to result from the TSLs considered in this
rulemaking. DOE reports annual emissions reductions for each TSL in
chapter 14 of the NOPR TSD.
Table VII.46--Cumulative Emissions Reduction Estimated for GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Trial standard level
-----------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 9.9 9.7 42 140 160
SO2 (thousand tons)................................. 15 15 64 220 250
NOX (thousand tons)................................. 5.5 5.5 23 78 89
Hg (tons)........................................... 0.019 0.019 0.082 0.28 0.32
N2O (thousand tons)................................. 0.16 0.16 0.69 2.4 2.7
CH4 (thousand tons)................................. 1.1 1.0 4.5 15 18
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 0.52 0.51 2.2 7.6 8.6
SO2 (thousand tons)................................. 0.11 0.11 0.48 1.6 1.9
NOX (thousand tons)................................. 7.2 7.0 31 100 120
[[Page 24170]]
Hg (tons)........................................... 0.00028 0.00028 0.0012 0.0041 0.0047
N2O (thousand tons)................................. 0.0053 0.0052 0.023 0.077 0.088
CH4 (thousand tons)................................. 43 42 180 630 720
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 10 10 44 150 170
SO2 (thousand tons)................................. 15 15 65 220 250
NOX (thousand tons)................................. 13 12 54 180 210
Hg (tons)........................................... 0.020 0.019 0.083 0.28 0.32
N2O (thousand tons)................................. 0.17 0.16 0.71 2.5 2.8
N2O (thousand tons CO2eq)*.......................... 49 48 210 730 830
CH4 (thousand tons)................................. 44 43 190 640 730
CH4 (million tons CO2eq)*........................... 1,100 1,100 4,700 16,000 18,000
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
Table VII.47--Cumulative Emissions Reduction Estimated for IRL Trial
Standard Levels
------------------------------------------------------------------------
Trial
standard
level
-----------
1
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.66
SO2 (thousand tons)......................................... 0.69
NOX (thousand tons)......................................... 0.35
Hg (tons)................................................... 0.0012
N2O (thousand tons)......................................... 0.0095
CH4 (thousand tons)......................................... 0.066
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.032
SO2 (thousand tons)......................................... 0.0069
NOX (thousand tons)......................................... 0.45
Hg (tons)................................................... 0.00002
N2O (thousand tons)......................................... 0.00033
CH4 (thousand tons)......................................... 2.7
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.70
SO2 (thousand tons)......................................... 0.69
NOX (thousand tons)......................................... 0.79
Hg (tons)................................................... 0.0012
N2O (thousand tons)......................................... 0.0099
N2O (thousand tons CO2eq)*.................................. 2.9
CH4 (thousand tons)......................................... 2.7
CH4 (million tons CO2eq)*................................... 68
------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
As part of the analysis for this rule, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
and NOX that DOE estimated for each of the TSLs considered.
As discussed in section VI.M.1, DOE used the most recent values for the
SCC developed by an interagency process. The four sets of SCC values
resulting from that process (expressed in 2012$) represented by $11.8/
metric ton (the average value from a distribution that uses a 5 percent
discount rate), $39.7/metric ton (the average value from a distribution
that uses a 3 percent discount rate), $61.2/metric ton (the average
value from a distribution that uses a 2.5 percent discount rate), and
$117/metric ton (the 95th-percentile value from a distribution that
uses a 3 percent discount rate). These values correspond to the value
of emission reductions in 2015; the values for later years are higher
due to increasing damages as the projected magnitude of climate change
increases.
Table VII.48 and Table VII.49 present the global value of
CO2 emissions reductions at each TSL. For each of the four
cases, DOE calculated a present value of the stream of annual values
using the same discount rate as was used in the studies upon which the
dollar-per-ton values are based. DOE calculated domestic values as a
range from 7 percent to 23 percent of the global values, and these
results are presented in chapter 15 of the NOPR TSD.
Table VII.48--Estimates of Global Present Value of CO2 Emissions Reduction Under GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
SCC Case*
---------------------------------------------------------------------------
TSL 5% discount rate, 3% discount rate, 2.5% discount 3% discount rate,
average* average* rate, average* 95th percentile*
----------------------------------------------------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 77 330 520 1,000
2................................... 76 330 520 1,000
3................................... 330 1,400 2,200 4,300
4................................... 1,100 4,700 7,300 14,000
5................................... 1,200 5,300 8,400 16,000
----------------------------------------------------------------------------------------------------------------
[[Page 24171]]
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 4.0 17 27 54
2................................... 4.0 17 27 53
3................................... 17 74 120 230
4................................... 57 250 390 760
5................................... 65 280 450 870
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 81 350 550 1,100
2................................... 80 350 540 1,100
3................................... 340 1,500 2,300 4,500
4................................... 1,100 4,900 7,700 15,000
5................................... 1,300 5,600 8,900 17,000
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117
per metric ton (2012$).
Table VII.49--Estimates of Global Present Value of CO2 Emissions Reduction Under IRL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
SCC Case*
---------------------------------------------------------------------------
TSL 5% discount rate, 3% discount rate, 2.5% discount 3% discount rate,
average* average* rate, average* 95th percentile*
----------------------------------------------------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 5.8 24 37 72
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 0.28 1.2 1.8 3.5
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 6.1 25 39 75
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $11.8, $39.7, $61.2, and $117
per metric ton (2012$).
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed on
reducing CO2 emissions in this rulemaking is subject to
change. DOE, together with other Federal agencies, will continue to
review various methodologies for estimating the monetary value of
reductions in CO2 and other GHG emissions. This ongoing
review will consider the comments on this subject that are part of the
public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this proposed rule the
most recent values and analyses resulting from the interagency process.
DOE also estimated the cumulative monetary value of the economic
benefits associated with NOX emissions reductions
anticipated to result from amended standards for GSFLs and IRLs. The
dollar-per-ton value that DOE used is discussed in section VI.L. Table
VII.50 and Table VII.51 present the cumulative present values for each
TSL calculated using 7 percent and 3 percent discount rates.
[[Page 24172]]
Table VII.50--Estimates of Present Value of NOX Emissions Reduction
Under GSFL Trial Standard Levels
------------------------------------------------------------------------
3% discount 7% discount
TSL rate rate
------------------------------------------------------------------------
Million 2012$
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1....................................... 9.6 5.8
2....................................... 9.5 5.8
3....................................... 40 24
4....................................... 130 77
5....................................... 150 89
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1....................................... 12 6.9
2....................................... 12 6.9
3....................................... 50 29
4....................................... 170 93
5....................................... 190 110
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1....................................... 21 13
2....................................... 21 13
3....................................... 90 53
4....................................... 290 170
5....................................... 340 200
------------------------------------------------------------------------
Table VII.51--Estimates of Present Value of NOX Emissions Reduction
Under IRL Trial Standard Levels
------------------------------------------------------------------------
3% 7%
TSL discount discount
rate rate
------------------------------------------------------------------------
Million 2012$
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1............................................... 0.71 0.52
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1............................................... 0.87 0.61
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1............................................... 1.6 1.1
------------------------------------------------------------------------
7. Summary of National Economic Impacts
The NPV of the monetized benefits associated with emissions
reductions can be viewed as a complement to the NPV of the consumer
savings calculated for each TSL considered in this rulemaking. Table
VII.52 presents the NPV values that result from adding the estimates of
the potential economic benefits resulting from reduced CO2
and NOX emissions in each of four valuation scenarios to the
NPV of consumer savings calculated for each TSL considered in this
rulemaking, at both a 7 percent and 3 percent discount rate. The
CO2 values used in the columns of each table correspond to
the four sets of SCC values discussed above.
Table VII.52--Net Present Value of Consumer Savings Combined With Present Value of Monetized Benefits From CO2
and NOX Emissions Reductions Under GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% discount rate added with:
-----------------------------------------------------------------------
TSL SCC Case $11.8/ SCC Case $39.7/ SCC Case $61.2/ SCC Case $117/
metric ton CO2* metric ton CO2* metric ton CO2* metric ton CO2*
----------------------------------------------------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
1....................................... -0.39 -0.12 0.08 0.60
2....................................... -0.53 -0.27 -0.07 0.44
3....................................... 1.5 2.6 3.4 5.7
4....................................... 9.5 13 16 23
5....................................... 9.7 14 17 26
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% discount rate added with:
-----------------------------------------------------------------------
TSL SCC Case $11.8/ SCC Case $39.7/ SCC Case $61.2/ SCC Case $117/
metric ton CO2* metric ton CO2* metric ton CO2* metric ton CO2*
-----------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
1....................................... -0.30 -0.03 0.17 0.70
2....................................... -0.38 -0.12 0.08 0.59
3....................................... 0.63 1.8 2.6 4.8
4....................................... 4.5 8.3 11 18
5....................................... 4.6 9.0 12 21
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2012$. For NOX emissions, each case uses the medium
value, which corresponds to $2,639 per ton.
[[Page 24173]]
Table VII.53--Net Present Value of Consumer Savings Combined with Present Value of Monetized Benefits from CO2
and NOX Emissions Reductions Under IRL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% discount rate added with:
-----------------------------------------------------------------------
TSL SCC Case $11.8/ SCC Case $39.7/ SCC Case $61.2/ SCC Case $117/
metric ton CO2* metric ton CO2* metric ton CO2* metric ton CO2*
----------------------------------------------------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
1....................................... 0.29 0.31 0.32 0.36
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% discount rate added with:
----------------------------------------------------------------------------------------------------------------
TSL SCC Case SCC Case SCC Case SCC Case
$11.8/metric ton $39.7/metric ton $61.2/metric ton $117/metric ton
CO2* CO2* CO2* CO2*
-----------------------------------------------------------------------
Billion 2012$
----------------------------------------------------------------------------------------------------------------
1....................................... 0.19 0.20 0.22 0.25
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2012$. For NOX emissions, each case uses the medium
value, which corresponds to $2,639 per ton.
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. consumer monetary savings that occur as a result of market
transactions, while the value of CO2 reductions is based on
a global value. Second, the assessments of operating cost savings and
the SCC are performed with different methods that use different time
frames for analysis. The national operating cost savings is measured
for the lifetime of product shipped in 2017-2046. The SCC values, on
the other hand, reflect the present value of future climate-related
impacts resulting from the emission of one metric ton of CO2
in each year. These impacts continue well beyond 2100.
8. Other Factors
The Secretary, in determining whether a standard is economically
justified, may consider any other factors that the Secretary deems to
be relevant. (42 U.S.C. 6295(o)(2)(B)(i)) No other factors were
considered in this analysis.
C. Proposed Standards
When considering proposed standards, the new or amended energy
conservation standard that DOE adopts for any type (or class) of
covered product must be designed to achieve the maximum improvement in
energy efficiency that the Secretary determines is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In
determining whether a standard is economically justified, the Secretary
must determine whether the benefits of the standard exceed its burdens,
considering to the greatest extent practicable the seven statutory
factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or
amended standard must also ``result in significant conservation of
energy.'' (42 U.S.C. 6295(o)(3)(B))
DOE considers the impacts of standards at each TSL, beginning with
the max tech level, to determine whether that level met the evaluation
criteria. Where the max tech level is not justified, DOE then considers
the next most efficient level and undertakes the same evaluation until
it reaches the highest efficiency level that is technologically
feasible, economically justified, and saves a significant amount of
energy.
To aid the reader in understanding the benefits and/or burdens of
each TSL, Table VII.54 and Table VII.55 in this section summarize the
quantitative analytical results for each TSL, based on the assumptions
and methodology discussed herein. The efficacy levels contained in each
TSL are described in section VI.D. In addition to the quantitative
results presented in the tables, DOE also considers other burdens and
benefits that affect economic justification. These include the impacts
on identifiable subgroups of consumers who may be disproportionately
affected by a national standard (see section VI.H), and impacts on
employment. DOE discusses the impacts on employment in GSFL and IRL
manufacturing in section VII.B.2.b, and discusses the indirect
employment impacts in section VI.O.
As discussed in previous DOE standards rulemakings and the February
2011 NODA (76 FR 9696, Feb. 22, 2011), DOE also notes that economics
literature provides a wide-ranging discussion of how consumers trade
off upfront costs and energy savings in the absence of government
intervention. Much of this economics literature attempts to explain why
consumers appear to undervalue energy efficiency improvements. This
undervaluation suggests that regulation promoting energy efficiency can
produce significant net private gains (as well as producing social
gains by, for example, reducing pollution). There is evidence that
consumers undervalue future energy savings as a result of (1) a lack of
information, (2) a lack of sufficient savings to warrant accelerating
or altering purchases (e.g., an inefficient ventilation fan in a new
building or the delayed replacement of a water pump), (3) inconsistent
weighting of future energy cost savings relative to available returns
on other investments, (4) computational or other difficulties
associated with the evaluation of relevant tradeoffs, and (5) a
divergence in incentives (e.g., renter versus owner; builder vs.
purchaser). Other literature indicates that with less-than-perfect
foresight and a high degree of uncertainty about the future, it may be
rational for consumers to trade off these types of investments at a
higher-than-expected rate between current consumption and uncertain
future energy cost savings. Some studies suggest that this seeming
undervaluation may be explained in certain circumstances by differences
between tested and actual energy savings, or by uncertainty and
irreversibility of energy investments. There may also be ``hidden''
welfare losses to consumers if newer energy efficient products are
imperfect substitutes for the less efficient products they replace, in
terms of performance or other attributes that consumers value. In the
abstract, it may be difficult to say how a welfare gain from correcting
[[Page 24174]]
potential under-investment in energy conservation compares in magnitude
to the potential welfare losses associated with no longer purchasing a
machine or switching to an imperfect substitute, both of which still
exist in this framework.
The mix of evidence in the empirical economics literature suggests
that if feasible, analysis of regulations mandating energy-efficiency
improvements should explore the potential for both welfare gains and
losses and move toward a fuller economic framework where all relevant
changes can be quantified.\91\ While DOE is not prepared at present to
provide a fuller quantifiable framework for this discussion, DOE seeks
comments on how to assess these possibilities.\92\ In particular, DOE
requests comment on whether there are features or attributes of the
more energy efficient GSFLs and IRLs that manufacturers would produce
to meet the standards in this proposed rule that might affect the
welfare, positively or negatively, of consumers who purchase these
lamps.
---------------------------------------------------------------------------
\91\ A good review of the literature related to this issue can
be found in Gillingham, K., R. Newell, K. Palmer. (2009). ``Energy
Efficiency Economics and Policy,'' Annual Review of Resource
Economics, 1: 597-619; and Tietenberg, T. (2009). ``Energy
Efficiency Policy: Pipe Dream or Pipeline to the Future?'' Review of
Environmental Economics and Policy. Vol. 3, No. 2: 304-320.
\92\ A draft paper, ``Notes on the Economics of Household Energy
Consumption and Technology Choice,'' proposes a broad theoretical
framework on which an empirical model might be based and is posted
on the DOE Web site along with this notice at www.eere.energy.gov/buildings/appliance_standards.
---------------------------------------------------------------------------
1. Benefits and Burdens of Trial Standard Levels Considered for General
Service Fluorescent Lamps
Table VII.54 and Table VII.55 summarize the quantitative impacts
estimated for each TSL for GSFL.
Table VII.54--Summary of Analytical Results for GSFL: National Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
National FFC Energy Savings quads
----------------------------------------------------------------------------------------------------------------
0.21 0.21 0.89 3.0 3.5
----------------------------------------------------------------------------------------------------------------
NPV of Consumer Benefits 2012$ billion
----------------------------------------------------------------------------------------------------------------
3% discount rate.............. -0.49 -0.63 1.0 8.1 8.1
7% discount rate.............. -0.39 -0.48 0.23 3.2 3.1
----------------------------------------------------------------------------------------------------------------
Cumulative Emissions Reduction (Total FFC Emissions)
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)..... 10 10 44 150 170
SO2 (thousand tons)........... 15 15 65 220 250
NOX (thousand tons)........... 13 12 54 180 210
Hg (tons)..................... 0.020 0.019 0.083 0.28 0.32
N2O (thousand tons)........... 0.17 0.16 0.71 2.5 2.8
N2O (thousand tons CO2eq) *... 49 48 210 730 830
CH4 (thousand tons)........... 44 43 190 640 730
CH4 (million tons CO2eq) *.... 1,100 1,100 4,700 16,000 18,000
----------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction (Total FFC Emissions)
----------------------------------------------------------------------------------------------------------------
CO2 2012$ million **.......... 82 to 1,100 80 to 1,100 340 to 4,500 1,100 to 15,000 1,300 to 17,000
NOX--3% discount rate, 2012$ 21 21 90 290 340
million......................
NOX--7% discount rate, 2012$ 13 13 53 170 200
million......................
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2
emissions.
Table VII.55--Summary of Analytical Results for GSFL: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Change in Industry NPV (2012$ 41.8--(0.9) 37.8--(9.2) 120.5--(11.5 358.5--(22.9 397.1--(39.9
million)[dagger]......................... ) ) )
Change in Industry NPV (%)[dagger]........ 2.7--(0.1) 2.5--(0.6) 7.8--(0.7) 23.2--(1.5) 25.7--(2.6)
----------------------------------------------------------------------------------------------------------------
Consumer Mean LCC Savings 2012$
----------------------------------------------------------------------------------------------------------------
4-foot MBP <=4,500 K...................... 0.00 0.00 0.54 3.14 3.14
4-foot T5 MiniBP SO <=4,500 K............. 2.33 2.33 2.33 2.33 2.76
4-foot T5 MiniBP HO <=4,500 K............. 2.28 2.28 2.28 2.28 2.28
8-foot SP Slimline <=4,500 K.............. 0.00 6.88 0.00 0.00 2.08
8-foot RDC HO <=4,500 K................... -9.56 -16.76 -9.56 -9.56 -16.76
Weighted Average*......................... -0.68 -1.00 -0.22 1.77 1.43
----------------------------------------------------------------------------------------------------------------
Consumer Mean PBP years**
----------------------------------------------------------------------------------------------------------------
4-foot MBP <=4,500 K...................... 0.0 0.0 0.6 3.6 3.6
4-foot T5 MiniBP SO <=4,500 K............. 1.2 1.2 1.2 1.2 4.3
4-foot T5 MiniBP HO <=4,500 K............. 3.0 3.0 3.0 3.0 3.0
8-foot SP Slimline <=4,500 K.............. 0.0 0.6 0.0 0.0 4.5
8-foot RDC HO <=4,500 K................... NER NER NER NER NER
Weighted Average*......................... 0.1 0.1 0.6 3.2 3.7
Weighted Average Customers with Net Cost 9.5 11.5 59.5 29.4 34.5
(%)*.....................................
[[Page 24175]]
Weighted Average Customers with Net 1.1 2.6 36.0 60.4 65.5
Benefit (%)*.............................
Weighted Average Customers with No Impact 89.4 85.8 4.5 10.2 0.0
(%)*.....................................
----------------------------------------------------------------------------------------------------------------
* Weighted by shares of each product class in total projected shipments in 2017.
** Does not include weighting for ``NER'' scenarios. Entries of ``NER'' indicate standard levels that do not
reduce operating costs, which prevents the consumer from recovering the increased purchase cost.
[dagger] Values in parentheses are negative values.
First, DOE considered TSL 5, the most efficient level (max tech),
which would save an estimated total of 3.5 quads of energy, an amount
DOE considers significant. TSL 5 has an estimated NPV of consumer
benefit of $3.1 billion using a 7 percent discount rate, and $8.1
billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 5 are 170 million metric
tons of CO2, 210 thousand tons of NOX, 250
thousand tons of SO2, 0.32 tons of Hg, 730 thousand tons of
CH4, and 2.8 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reductions at TSL 5
ranges from $1,300 million to $17,000 million.
At TSL 5, the weighted average LCC savings is $3.14 for the 4-foot
MBP lamps, $2.76 for the 4-foot T5 MiniBP SO lamps, $2.28 for the 4-
foot T5 MiniBP HO lamps, $2.08 for the 8-foot SP slimline lamps, and -
$16.76 for the 8-foot RDC HO lamps.
At TSL 5, the projected change in INPV ranges from a decrease of
$39.9 million to an increase of $397.1 million. If the decrease is
realized, TSL 5 could result in a net loss of up to 2.6 percent in INPV
to manufacturers of covered GSFLs. Also at TSL 5, DOE estimates
industry will need to invest approximately $38.6 million in conversion
costs.
After considering the analysis and weighing the benefits and the
burdens, DOE has tentatively concluded that, at TSL 5 for GSFL, the
benefits of energy savings, positive NPV of total consumer benefits,
positive impacts on consumers (as indicated by positive average LCC
savings, favorable PBPs, and the large percentage of consumers who
would experience LCC benefits), emission reductions and the estimated
monetary value of the emissions reductions would outweigh the potential
reduction in industry value, and increase in LCCs experienced by
certain consumers at TSL 5. The Secretary has concluded that TSL 5
would save a significant amount of energy and is technologically
feasible and economically justified.
Based on the above considerations, DOE today proposes to adopt the
energy conservation standards for GSFL at TSL 5. Table VII.56 presents
the proposed energy conservation standards for GSFL.
Table VII.56--Proposed Energy Conservation Standards for GSFL
------------------------------------------------------------------------
Proposed level
Lamp type CCT K lm/W
------------------------------------------------------------------------
4-Foot Medium Bipin................. <=4,500 92.4
>4,500 90.6
2-Foot U-Shaped..................... <=4,500 86.9
>4,500 84.3
8-Foot Slimline..................... <=4,500 99.0
>4,500 94.1
8-Foot High Output.................. <=4,500 97.6
>4,500 95.6
4-Foot Miniature Bipin Standard <=4,500 97.1
Output.............................
>4,500 91.3
4-Foot Miniature Bipin High Output.. <=4,500 82.7
>4,500 78.6
------------------------------------------------------------------------
2. Summary of Benefits and Costs (Annualized) of the Proposed Standards
for General Service Fluorescent Lamps
The benefits and costs of today's proposed standards, for product
sold in 2017-2046, can also be expressed in terms of annualized values.
The annualized monetary values are the sum of (1) the annualized
national economic value of the benefits from consumer operation of
product that meet the proposed standards (consisting primarily of
operating cost savings from using less energy, minus increases in
product purchase and installation costs, which is another way of
representing consumer NPV), and (2) the annualized monetary value of
the benefits of emission reductions, including CO2 emission
reductions.\93\
---------------------------------------------------------------------------
\93\ DOE used a two-step calculation process to convert the
time-series of costs and benefits into annualized values. First, DOE
calculated a present value in 2013, the year used for discounting
the NPV of total consumer costs and savings, for the time-series of
costs and benefits using discount rates of 3 and 7 percent for all
costs and benefits except for the value of CO2
reductions. For the latter, DOE used a range of discount rates. From
the present value, DOE then calculated the fixed annual payment over
a 30-year period (2017 through 2046) that yields the same present
value. The fixed annual payment is the annualized value. Although
DOE calculated annualized values, this does not imply that the time-
series of cost and benefits from which the annualized values were
determined is a steady stream of payments.
---------------------------------------------------------------------------
Estimates of annualized benefits and costs of the proposed
standards for GSFL are shown in Table VII.57. The results under the
primary estimate are as follows. Using a 7-percent discount rate for
benefits and costs other than CO2 reduction, for which DOE
used a 3-percent discount rate along with the average SCC series that
uses a 3-percent discount rate, the cost of the standards proposed in
today's rule is $873 million per year in increased product costs; while
the estimated benefits are $1,180 million per year in reduced product
operating costs, $314 million per year in CO2 reductions,
and $19.3 million per year in reduced NOX emissions. In this
case, the net benefit would amount to $642 million per year. Using a 3-
percent discount rate for all benefits and costs
[[Page 24176]]
and the average SCC series, the estimated cost of the standards
proposed in today's rule is $751 million per year in increased product
costs; while the estimated benefits are $1,200 million per year in
reduced operating costs, $314 million per year in CO2
reductions, and $18.9 million per year in reduced NOX
emissions. In this case, the net benefit would amount to approximately
$783 million per year.
Table VII.57--Annualized Benefits and Costs of Proposed Standards for GSFL (TSL 5)
----------------------------------------------------------------------------------------------------------------
Primary estimate Low net benefits High net benefits
Discount rate * estimate * estimate *
----------------------------------------------------------------------------------------------------------------
................. Million 2012$/year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings.......... 7%............... 1,180............ 1,160........... 1,220
3%............... 1,200............ 1,170........... 1,250
CO2 Reduction Monetized Value 5%............... 98............... 98.............. 98
($11.8/t case) **.
CO2 Reduction Monetized Value 3%............... 314.............. 314............. 314
($39.7/t case) **.
CO2 Reduction Monetized Value 2.5%............. 456.............. 456............. 456
($61.2/t case) **.
CO2 Reduction Monetized Value 3%............... 968.............. 968............. 968
($117/t case) **.
NOX Reduction Monetized Value 7%............... 19.3............. 19.3............ 19.3
(at $2,639/ton) **.
3%............... 18.9............. 18.9............ 18.9
Total Benefits [dagger]......... 7% plus CO2 range 1,300 to 2,160... 1,280 to 2,140.. 1,340 to 2,210
7%............... 1,520............ 1,490........... 1,560
3% plus CO2 range 1,320 to 2,180... 1,290 to 2,160.. 1,370 to 2,230
3%............... 1,530............ 1,510........... 1,580
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Product Costs....... 7%............... 873.............. 910............. 873
3%............... 751.............. 785............. 751
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger].................. 7% plus CO2 range 426 to 1,291..... 367 to 1,232.... 469 to 1,330
7%............... 642.............. 583............. 685
3% plus CO2 range 567 to 1,432..... 505 to 1,370.... 615 to 1,480
3%............... 783.............. 722............. 831
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with GSFLs shipped in 2017-2046. These
results include benefits to consumers which accrue after 2046 from the products purchased in 2017-2046. The
results account for the incremental variable and fixed costs incurred by manufacturers due to the standard,
some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central
energy prices from AEO2013 and a decreasing incremental product cost, due to price learning. The Low Benefits
Estimate assumes the low estimate of energy prices from AEO2013 and constant real product prices. The High
Benefits Estimate assumes the high energy price estimates from AEO2013 and decreasing incremental product
costs, due to price learning.
** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
3. Benefits and Burdens of Trial Standard Levels Considered for
Incandescent Reflector Lamps
Table VII.58 and Table VII.59 summarize the quantitative impacts
estimated for the potential IRL standards.
Table VII.58--Summary of Analytical Results for IRL: National Impacts
------------------------------------------------------------------------
Category TSL 1
------------------------------------------------------------------------
National FFC Energy Savings Quads
------------------------------------------------------------------------
0.013
------------------------------------------------------------------------
NPV of Consumers Benefits 2012$ Billion
------------------------------------------------------------------------
3% discount rate........................... 0.28
7% discount rate........................... 0.18
------------------------------------------------------------------------
Cumulative Emissions Reduction (Total FFC Emissions)
------------------------------------------------------------------------
CO[ihel2] (million metric tons)............ 0.70
SO[ihel2] (thousand tons).................. 0.69
[[Page 24177]]
NOX (thousand tons)........................ 0.79
Hg (tons).................................. 0.0012
N[ihel2]O (thousand tons).................. 0.0099
N[ihel2]O (thousand tons CO[ihel2]eq) *.... 2.9
CH4 (thousand tons)........................ 2.7
CH4 (thousand tons CO[ihel2]eq) *.......... 68
------------------------------------------------------------------------
Value of Emissions Reduction (Total FFC Emissions)
------------------------------------------------------------------------
CO[ihel2] 2012$ million **................. 6.1 to 75
NOX--3% discount rate 2012$ million........ 1.6
NOX--7% discount rate 2012$ million........ 1.1
------------------------------------------------------------------------
* CO[ihel2]eq is the quantity of CO[ihel2] that would have the same GWP.
** Range of the economic value of CO[ihel2] reductions is based on
estimates of the global benefit of reduced CO[ihel2] emissions.
Table VII.59--Summary of Analytical Results for IRL: Manufacturer and
Consumer Impacts
------------------------------------------------------------------------
Category TSL 1
------------------------------------------------------------------------
Manufacturer Impacts
------------------------------------------------------------------------
Change in Industry NPV 2012$ million **............. (47.5) - (51.8)
Change in Industry NPV % **......................... (27.0) - (29.5)
------------------------------------------------------------------------
Consumer Mean LCC Savings * 2012$
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V....... 2.95
------------------------------------------------------------------------
Consumer Mean PBP * years
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V....... 5.4
Consumers with Net Cost %........................... 0.0
Consumers with Net Benefit %........................ 100.0
Consumers with No Impact %.......................... 0.0
------------------------------------------------------------------------
* Weighted by shares of each equipment class in total projected
shipments in 2017.
** Values in parentheses are negative values.
DOE considered TSL 1, which would save an estimated total of 0.013
quads of energy, an amount DOE considers significant. TSL 1 has an
estimated NPV of consumer benefit of $0.18 billion using a 7 percent
discount rate, and $0.28 billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 1 are 0.70 million
metric tons of CO2, 0.79 thousand tons of NOX,
0.69 thousand tons of SO2, 0.0012 tons of Hg, 2.7 thousand
tons of CH4, and 0.0099 thousand tons of N2O. The
estimated monetary value of the CO2 emissions reductions at
TSL 1 ranges from $6.1 million to $75 million.
At TSL 1, the weighted average LCC savings for the standard
spectrum, > 2.5 inch diameter, < 125 V product class is $2.95. The LCC
savings were positive for both representative lamp units in each
sector.
At TSL 1, the projected change in INPV ranges from a decrease of
$51.8 million to decrease of $47.5 million. If the larger decrease is
realized, TSL 1 could result in a net loss of up to 29.5 percent in
INPV to manufacturers of covered IRLs. Also at TSL 1, DOE estimates
industry would need to invest approximately $71.5 million in conversion
costs.
After considering the analysis and weighing the benefits and the
burdens, DOE concludes that, at TSL 1 for IRLs, the benefits of energy
savings, positive NPV of consumer benefits, positive impacts on
consumers (as indicated by positive average LCC savings and the large
percentage of consumers who would experience LCC benefits), emission
reductions and the estimated monetary value of the emissions reductions
would outweigh the potential reduction in industry value. Consequently,
DOE has concluded that TSL 1 is economically justified.
Based on the above considerations, DOE today proposes to adopt the
energy conservation standards for IRL at TSL 1. Table VII.60 presents
the proposed energy conservation standards for IRL.
Table VII.60--Proposed Energy Conservation Standards for IRL
----------------------------------------------------------------------------------------------------------------
Proposed level
Lamp type Diameter inches Voltage V lm/W
----------------------------------------------------------------------------------------------------------------
Standard Spectrum......................................... >2.5 >=125 7.1P\0.27\
40 W-205 W................................................ <125 6.2P\0.27\
<=2.5 >=125 6.0P\0.27\
<125 5.2P\0.27\
[[Page 24178]]
Modified Spectrum......................................... >2.5 >=125 6.0P\0.27\
40 W-205 W................................................ <125 5.2P\0.27\
<=2.5 >=125 5.1P\0.27\
<125 4.4P\0.27\
----------------------------------------------------------------------------------------------------------------
4. Summary of Benefits and Costs (Annualized) of the Proposed Standards
for Incandescent Reflector Lamps
The benefits and costs of today's proposed standards for IRL, for
product sold in 2017-2046, can also be expressed in terms of annualized
values. The annualized monetary values are the sum of (1) the
annualized national economic value of the benefits from consumer
operation of product that meet the proposed standards (consisting
primarily of operating cost savings from using less energy, minus
increases in product purchase and installation costs, which is another
way of representing consumer NPV), and (2) the annualized monetary
value of the benefits of emission reductions, including CO2
emission reductions.
Estimates of annualized benefits and costs of the proposed
standards for IRL are shown in Table VII.61. The results under the
primary estimate are as follows. Using a 7-percent discount rate for
benefits and costs other than CO2 reduction, for which DOE
used a 3-percent discount rate along with the average SCC series that
uses a 3-percent discount rate, the annualized incremental equipment
cost of the standards proposed in today's rule is negative $10.4
million per year,\94\ and the annualized benefits of the standards
proposed in today's rule are $7.2 million per year in reduced product
operating costs, $1.4 million per year in CO2 reductions,
and $0.11 million per year in reduced NOX emissions. In this
case, the net benefit would amount to $19 million per year. Using a 3-
percent discount rate for all benefits and costs and the average SCC
series, the estimated annualized incremental equipment cost of the
standards proposed in today's rule is negative $9.7 million per
year,\94\ and the annualized benefits of the standards proposed in
today's rule are $5.9 million per year in reduced operating costs, $1.4
million per year in CO2 reductions, and $0.09 million per
year in reduced NOX emissions. In this case, the net benefit
would amount to approximately $17 million per year.
---------------------------------------------------------------------------
\94\ This represents a reduction in product costs compared to
the base case, because the more efficacious products have
substantially longer lifetimes than the products that would be
eliminated by the proposed standard.
Table VII.61--Annualized Benefits and Costs of Proposed Standards for IRL (TSL 1)
----------------------------------------------------------------------------------------------------------------
Low net benefits High net benefits
Discount rate Primary estimate* estimate* estimate*
----------------------------------------------------------------------------------------------------------------
.................. Million 2012$/year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Operating Cost Savings......... 7%................ 7.2............... 7.1............... 10
3%................ 5.9............... 5.8............... 5.8
CO2 Reduction Monetized Value 5%................ 0.5............... 0.5............... 0.5
($11.8/t case)**.
CO2 Reduction Monetized Value 3%................ 1.4............... 1.4............... 1.4
($39.7/t case)**.
CO2 Reduction Monetized Value 2.5%.............. 2.0............... 2.0............... 2.0
($61.2/t case)**.
CO2 Reduction Monetized Value 3%................ 4.2............... 4.2............... 4.2
($117/t case)*.
NOX Reduction Monetized Value 7%................ 0.11.............. 0.11.............. 0.16
(at $2,639/ton)**.
3%................ 0.09.............. 0.09.............. 0.09
Total Benefits [dagger]........ 7% plus CO2 range. 7.8 to 12......... 7.7 to 11......... 7.8 to 12
7%................ 8.7............... 8.6............... 8.7
3% plus CO2 range. 6.4 to 10......... 6.4 to 10......... 6.4 to 10
3%................ 7.4............... 7.3............... 7.3
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Incremental Product Costs 7%................ -10.4............. -10.5............. -10.4
[Dagger].
3%................ -9.7.............. -9.8.............. -9.7
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger]................. 7% plus CO2 range. 18 to 22.......... 18 to 22.......... 18 to 22
7%................ 19................ 19................ 19
3% plus CO2 range. 16 to 20.......... 16 to 20.......... 16 to 20
[[Page 24179]]
3%................ 17................ 17................ 17
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with IRLs shipped in 2017-2046. These results
include benefits to consumers which accrue after 2046 from the products purchased in 2017-2046. The results
account for the incremental variable and fixed costs incurred by manufacturers due to the standard, some of
which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the central energy
prices from AEO2013 and a decreasing incremental product cost, due to price learning. The Low Benefits
Estimate assumes the low estimate of energy prices from AEO2013 and constant real product prices. The High
Benefits Estimate assumes the high energy price estimates from AEO2013 and decreasing incremental product
costs, due to price learning.
** The CO2 values represent global monetized values of the SCC, in 2012$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3-percent and 7-percent cases are derived using the series corresponding to
average SCC with 3-percent discount rate. In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2 range,''
the operating cost and NOX benefits are calculated using the labeled discount rate, and those values are added
to the full range of CO2 values.
[Dagger] This reduction in product costs occurs because the more efficacious products have substantially longer
lifetimes than the products that would be eliminated by the proposed standard.
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that today's standards address are as follows:
(1) There is a lack of consumer information and/or information
processing capability about energy efficiency opportunities in the
lighting market.
(2) There is asymmetric information (one party to a transaction has
more and better information than the other) and/or high transactions
costs (costs of gathering information and effecting exchanges of goods
and services).
(3) There are external benefits resulting from improved energy
efficiency of GSFLs and IRLs that are not captured by the users of such
equipment. These benefits include externalities related to
environmental protection and energy security that are not reflected in
energy prices, such as reduced emissions of GHGs.
In addition, DOE has determined that today's regulatory action is
an ``economically significant regulatory action'' under section 3(f)(1)
of Executive Order 12866. Accordingly, section 6(a)(3) of the Executive
Order requires that DOE prepare a regulatory impact analysis (RIA) on
today's rule and that the Office of Information and Regulatory Affairs
(OIRA) in OMB review this rule. DOE presented to OIRA for review the
draft rule and other documents prepared for this rulemaking, including
the RIA, and has included these documents in the rulemaking record. The
assessments prepared pursuant to Executive Order 12866 can be found in
the technical support document for this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011). EO 13563
is supplemental to and explicitly reaffirms the principles, structures,
and definitions governing regulatory review established in Executive
Order 12866. To the extent permitted by law, agencies are required by
Executive Order 13563 to: (1) Propose or adopt a regulation only upon a
reasoned determination that its benefits justify its costs (recognizing
that some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, the Office of Information and Regulatory Affairs has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. In this NOPR, DOE has taken particular
note of the potential for future volatility in the price of rare earth
oxides used in the manufacture of GSFLs as it affects the future costs
and benefits of the proposed standard. DOE plans to pursue a
retrospective review of rare earth prices as input for any future
updates to GSFL standards. For the reasons stated in the preamble, DOE
believes that today's NOPR is consistent with these with the principles
laid out in Executive Order 13563, including the requirement that, to
the extent permitted by law, benefits justify costs and that net
benefits are maximized.
B. Review Under the Regulatory Flexibility Act
The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
preparation of an initial regulatory flexibility analysis (IRFA) for
any rule that by law must be proposed for public comment, unless the
agency certifies that the rule, if promulgated, will not have a
significant economic impact on a substantial number of small entities.
As required by Executive Order 13272, ``Proper Consideration of Small
Entities in Agency Rulemaking,'' 67 FR 53461 (August 16, 2002), DOE
published procedures and policies on February 19, 2003, to ensure that
the potential impacts of its rules on small entities are properly
considered during the rulemaking process. 68 FR 7990. DOE has made its
procedures and policies available on the Office of the General
[[Page 24180]]
Counsel's Web site (http://energy.gov/gc/office-general-counsel).
As a result of this review, DOE has prepared an IRFA for GSFLs and
IRLs, a copy of which DOE will transmit to the Chief Counsel for
Advocacy of the Small Business Administration (SBA) for review under 5
U.S.C. 605(b). As presented and discussed below, the IFRA describes
potential impacts on GSFL and IRL manufacturers and discusses
alternatives that could minimize these impacts.
A statement of the objectives of, and reasons and legal basis for,
the proposed rule are set forth elsewhere in the preamble and not
repeated here.
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
For manufacturers of GSFLs and IRLs, the SBA has set a size
threshold, which defines those entities classified as ``small
businesses'' for the purposes of the statute. DOE used the SBA's small
business size standards to determine whether any small entities would
be subject to the requirements of the rule. 65 FR 30836, 30848 (May 15,
2000), as amended at 65 FR 53533, 53544 (Sept. 5, 2000) and codified at
13 CFR part 121. The size standards are listed by North American
Industry Classification System (NAICS) code and industry description
available at: http://www.sba.gov/content/table-small-business-size-standards. GSFL and IRL manufacturing is classified under NAICS code
335110, ``Electric Lamp Bulb and Part Manufacturing.'' The SBA sets a
threshold of 1,000 employees or less for an entity to be considered as
a small business for this category.
To estimate the number of companies that could be small business
manufacturers of GSFLs and IRLs covered by this rulemaking, DOE
conducted a market survey using publicly available information. DOE's
research involved industry trade association membership directories
(including NEMA), information from previous rulemakings, individual
company Web sites, SBA's database, and market research tools (e.g.,
Hoover's reports). DOE also asked stakeholders and industry
representatives if they were aware of any small manufacturers during
manufacturer interviews and DOE public meetings. DOE used information
from these sources to create a list of companies that potentially
manufacture or sell GSFLs or IRLs and would be impacted by this
rulemaking. As necessary, DOE contacted companies to determine whether
they met the SBA's definition of a small business manufacturer of GSFLs
or IRLs. DOE screened out companies that do not offer products covered
by this rulemaking, do not meet the definition of a ``small business,''
or are completely foreign owned and operated.
For GSFLs, DOE initially identified a total of 47 potential
companies that sell GSFLs in the United States. After reviewing
publicly available information on these potential GSFL manufacturers,
DOE determined that 26 were either large manufacturers, manufacturers
that were completely foreign owned and operated, or did not sell GSFLs
covered by this rulemaking. DOE then contacted the remaining 21 GSFL
companies to determine whether they met SBA's definition of a small
business and whether they manufactured or sold GSFLs that would be
affected by today's proposal. Based on these efforts, DOE estimated
that there are 21 small businesses that either manufacture or sell
covered GSFLs in the United States.
For IRLs, DOE initially identified a total of 37 potential
companies that sell IRLs in the United States. After reviewing publicly
available information on these potential IRL manufacturers, DOE
determined that 22 were either large manufacturers, manufacturers that
were completely foreign owned and operated, or did not sell IRLs
covered by this rulemaking. DOE then contacted the remaining 15 IRL
companies to determine whether they met SBA's definition of a small
business and whether they manufactured or sold IRLs that would be
affected by today's proposal. Based on these efforts, DOE estimated
that there are 15 small businesses that either manufacture or sell
covered IRLs in the United States.
b. Manufacturer Participation
DOE contacted all 21 identified GSFL small businesses to invite
them to take part in a small business MIA interview. Of the GSFL
manufacturers DOE contacted, eight responded to DOE's email and phone
communications and 13 did not. DOE was able to reach and discuss
potential standards with two of the eight GSFL small business
manufacturers that responded. The remaining six declined DOE's request
to be interviewed for this rulemaking. DOE also contacted all 15
identified IRL small businesses to invite them to take part in a small
business MIA interview. Of the IRL manufacturers DOE contacted, five
responded to DOE's email and phone communications and 10 did not. DOE
was able to reach and discuss potential standards with two of the five
IRL small business manufacturers. The remaining three declined DOE's
request to be interviewed for this rulemaking. DOE also obtained
information about small business manufacturers and potential impacts on
small businesses while interviewing large manufacturers.
c. General Service Fluorescent Lamp and Incandescent Reflector Lamp
Industry Structures and Nature of Competition
Three major manufacturers supply approximately 90 percent of the
GSFL market. None of these three major GSFL manufacturers are small
businesses. DOE estimates that the remaining 10 percent of the GSFL
market is served by either small businesses or manufacturers that are
completely foreign owned and operated. No small business has more than
a three percent market share in the GSFL industry. Similarly in the IRL
market, the same three major GSFL manufacturers supply approximately 80
percent of the IRL market. Again, none of these three major IRL
manufacturers is a small business. DOE estimates that the remaining 20
percent of the IRL market is served by either small businesses or
manufacturers that are completely foreign owned and operated. No small
business has more than three percent of the IRL market individually.
Small businesses that sell covered GSFLs and IRLs tend to be companies
that outsource the manufacturing to overseas companies who produce the
lamps specified by the small businesses. These small businesses provide
the specifications for these lamps as well as the testing and
certification to comply with any U.S. energy conservation standards.
d. Comparison Between Large and Small Entities
For GSFLs and IRLs, small businesses differ from large
manufacturers in several ways that directly affect the extent to which
a company would be impacted by any potential energy conservation
standards. The main differences between small and large entities for
this rulemaking are that small manufacturers of GSFLs and IRLs have
lower sales volumes and are frequently not the original manufacturers
of GSFLs and IRLs. Therefore, these small businesses would not have any
capital conversion costs to comply with amended standards, since the
machinery used to produce GSFLs and IRLs is owned and operated by
overseas manufacturers. The small businesses would most likely
experience higher per-unit costs for the
[[Page 24181]]
products if the conversion costs experienced by the overseas
manufacturers are passed through to the small businesses, potentially
reducing those small business' manufacturer markups and profits. Small
businesses would also have product conversion costs associated with
testing and certifying any lamps that would need to be redesigned due
to standards. Typically the testing and certification costs are
proportional to the number of products offered by a company and not the
volume of sales. Some small businesses stated they could offer up to 75
percent of the number of covered products that large manufacturers
offer; however, the volume of sales for each single product offered by
a small business would be significantly smaller than that of a larger
manufacturer. Consequently, the revenue associated with a single
product is much smaller for small businesses than for large
manufacturers. Therefore, these small businesses could have product
conversion costs in the same range as large manufacturers, since
product conversion costs scale to number of products offered, even
though the total revenue is significantly lower for small businesses
compared to large manufacturers.
Lower sales volumes are the biggest disadvantage for most small
businesses. A lower-volume business' product conversion costs are
spread over fewer units than a larger competitor. Thus, unless the
small business can differentiate its product in some way that earns a
price premium, the small business experiences a reduction in profit
per-unit relative to the large manufacturer. Most small GSFL and IRL
businesses operate in the same lighting markets as large manufacturers
and do not operate in niche GSFL and IRL markets. Much of the same
equipment would need to be purchased by both large manufacturers and
small businesses to produce GSFLs and IRLs at higher efficacy levels.
If the small business is not the original lamp manufacturer, the
manufacturer that sells to the small business would have to purchase
this equipment. Therefore, undifferentiated small businesses would face
a greater per-unit cost penalty because they must spread the conversion
costs over fewer units. While small businesses may not be directly
paying these capital conversion costs, they are still responsible for
selling certified products made by the original lamp manufacturers. The
costs incurred by contracted manufacturers are passed on to small
businesses that must maintain profit margins by either increasing
product prices or decreasing profitability.
2. Description and Estimate of Compliance Requirements
Small GSFL and IRL businesses will be affected differently by the
proposed energy conservation standards compared to large manufacturers.
One of the key differences between large manufacturers and the small
businesses identified by DOE for this rulemaking is that small IRL and
GSFL businesses typically outsource the manufacturing of the lamps they
sell to original equipment manufacturers abroad. This, in addition to
the small volume of sales typical of small businesses, results in small
GSFL and IRL businesses having different types and amounts of
conversion costs compared to large manufacturers.
As a result of this rulemaking, small businesses will incur product
conversion costs because products that no longer meet the proposed
efficacy levels of amended energy conservation standards will most
likely need to be redesigned, retested, and recertified. Since small
businesses have significantly less revenue and annual R&D budgets than
large manufacturers, the product conversion costs necessary to comply
with amended standards represent a significant portion of a small
business' annual revenue. However, unlike large manufacturers, small
businesses will most likely not incur any capital conversion costs due
to amended standards because small businesses usually do not own and
operate the machinery used to manufacture the covered lamps. The
capital conversion costs incurred by original equipment manufacturers
will instead be passed along indirectly to the domestic small
businesses.
In the GSFL market, DOE identified 21 small GSFL businesses with
covered products affected by this rulemaking. It is unlikely that small
GSFL businesses will incur any capital conversion costs because small
businesses usually do not own and operate the machinery used to
manufacture the covered lamps; however, they will likely face
significant product conversion costs to cover R&D, certification, and
testing of products that need to be redesigned to meet the proposed
GSFL efficacy levels of today's NOPR. DOE estimates that approximately
20 percent of the covered products offered by small GSFL manufacturers
meet the proposed efficacy levels at TSL 5. As a result, an average of
approximately 80 percent of products would need to be redesigned to
meet proposed efficacy levels, resulting in small GSFL businesses
incurring more than $1.6 million on average in product conversion costs
or nearly seven times as much as typical annual GSFL R&D expenses. GSFL
sales account for approximately 25 percent of a typical small business'
annual revenue, so redesigning up to 80 percent of those offerings
could have a significant impact on their business. Redesigning a large
majority of product offerings that represent a significant revenue
stream will be more difficult for small businesses, compared to large
businesses, as they have less R&D and revenue.
Table VIII.1--Estimated GSFL Product Conversion Costs as a Percentage of
Annual GSFL R&D Expense
------------------------------------------------------------------------
Product Total conversion
conversion cost cost as a
as a percentage percentage of
of annual R&D annual revenue
expense (percent) (percent)
------------------------------------------------------------------------
Typical Large Manufacturer...... 1 0
Typical Small Manufacturer...... 692 31
------------------------------------------------------------------------
In the IRL market, DOE identified 15 small IRL businesses with
covered products affected by this rulemaking. DOE estimates that a
typical small IRL business will not incur any direct capital conversion
costs at TSL 1, the proposed standard in today's NOPR, since most IRL
small businesses do not own and operate the machinery used to
manufacture IRLs. The small businesses would most likely experience
higher per-unit costs for the products if the
[[Page 24182]]
conversion costs experienced by the overseas manufacturers are passed
through to the small businesses, potentially reducing those small
business' manufacturer markups. Small IRL businesses are expected to
incur product capital conversion costs of approximately $836 thousand
per manufacturer. As Table VIII.2 below illustrates, small businesses
would have significant product conversion costs amounting to nearly
nine times the annual amount spent on IRL R&D. Small IRL businesses
have much smaller annual R&D budgets as well as smaller annual revenue
streams, so incurring the product conversion costs necessary to meet
the efficacy standards at TSL 1 could be problematic for those small
businesses that have a large majority of their IRLs at the baseline
efficacy level. Total conversion cost for a typical small business
could amount to nearly a third that small business' annual IRL revenue.
Table VIII.2--Estimated IRL Product Conversion Costs as a Percentage of
Annual IRL R&D Expense
------------------------------------------------------------------------
Product Total conversion
conversion cost cost as a
as a percentage percentage of
of annual R&D annual revenue
expense (percent) (percent)
------------------------------------------------------------------------
Typical Large Manufacturer...... 387 28
Typical Small Manufacturer...... 852 29
------------------------------------------------------------------------
While some small businesses would have some products meet the IRL
efficacy levels proposed in today's NOPR, there are a few small
businesses that may not be able to meet the IRL efficacy levels
proposed in today's NOPR. Not meeting TSL 1 for IRL products may also
be a strategic decision for some small businesses since IRL products
make up about five percent of a typical small IRL business' revenue.
Therefore, some small lighting businesses may choose to not sell IRLs
covered by this rulemaking and exit the market.
Small businesses in both the IRL and GSFL industries expressed
concern that possible manufacturing downtime, discontinuation of
product lines, and high direct and indirect conversion costs resulting
from amended GSFL and IRL energy conservation standards could have a
significant impact on their revenue and could affect domestic
employment decisions. Domestic employment impacts would be especially
prevalent in the GSFL market where GSFL revenue accounts for
approximately 25 percent of a typical small business' revenue. Domestic
employment impacts would be seen in small business' sales forces and
warehouse staff that could be potentially downsized as a result of
amended GSFL and IRL standards.
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the rule being considered today.
4. Significant Alternatives to the Proposed Rule
The discussion above analyzes impacts on small businesses that
would result from the GSFL TSL and IRL TSL DOE is proposing in today's
notice. Though TSLs lower than the proposed TSLs are expected to reduce
the impacts on small entities, DOE is required by EPCA to establish
standards that achieve the maximum improvement in energy efficiency
that are technically feasible and economically justified, and result in
a significant conservation of energy. Therefore, DOE rejected the lower
TSLs.
The NOPR TSD includes a regulatory impact analysis in chapter 18.
For GSFLs and IRLs, this report discusses the following policy
alternatives in addition to the other TSLs being considered: (1)
Consumer rebates, (2) consumer tax credits, and (3) manufacturer tax
credits. DOE does not intend to consider these alternatives further
because they either are not feasible to implement or are not expected
to result in energy savings as large as those that would be achieved by
the standard levels under consideration.
DOE continues to seek input from businesses that would be affected
by this rulemaking and will consider comments received in the
development of any final rule.
5. Significant Issues Raised by Public Comments
NEMA commented during the framework comment period there is an
added burden of significantly more testing and reporting of a lot of
small sales volume lamps which would result from the proposed increase
in regulations. This increased burden would be much harder on small
business manufacturers, especially if those small business
manufacturers have to pay testing costs to a National Voluntary
Laboratory Accreditation Program (NVLAP) source facility. (NEMA, No. 10
at p. 75) NEMA also commented during the framework comment period that
there is a substantial cumulative effect of numerous concurrent
lighting regulations being carried out in addition to this rulemaking
and small business manufacturers are even harder hit because of this
cumulative regulatory burden. NEMA believes that small business
manufacturers should not have to bear an unfair burden as a result of
overly aggressive policies. (NEMA, No. 10 at pp. 74-75) DOE agrees that
there is potential for small manufacturers to be disproportionately
burdened by additional regulations as a result of additional testing
and reporting costs and from the potential of a cumulative regulatory
burden, DOE outlines its conclusions on the potential impacts of
amended standards on small businesses in the above section of today's
NOPR.
DOE's MIA suggests that most GSFL small businesses will generally
be able to maintain profitability at the TSL proposed in today's
rulemaking. It is possible, however, that small IRL manufacturers could
incur significant conversion costs as a result of this proposed rule,
and those high costs could endanger their IRL business. However, based
on the fact that IRL sales typically only account for a small but non-
trivial overall portion of a small lighting business' sales, DOE does
not believe that any small business will go out of business due to the
IRL standard proposed in today's NOPR. DOE's MIA is based on its
interviews of both small and large manufacturers, and consideration of
the small business impacts explicitly enters into DOE's choice of the
TSLs proposed in today's NOPR.
DOE did not receive any public comments suggesting that small
businesses would not be able to achieve the efficiency levels at TSL 5
for GSFLs and at TSL 1 for IRLs. DOE seeks
[[Page 24183]]
comment on the feasibility of small business to achieve the efficacy
levels for GSFLs and IRLs proposed in today's NOPR.
C. Review Under the Paperwork Reduction Act
Manufacturers of GSFLs and IRLs must certify to DOE that their
products comply with any applicable energy conservation standards. In
certifying compliance, manufacturers must test their products according
to the DOE test procedures for GSFLs and IRLs, including any amendments
adopted for those test procedures. DOE has established regulations for
the certification and recordkeeping requirements for all covered
consumer products and commercial equipment, including GSFLs and IRLs.
76 FR 12422 (March 7, 2011). The collection-of-information requirement
for the certification and recordkeeping is subject to review and
approval by OMB under the Paperwork Reduction Act (PRA). This
requirement has been approved by OMB under OMB control number 1910-
1400. Public reporting burden for the certification is estimated to
average 20 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the
collection of information.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that the proposed rule fits within the category of
actions included in Categorical Exclusion (CX) B5.1 and otherwise meets
the requirements for application of a CX. See 10 CFR Part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The proposed rule fits
within the category of actions because it is a rulemaking that
establishes energy conservation standards for consumer products or
industrial equipment, and for which none of the exceptions identified
in CX B5.1(b) apply. Therefore, DOE has made a CX determination for
this rulemaking, and DOE does not need to prepare an Environmental
Assessment or Environmental Impact Statement for this proposed rule.
DOE's CX determination for this proposed rule is available at http://cxnepa.energy.gov.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on federal agencies formulating and
implementing policies or regulations that preempt state law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the states and
to carefully assess the necessity for such actions. The Executive Order
also requires agencies to have an accountable process to ensure
meaningful and timely input by state and local officials in the
development of regulatory policies that have Federalism implications.
On March 14, 2000, DOE published a statement of policy describing the
intergovernmental consultation process it will follow in the
development of such regulations. 65 FR 13735. EPCA governs and
prescribes Federal preemption of state regulations as to energy
conservation for the products that are the subject of today's proposed
rule. States can petition DOE for exemption from such preemption to the
extent, and based on criteria, set forth in EPCA. (42 U.S.C. 6297) No
further action is required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on Federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; and (3)
provide a clear legal standard for affected conduct rather than a
general standard and promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Section 3(b) of Executive Order 12988 specifically
requires that Executive agencies make every reasonable effort to ensure
that the regulation: (1) Clearly specifies the preemptive effect, if
any; (2) clearly specifies any effect on existing Federal law or
regulation; (3) provides a clear legal standard for affected conduct
while promoting simplification and burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately defines key terms; and (6)
addresses other important issues affecting clarity and general
draftsmanship under any guidelines issued by the Attorney General.
Section 3(c) of Executive Order 12988 requires Executive agencies to
review regulations in light of applicable standards in section 3(a) and
section 3(b) to determine whether they are met or it is unreasonable to
meet one or more of them. DOE has completed the required review and
determined that, to the extent permitted by law, this proposed rule
meets the relevant standards of Executive Order 12988.
G. Review Under the Unfunded Mandates Reform Act of 1995
Title II of the Unfunded Mandates Reform Act of 1995 (UMRA)
requires each Federal agency to assess the effects of Federal
regulatory actions on state, local, and Tribal governments and the
private sector. Public Law 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For a proposed regulatory action likely to result in a rule that may
cause the expenditure by state, local, and Tribal governments, in the
aggregate, or by the private sector of $100 million or more in any one
year (adjusted annually for inflation), section 202 of UMRA requires a
Federal agency to publish a written statement that estimates the
resulting costs, benefits, and other effects on the national economy.
(2 U.S.C. 1532(a), (b)) The UMRA also requires a Federal agency to
develop an effective process to permit timely input by elected officers
of state, local, and Tribal governments on a proposed ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at http://energy.gov/gc/downloads/unfunded-mandates-reform-act-intergovernmental-consultation.
Although today's proposed rule does not contain a Federal
intergovernmental mandate, it may require expenditures of $100 million
or more on the private sector. Specifically, the proposed rule will
likely result in a final rule that could require expenditures of $100
million or more. Such expenditures may include: (1) Investment in
research and development and in capital expenditures by GSFL and IRL
manufacturers in the years between the final rule and the compliance
date for the new standards, and (2) incremental additional expenditures
by consumers to purchase higher-efficiency GSFL and IRL, starting at
the compliance date for the applicable standard.
[[Page 24184]]
Section 202 of UMRA authorizes a Federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the proposed rule. 2 U.S.C. 1532(c). The content
requirements of section 202(b) of UMRA relevant to a private sector
mandate substantially overlap the economic analysis requirements that
apply under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of the NOPR and the ``Regulatory
Impact Analysis'' section of the TSD for this proposed rule respond to
those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. 2 U.S.C. 1535(a). DOE is required to select from those
alternatives the most cost-effective and least burdensome alternative
that achieves the objectives of the proposed rule unless DOE publishes
an explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C.
6295(i)(4)-(5), today's proposed rule would establish energy
conservation standards for GSFLs and IRLs that are designed to achieve
the maximum improvement in energy efficiency that DOE has determined to
be both technologically feasible and economically justified. A full
discussion of the alternatives considered by DOE is presented in the
``Regulatory Impact Analysis'' section of the TSD for today's proposed
rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires Federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (Mar. 18, 1988), that this regulation would not
result in any takings that might require compensation under the Fifth
Amendment to the U.S. Constitution.
J. Review Under the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for Federal agencies to
review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed today's NOPR under the OMB and DOE guidelines
and has concluded that it is consistent with applicable policies in
those guidelines.
K. Review Under Executive Order 13211
Executive Order 13211, ``Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use'' 66 FR 28355
(May 22, 2001), requires Federal agencies to prepare and submit to OIRA
at OMB, a Statement of Energy Effects for any proposed significant
energy action. A ``significant energy action'' is defined as any action
by an agency that promulgates or is expected to lead to promulgation of
a final rule, and that: (1) Is a significant regulatory action under
Executive Order 12866, or any successor order; and (2) is likely to
have a significant adverse effect on the supply, distribution, or use
of energy, or (3) is designated by the Administrator of OIRA as a
significant energy action. For any proposed significant energy action,
the agency must give a detailed statement of any adverse effects on
energy supply, distribution, or use should the proposal be implemented,
and of reasonable alternatives to the action and their expected
benefits on energy supply, distribution, and use.
DOE has tentatively concluded that today's regulatory action, which
sets forth energy conservation standards for GSFLs and IRLs, is not a
significant energy action because the proposed standards are not likely
to have a significant adverse effect on the supply, distribution, or
use of energy, nor has it been designated as such by the Administrator
at OIRA. Accordingly, DOE has not prepared a Statement of Energy
Effects on the proposed rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as scientific information the
agency reasonably can determine will have, or does have, a clear and
substantial impact on important public policies or private sector
decisions. 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report'' dated February 2007 has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
IX. Public Participation
A. Attendance at the Public Meeting
The time, date, and location of the public meeting are listed in
the DATES and ADDRESSES sections at the beginning of this notice. If
you plan to attend the public meeting, please notify Ms. Brenda Edwards
at (202) 586-2945 or [email protected]. As explained in the
ADDRESSES section, foreign nationals visiting DOE Headquarters are
subject to advance security screening procedures.
In addition, you can attend the public meeting via webinar. Webinar
registration information, participant instructions, and information
about the capabilities available to webinar participants will be
published on DOE's Web site at: www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24. Participants are
responsible for ensuring their
[[Page 24185]]
systems are compatible with the webinar software.
B. Procedure for Submitting Prepared General Statements for
Distribution
Any person who has plans to present a prepared general statement
may request that copies of his or her statement be made available at
the public meeting. Such persons may submit requests, along with an
advance electronic copy of their statement in PDF (preferred),
Microsoft Word or Excel, WordPerfect, or text (ASCII) file format, to
the appropriate address shown in the ADDRESSES section at the beginning
of this notice. The request and advance copy of statements must be
received at least one week before the public meeting and may be
emailed, hand-delivered, or sent by mail. DOE prefers to receive
requests and advance copies via email. Please include a telephone
number to enable DOE staff to make follow-up contact, if needed.
C. Conduct of the Public Meeting
DOE will designate a DOE official to preside at the public meeting
and may also use a professional facilitator to aid discussion. The
meeting will not be a judicial or evidentiary-type public hearing, but
DOE will conduct it in accordance with section 336 of EPCA (42 U.S.C.
6306). A court reporter will be present to record the proceedings and
prepare a transcript. DOE reserves the right to schedule the order of
presentations and to establish the procedures governing the conduct of
the public meeting. After the public meeting, interested parties may
submit further comments on the proceedings as well as on any aspect of
the rulemaking until the end of the comment period.
The public meeting will be conducted in an informal, conference
style. DOE will present summaries of comments received before the
public meeting, allow time for prepared general statements by
participants, and encourage all interested parties to share their views
on issues affecting this rulemaking. Each participant will be allowed
to make a general statement (within time limits determined by DOE),
before the discussion of specific topics. DOE will allow, as time
permits, other participants to comment briefly on any general
statements.
At the end of all prepared statements on a topic, DOE will permit
participants to clarify their statements briefly and comment on
statements made by others. Participants should be prepared to answer
questions by DOE and by other participants concerning these issues. DOE
representatives may also ask questions of participants concerning other
matters relevant to this rulemaking. The official conducting the public
meeting will accept additional comments or questions from those
attending, as time permits. The presiding official will announce any
further procedural rules or modification of the above procedures that
may be needed for the proper conduct of the public meeting.
A transcript of the public meeting will be included in the docket,
which can be viewed as described in the Docket section at the beginning
of this notice. In addition, any person may buy a copy of the
transcript from the transcribing reporter.
D. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule before or after the public meeting, but no later than the
date provided in the DATES section at the beginning of this proposed
rule. Interested parties may submit comments, data, and other
information using any of the methods described in the ADDRESSES section
at the beginning of this notice.
Submitting comments via regulations.gov. The regulations.gov Web
page will require you to provide your name and contact information.
Your contact information will be viewable to DOE Building Technologies
staff only. Your contact information will not be publicly viewable
except for your first and last names, organization name (if any), and
submitter representative name (if any). If your comment is not
processed properly because of technical difficulties, DOE will use this
information to contact you. If DOE cannot read your comment due to
technical difficulties and cannot contact you for clarification, DOE
may not be able to consider your comment.
However, your contact information will be publicly viewable if you
include it in the comment itself or in any documents attached to your
comment. Any information that you do not want to be publicly viewable
should not be included in your comment, nor in any document attached to
your comment. Otherwise, persons viewing comments will see only first
and last names, organization names, correspondence containing comments,
and any documents submitted with the comments.
Do not submit to regulations.gov information for which disclosure
is restricted by statute, such as trade secrets and commercial or
financial information (hereinafter referred to as Confidential Business
Information (CBI)). Comments submitted through regulations.gov cannot
be claimed as CBI. Comments received through the Web site will waive
any CBI claims for the information submitted. For information on
submitting CBI, see the Confidential Business Information section
below.
DOE processes submissions made through regulations.gov before
posting. Normally, comments will be posted within a few days of being
submitted. However, if large volumes of comments are being processed
simultaneously, your comment may not be viewable for up to several
weeks. Please keep the comment tracking number that regulations.gov
provides after you have successfully uploaded your comment.
Submitting comments via email, hand delivery/courier, or mail.
Comments and documents submitted via email, hand delivery, or mail also
will be posted to regulations.gov. If you do not want your personal
contact information to be publicly viewable, do not include it in your
comment or any accompanying documents. Instead, provide your contact
information in a cover letter. Include your first and last names, email
address, telephone number, and optional mailing address. The cover
letter will not be publicly viewable as long as it does not include any
comments
Include contact information each time you submit comments, data,
documents, and other information to DOE. If you submit via mail or hand
delivery/courier, please provide all items on a CD, if feasible. It is
not necessary to submit printed copies. No facsimiles (faxes) will be
accepted.
Comments, data, and other information submitted to DOE
electronically should be provided in PDF (preferred), Microsoft Word or
Excel, WordPerfect, or text (ASCII) file format. Provide documents that
are not secured, that are written in English, and that are free of any
defects or viruses. Documents should not contain special characters or
any form of encryption and, if possible, they should carry the
electronic signature of the author.
Campaign form letters. Please submit campaign form letters by the
originating organization in batches of between 50 to 500 form letters
per PDF or as one form letter with a list of supporters' names compiled
into one or more PDFs. This reduces comment processing and posting
time.
Confidential Business Information. According to 10 CFR 1004.11, any
person submitting information that he or she believes to be
confidential and exempt by law from public disclosure should submit via
email, postal mail, or hand delivery/courier two well-marked copies:
one copy of the document
[[Page 24186]]
marked confidential including all the information believed to be
confidential, and one copy of the document marked non-confidential with
the information believed to be confidential deleted. Submit these
documents via email or on a CD, if feasible. DOE will make its own
determination about the confidential status of the information and
treat it according to its determination.
Factors of interest to DOE when evaluating requests to treat
submitted information as confidential include: (1) A description of the
items; (2) whether and why such items are customarily treated as
confidential within the industry; (3) whether the information is
generally known by or available from other sources; (4) whether the
information has previously been made available to others without
obligation concerning its confidentiality; (5) an explanation of the
competitive injury to the submitting person which would result from
public disclosure; (6) when such information might lose its
confidential character due to the passage of time; and (7) why
disclosure of the information would be contrary to the public interest.
It is DOE's policy that all comments may be included in the public
docket, without change and as received, including any personal
information provided in the comments (except information deemed to be
exempt from public disclosure).
E. Issues on Which DOE Seeks Comment
Although DOE welcomes comments on any aspect of this proposal, DOE
is particularly interested in receiving comments and views of
interested parties concerning the following issues:
1. DOE requests comment on the overall methodology, assumptions,
and results of the GSFL and IRL engineering analyses. (See section VI.D
for further details.)
2. In the engineering analysis, DOE selects a baseline lamp as a
reference point against which to measure changes resulting from energy
conservation standards. DOE requests comments on the baseline lamps
selected in this analysis for GSFLs. (See section VI.D.2.c for further
details.)
3. For GSFLs, the baseline and more efficacious substitutes
selected represent the most common lifetimes for each product class.
DOE requests comment on the rated lifetimes of the GSFL baselines and
more efficacious substitutes. (See section VI.D.2.d for further
details.)
4. Because fluorescent lamps operate on a ballast in practice, DOE
analyzed lamp-and-ballast systems in the engineering analysis, to more
accurately capture real-world energy use and light output. DOE requests
comments on its methodology for developing lamp-and-ballast systems as
well as the results of these GSFL systems. (See section VI.D.2.e for
further details.)
5. For GSFLs, DOE requests comment on the max tech levels
identified in this analysis and more information on the accuracy of
catalog and certification data which were used to identify these
levels. (See section VI.D.2.f for further details.)
6. DOE develops ELs based on three factors: (1) The design options
associated with the specific lamps studied; (2) the ability of lamps
across wattages to comply with the standard level of a given product
class; and (3) the max tech EL. DOE requests comments on the
methodology used to develop ELs for GSFLs as well as on the resulting
ELs. (See section VI.D.2.g for further details.)
7. DOE develops scaling factors to scale the levels developed
directly for the representative product classes and determine levels
for product classes not analyzed directly. DOE requests comments on the
scaling factors developed to scale GSFL product classes from the less
than or equal to 4,500 K CCT lamps to the greater than 4,500 K CCT
lamps. DOE also requests comments on the scaling factor developed to
scale from the 4-foot MBP product class to the 2-foot U-shaped product
class. (See section VI.D.2.h for further details.)
8. In the engineering analysis, DOE selects a baseline lamp as a
reference point against which to measure changes resulting from energy
conservation standards. DOE requests comments on the baseline lamps
selected in this analysis for IRLs. (See section VI.D.3.c for further
details.)
9. In the engineering analysis for IRLs, DOE observed lifetime
changes for different technologies. DOE requests comment on the rated
lifetimes of the baseline and more efficacious substitutes. (See
section VI.D.3.d for further details).
10. DOE requests comment on the max tech levels identified in this
analysis and information on high efficacy IRLs including prototype
lamps. (See section VI.D.3.e for further details.)
11. DOE has not found evidence that more efficacious small
diameter, modified spectrum, or 130 V IRLs are not technologically
feasible or practicable to manufacture, and therefore is proposing to
increase efficacy levels for these lamp types. DOE requests comment on
any technological barriers in manufacturing more efficacious small
diameter, modified spectrum, or 130 V rated lamps for commercial
production. (See section VI.D.3.i for further details.)
12. Because GSFLs and IRLs are difficult to reverse-engineer (i.e.,
not easily disassembled), DOE directly estimated end-user prices for
lamps by establishing discounts from manufacturer suggested price
lists. DOE requests feedback on the pricing methodology used in this
analysis. (See section VI.E for further details.)
13. DOE used data published in the 2010 LMC in combination with
CBECS, MECS, and RECS to determine an average weighted electricity
price based on the probability of a GSFL or IRL in a particular
building type in each census division and large state. DOE requests
comment on its methodology of determining average weighted electricity
prices in the LCC. (See section VI.G.6 for further details.)
14. DOE determined LCC savings and PBP results for different
scenarios where consumers need to purchase a lamp (i.e., lamp failure,
ballast failure, and new construction and renovation for GSFLs and lamp
failure and new construction and renovation for IRLs). DOE requests
comments on these lamp purchasing events developed for this analysis.
(See section VI.G.9 for further details.)
15. DOE conducts the LCC and PBP analyses over the lifetime of the
product. DOE considered the impact of group relamping practices on GSFL
lifetime in the commercial and industrial sectors. DOE requests comment
on its spot and group relamping assumptions, particularly the percent
of rated life at which group relamping occurs. DOE also requests
comment on its general approach to determining lamp lifetime for this
analysis. (See section VI.G.10.a for further details.)
16. DOE requests comment on its LCC analysis period assumptions. In
particular, DOE requests comment on basing the analysis period on the
baseline lamp life divided by the annual operating hours of that lamp
for the IRL and the commercial and industrial sector GSFL analyses. DOE
also requests comment on basing the analysis period on the useful life
of the baseline lamp for a specific event for residential GSFLs. (See
section VI.G.12 for further details.)
17. For this rulemaking, DOE analyzed the effects of this proposal
assuming that the GSFLs and IRLs would be available to purchase for 30
years and undertook a sensitivity analysis using 9 years rather than 30
years of product shipments. The choice of a 30-year period of shipments
is consistent with the DOE analysis for
[[Page 24187]]
other products and commercial equipment. The choice of a 9-year period
is a proxy for the timeline in EPCA for the review of certain energy
conservation standards and potential revision of and compliance with
such revised standards. DOE is seeking input, information and data on
whether there are ways to further refine the analytic timeline. (See
section VI.I for further details.)
18. DOE assumes in its shipments and national impacts analyses that
reduced wattage 4-foot MBP lamps can be coupled to dimming ballasts,
but it assumes that no individual reduced wattage lamp option will be
coupled to more than 10 percent of the dimming ballasts in the
installed stock, owing to performance problems that may arise in some
applications. DOE welcomes input on the reasonableness and
appropriateness of these assumptions. (See section VI.I for further
details.)
19. DOE assumes in its reference shipments and national impacts
analyses that the future real price of rare earth oxides used in the
manufacture of GSFLs will remain near current levels on average. DOE
further assumes in an alternative-scenario analysis that the future
price of rare earth oxides may increase owing to market forces outside
of this proposed rulemaking, but DOE assumes that the future price is
not likely to exceed 3.4 times the current price on average. DOE
estimates that the standard proposed here would cause a maximum annual
increase in demand for rare earth oxides of 296 tons in 2017, with
lower demand increases in later years. DOE welcomes input on the
reasonableness and appropriateness of these estimates and assumptions.
(See section VI.I for further details.)
20. DOE assumes in its reference shipments and national impacts
analyses that the future price of xenon gas will remain near current
levels on average. DOE further assumes in an alternative-scenario
analysis that the future price of xenon gas may rise but that it is not
likely to exceed ten times the current price on average. DOE welcomes
input on the reasonableness and appropriateness of these assumptions.
(See section VI.I for further details.)
21. To improve DOE's estimates of the potential impact of lighting
controls on this rulemaking, DOE seeks input on the current fraction of
GSFL ballast shipments that are dimming ballasts and the likely rate of
growth of dimming ballasts in the future. (See section VI.I for further
details.)
22. DOE assumed zero direct rebound effect for efficiency
improvements in GSFLs and IRLs. DOE conducted sensitivity analyses to
evaluate alternative assumptions about rebound. DOE welcomes comment on
its assumptions and methodology for estimating the rebound effect
including potential magnitudes of rebound effects. (See section
VI.J.1for further details.)
23. To calculate the MSP, in the MIA, DOE determined the
distribution chain markup for the GSFL and IRL industries. DOE invites
comment on its methodology of using a 1.52 distribution chain markup in
combination with the medium end-user price to estimate the MSP of all
GSFLs and IRLs. (See section VI.K.2 for further details.)
24. As part of the MIA, DOE estimates the product and capital
conversion costs that all manufacturers must make to comply with
potential standards. DOE requests comment on the $6.1 product
conversion costs and $65.4 capital conversion costs necessary for IRL
manufacturers to comply with the proposed standards. (See sections
VI.K.2.a and VII.B.2.a for further details.)
25. DOE solicits comment on the application of the new SCC values
used to determine the social benefits of CO2 emissions
reductions over the rulemaking analysis period. (The rulemaking
analysis period covers from 2017 to 2046 plus the appropriated number
of years to account for the lifetime of the equipment purchased between
2017 and 2046.) In particular, the agency solicits comment on the
agency's derivation of SCC values after 2050 where the agency applied
the average annual growth rate of the SCC estimates in 2040-2050
associated with each of the four sets of values. (See section VI.M.1
for further details.)
26. As part of the MIA, DOE quantitatively assessed the impacts of
potential amended energy conservation standards on direct employment.
DOE seeks comment on the potential domestic employment impacts to GSFL
and IRL manufacturers at the proposed efficacy levels. (See section
VII.B.2.b for further details.)
27. In the cumulative regulatory burden analysis, DOE assess the
combined effects of recent or impending regulations on manufacturers.
DOE seeks comment on the compliance costs of any other regulations GSFL
or IRL manufacturers must make, especially if compliance with those
regulations is required three years before or after the estimated
compliance date of these proposed standards (2017). (See section
VII.B.2.e for further details.)
28. As part of the cumulative regulatory burden analysis, DOE
examines how the proposed standards affect manufacturers complying with
other regulations. Since GSFL manufacturers must also comply with the
Minimata Convention on Mercury, DOE seeks comment on GSFL manufacturers
potentially increasing the amount of mercury in GSFLs in order to
comply with the proposed GSFL standards. (See section VII.B.2.e for
further details.)
29. For the proposed GSFL standards, DOE requests comment on the
reasonableness of its assumption that first cost is a significant
driver of consumers' choice of product class, which results in the
shipments analysis projecting a rapid shift from 4-foot MBP T8s to
standard output T5s in the TSL 5 standards case. The TSL 5 standards
case substantially increases first cost for 4-foot MBP T8s. (See
section VII.B.3 for further details.)
30. Noting that DOE projects a sharp decrease in total GSFL
shipments both with and without standards during the rulemaking period
because of the projected sharp incursion of LEDs into the GSFL market--
DOE seeks comment on the reasonableness of the shipments model
projection for TSL 5, specifically, that standard output T5 lamps could
increase from 3 to 4 percent of the standard output GSFL market
presently, to approximately 13 percent of the same market by 2020, and
to approximately 30 percent of the much attenuated standard output GSFL
market by 2046. (See section VII.B.3 for further details.)
31. DOE requests comment on its assumption that there will be no
lessening of utility or performance such that the performance
characteristics, including lumen package, color quality, lifetime, and
ability to dim, would be adversely affected for the GSFL efficacy
levels. (See sections VII.B.4, VI.A, VI.B, VI.C, and VI.D for further
details.)
32. DOE requests comment on whether there are features or
attributes, including physical constraints such as shape or diameter,
of the more energy-efficient GSFL lamps that manufacturers would
produce to meet the standards in this proposed rule that might affect
how they would be used by consumers. DOE requests comment specifically
on how any such effects should be weighed in the choice of standards
for GSFLs for the final rule.
33. DOE requests comment on its assumption that there will be no
lessening of utility or performance such that the performance
characteristics, including lumen package and lifetime, would be
adversely affected for the IRL efficacy levels. (See sections VII.B.4,
VI.A, VI.B, VI.C, and VI.D for further details.)
34. DOE requests comment on whether there are features or
attributes,
[[Page 24188]]
such as the shape or diameter, of the more energy-efficient IRL lamps
that manufacturers would produce to meet the standards in this proposed
rule that might affect how they would be used by consumers. DOE
requests comment specifically on how any such effects should be weighed
in the choice of standards for the IRLs for the final rule.
35. Due to the assumed shifts in shipments between product classes,
the energy savings and monetized cost and benefit values computed for a
single product class, considered in isolation, may yield negative
energy savings but are more than offset by the large positive
contributions to the aggregate energy savings and monetized benefits
across all product classes. The expected switching between product
classes also led to an aggregate negative cost estimate for the
proposed standard level. In part due to the negative cost estimate for
IRLs, DOE requests comment on the consumer choice model that projects
shifts in shipments between product classes and whether there are other
factors (e.g. utility, costs to replace light fixtures, design
incompatibility) that may preclude or limit that shifting that may not
be considered in DOE's analysis. (See section VII.3.c. and chapter 12
of the TSD for more details).
36. The Regulatory Flexibility Act (5 U.S.C. 601 et seq.) requires
DOE to analyze the impact of its proposed standards on small entities,
as well as any alternatives that accomplish the stated objectives of
EPCA and minimize any significant economic impact of the proposed rule
on small entities. DOE requests comment on the potential impacts to
GSFL and IRL small businesses at the proposed efficacy levels. (See
section VIII.B for further details.)
X. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's
proposed rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Intergovernmental relations, Reporting and recordkeeping requirements,
and Small businesses.
Issued in Washington, DC, on April 11, 2014.
David T. Danielson,
Assistant Secretary, Energy Efficiency and Renewable Energy.
For the reasons set forth in the preamble, DOE proposes to amend
part 430 of chapter II, subchapter D, of title 10 of the Code of
Federal Regulations, as set forth below:
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
1. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
2. In Sec. 430.2, add the definitions for ``700 series fluorescent
lamp'', ``Designed and marketed,'' ``Fluorescent lamp designed for use
in reprographic equipment,'' ``Impact-resistant fluorescent lamp,''
``Lamps primarily designed to produce radiation in the ultra-violet
region of the spectrum,'' ``Reflectorized or aperture lamp,'' in
alphabetical order, and revise the definition for ``fluorescent lamp''
to read as follows:
Sec. 430.2 Definitions.
* * * * *
700 series fluorescent lamp means a fluorescent lamp with a color
rendering index (measured according to the test procedures outlined in
Appendix R to subpart B of this part) that is in the range (inclusive)
of 70 to 79.
* * * * *
Designed and marketed means that the intended application of the
lamp is stated in a publicly available document (e.g., product
literature, catalogs, packaging labels, and labels on the product
itself). This definition is applicable to terms related to the
following covered lighting products: fluorescent lamp ballasts;
fluorescent lamps; general service fluorescent lamps; general service
incandescent lamps; incandescent lamps; incandescent reflector lamps;
medium base compact fluorescent lamps; and specialty application
mercury vapor lamp ballasts.
* * * * *
Fluorescent lamp means a low pressure mercury electric-discharge
source in which a fluorescing coating transforms some of the
ultraviolet energy generated by the mercury discharge into light,
including only the following:
(1) Any straight-shaped lamp (commonly referred to as 4-foot medium
bipin lamps) with medium bipin bases of nominal overall length of 48
inches and rated wattage of 25 or more;
(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases of nominal overall length between 22 and
25 inches and rated wattage of 25 or more;
(3) Any rapid start lamp (commonly referred to as 8-foot high
output lamps) with recessed double contact bases of nominal overall
length of 96 inches;
(4) Any instant start lamp (commonly referred to as 8-foot slimline
lamps) with single pin bases of nominal overall length of 96 inches and
rated wattage of 49 or more;
(5) Any straight-shaped lamp (commonly referred to as 4-foot
miniature bipin standard output lamps) with miniature bipin bases of
nominal overall length between 45 and 48 inches and rated wattage of 25
or more; and
(6) Any straight-shaped lamp (commonly referred to 4-foot miniature
bipin high output lamps) with miniature bipin bases of nominal overall
length between 45 and 48 inches and rated wattage of 44 or more.
* * * * *
Fluorescent lamp designed for use in reprographic equipment means a
fluorescent lamp intended for use in equipment used to reproduce,
reprint, or copy graphic material.
* * * * *
Impact-resistant fluorescent lamp means a lamp that
(1) Has a coating or equivalent technology that is compliant with
NSF/ANSI 51 (incorporated by reference; see Sec. 430.3) and is
designed to contain the glass if the glass envelope of the lamp is
broken; and
(2) Is designated and marketed for the intended application, with:
(i) The designation on the lamp packaging; and
(ii) Marketing materials that identify the lamp as being impact-
resistant, shatter-resistant, shatter-proof, or shatter-protected.
* * * * *
Lamps primarily designed to produce radiation in the ultra-violet
region of the spectrum mean fluorescent lamps that primarily emit light
in the portion of the electromagnetic spectrum where light has a
wavelength between 10 and 400 nanometers.
* * * * *
Reflectorized or aperture lamp means a fluorescent lamp that
contains an inner reflective coating on the bulb to direct light.
* * * * *
0
3. Section 430.32 is amended by revising paragraph (n) to read as
follows:
Sec. 430.32 Energy and water conservation standards and their
effective dates.
* * * * *
(n) General service fluorescent lamps and incandescent reflector
lamps. (1) Except as provided in paragraphs (n)(2),
[[Page 24189]]
(n)(3), and (n)(4) of this section, each of the following general
service fluorescent lamps manufactured after the effective dates
specified in the table shall meet or exceed the following lamp efficacy
and CRI standards:
----------------------------------------------------------------------------------------------------------------
Minimum average
Lamp type Nominal lamp Minimum CRI lamp efficacy lm/ Effective date
wattage W
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin................ >35 W 69 75.0 Nov. 1, 1995.
<=35 W 45 75.0 Nov. 1, 1995.
2-foot U-shaped.................... >35 W 69 68.0 Nov. 1, 1995.
<=35 W 45 64.0 Nov. 1, 1995.
8-foot slimline.................... >65 W 69 80.0 May 1, 1994.
<=65 W 45 80.0 May 1, 1994.
8-foot high output................. >100 W 69 80.0 May 1, 1994.
<=100 W 45 80.0 May 1, 1994.
----------------------------------------------------------------------------------------------------------------
(2) The standards described in paragraph (n)(1) of this section do
not apply to:
(i) Any 4-foot medium bipin lamp or 2-foot U-shaped lamp with a
rated wattage less than 28 watts;
(ii) Any 8-foot high output lamp not defined in ANSI C78.81
(incorporated by reference; see Sec. 430.3) or related supplements, or
not 0.800 nominal amperes; or
(iii) Any 8-foot slimline lamp not defined in ANSI C78.3
(incorporated by reference; see Sec. 430.3).
(3) Except as provided in paragraph (n)(4) of this section, each of
the following general service fluorescent lamps manufactured after July
14, 2012, shall meet or exceed the following lamp efficacy standards
shown in the table:
------------------------------------------------------------------------
Minimum average
Lamp type Correlated color lamp efficacy lm/
temperature W
------------------------------------------------------------------------
4-foot medium bipin............. <=4,500K............ 89
>4,500K and <=7,000K 88
2-foot U-shaped................. <=4,500K............ 84
>4,500K and <=7,000K 81
8-foot slimline................. <=4,500K............ 97
>4,500K and <=7,000K 93
8-foot high output.............. <=4,500K............ 92
>4,500K and <=7,000K 88
4-foot miniature bipin standard <=4,500K............ 86
output.
>4,500K and <=7,000K 81
4-foot miniature bipin high <=4,500K............ 76
output.
>4,500K and <=7,000K 72
------------------------------------------------------------------------
(4) Each of the following general service fluorescent lamps
manufactured on or after [3 Years after Date of Publication of final
rule in the Federal Register], shall meet or exceed the following lamp
efficacy standards shown in the table:
------------------------------------------------------------------------
Minimum average
Lamp type Correlated color lamp efficacy lm/
temperature W
------------------------------------------------------------------------
4-foot medium bipin............. <=4,500K............ 92.4
>4,500K and <=7,000K 90.6
2-foot U-shaped................. <=4,500K............ 86.9
>4,500K and <=7,000K 84.3
8-foot slimline................. <=4,500K............ 99.0
>4,500K and <=7,000K 94.1
8-foot high output.............. <=4,500K............ 97.6
>4,500K and <=7,000K 95.6
4-foot miniature bipin standard <=4,500K............ 97.1
output.
>4,500K and <=7,000K 91.3
4-foot miniature bipin high <=4,500K............ 82.7
output.
>4,500K and <=7,000K 78.6
------------------------------------------------------------------------
[[Page 24190]]
(5) Except as provided in paragraphs (n)(6) and (n)(7) of this
section, each of the following incandescent reflector lamps
manufactured after November 1, 1995, shall meet or exceed the lamp
efficacy standards shown in the table:
------------------------------------------------------------------------
Minimum average
Nominal lamp wattage lamp efficacy lm/
W
------------------------------------------------------------------------
40-50................................................. 10.5
51-66................................................. 11.0
67-85................................................. 12.5
86-115................................................ 14.0
116-155............................................... 14.5
156-205............................................... 15.0
------------------------------------------------------------------------
(6) Except as provided in paragraph (n)(7) of this section each of
the following incandescent reflector lamps manufactured after July 14,
2012, shall meet or exceed the lamp efficacy standards shown in the
table:
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy lm/
inches W
----------------------------------------------------------------------------------------------------------------
40-205........................... Standard Spectrum...... >2.5 >=125 V 6.8*P\0.27\
<125 V 5.9*P\0.27\
<=2.5 >=125 V 5.7*P\0.27\
<125 V 5.0*P\0.27\
40-205........................... Modified Spectrum...... >2 .5 >=125 V 5.8*P\0.27\
<125 V 5.0*P\0.27\
<=2.5 >=125 V 4.9*P\0.27\
<125 V 4.2*P\0.27\
----------------------------------------------------------------------------------------------------------------
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified
spectrum in 430.2.
(7) Each of the following incandescent reflector lamps with the
exception of BPAR, BR, and ER lamps manufactured on or after [3 Years
after Date of Publication of final rule in the Federal Register], shall
meet or exceed the following lamp efficacy standards shown in the
table:
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy lm/
inches W
----------------------------------------------------------------------------------------------------------------
40-205........................... Standard Spectrum...... >2.5 >=125V 7.1P\0.27\
<125V 6.2P\0.27\
<=2.5 >=125V 6.0P\0.27\
<125V 5.2P\0.27\
40-205........................... Modified Spectrum...... >2.5 >=125V 6.0P\0.27\
<125V 5.2P\0.27\
<=2.5 >=125V 5.1P\0.27\
<125V 4.4P\0.27\
----------------------------------------------------------------------------------------------------------------
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified
spectrum in 430.2.
(8)(i)(A) Subject to the exclusions in paragraph (n)(8)(ii) of this
section, the standards specified in this section shall apply to ER
incandescent reflector lamps, BR incandescent reflector lamps, BPAR
incandescent reflector lamps, and similar bulb shapes on and after
January 1, 2008.
(B) Subject to the exclusions in paragraph (n)(8)(ii) of this
section, the standards specified in this section shall apply to
incandescent reflector lamps with a diameter of more than 2.25 inches,
but not more than 2.75 inches, on and after June 15, 2008.
(ii) The standards specified in this section shall not apply to the
following types of incandescent reflector lamps:
(A) Lamps rated at 50 watts or less that are ER30, BR30, BR40, or
ER40 lamps;
(B) Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; or
(C) R20 incandescent reflector lamps rated 45 watts or less.
* * * * *
[FR Doc. 2014-08740 Filed 4-24-14; 8:45 am]
BILLING CODE 6450-01-P