[Federal Register Volume 79, Number 106 (Tuesday, June 3, 2014)]
[Proposed Rules]
[Pages 32020-32048]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2014-12127]
[[Page 32019]]
Vol. 79
Tuesday,
No. 106
June 3, 2014
Part II
Department of Energy
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10 CFR Parts 429 and 430
Energy Conservation Program: Test Procedures for Integrated Light-
Emitting Diode Lamps; Proposed Rule
Federal Register / Vol. 79 , No. 106 / Tuesday, June 3, 2014 /
Proposed Rules
[[Page 32020]]
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DEPARTMENT OF ENERGY
10 CFR Parts 429 and 430
[Docket No. EERE-2011-BT-TP-0071]
RIN 1904-AC67
Energy Conservation Program: Test Procedures for Integrated
Light-Emitting Diode Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Supplemental notice of proposed rulemaking.
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SUMMARY: On April 9, 2012, the U.S. Department of Energy (DOE)
published a notice of proposed rulemaking (NOPR) in which DOE proposed
a test procedure for light-emitting diode (LED) lamps (hereafter
referred to as LED lamps). This supplemental notice of proposed
rulemaking (SNOPR), revises DOE's proposal for a new test procedure for
LED lamps. This SNOPR supports implementation of labeling provisions by
the Federal Trade Commission (FTC) and implementation of DOE's energy
conservation standards for general service lamps that includes general
service LED lamps. The SNOPR continues to define methods for measuring
the lumen output, input power, and relative spectral distribution (to
determine correlated color temperature, or CCT). Further, the SNOPR
revises the method for calculating the lifetime of LED lamps, and
defines the lifetime as the time required for the LED lamp to reach a
lumen maintenance of 70 percent (that is, 70 percent of initial light
output). Additionally, the SNOPR adds calculations for lamp efficacy as
well as the color rendering index (CRI) of LED lamps, which were not
proposed in the test procedure NOPR.
DATES: DOE will accept comments, data, and information regarding this
SNOPR, but no later than August 4, 2014. See section V, ``Public
Participation,'' for details.
ADDRESSES: Any comments submitted must identify the SNOPR for Test
Procedures for LED lamps, and provide docket number EE-2011-BT-TP-0071
and/or regulatory information number (RIN) number 1904-AC67. 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 Office, Mailstop EE-5B, 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. It is not necessary to include printed
copies.
For detailed instructions on submitting comments and additional
information on the rulemaking process, see section V of this document
(Public Participation).
Docket: The docket is available for review at regulations.gov,
including Federal Register notices, public meeting attendee lists and
transcripts, comments, and other supporting documents/materials. All
documents in the docket are listed in the regulations.gov index.
However, not all documents listed in the index may be publicly
available, such as information that is exempt from public disclosure.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/18. This Web page will contain a link to the docket for this
notice on the regulations.gov site. The regulations.gov Web page
contains simple instructions on how to access all documents, including
public comments, in the docket. See section V for information on how to
submit comments through 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 Office, EE-5B, 1000 Independence Avenue SW., Washington,
DC, 20585-0121. Telephone: (202) 287-1604. Email: [email protected].
Ms. Celia Sher, U.S. Department of Energy, Office of the General
Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC, 20585-
0121. Telephone: (202) 287-6122. Email: [email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Authority and Background
II. Summary of the Supplemental Notice of Proposed Rulemaking
III. Discussion
A. Scope of Applicability
B. Standby and Off-Mode
C. Proposed Approach for Determining Lumen Output, Input Power,
Lamp Efficacy, Correlated Color Temperature, and Color Rendering
Index
1. NOPR Proposals
2. Test Conditions
3. Test Setup
4. Test Method
D. Proposed Approach for Lifetime Measurements
1. LED Lamp Lifetime Definition
2. NOPR Proposals
3. SNOPR Proposed Lifetime Method
E. Proposed Approach for Standby Mode Power
F. Basic Model, Sampling Plan, and Reported Value
1. Basic Model
2. Sampling Plan
3. Reported Value
G. Rounding Requirements
1. Lumen Output
2. Input Power
3. Lamp Efficacy
4. Correlated Color Temperature
5. Color Rendering Index
6. Annual Energy Cost
7. Lifetime
8. Life
9. Standby Mode Power
H. Acceptable Methods for Initial Certification or Labeling
I. Laboratory Accreditation
J. State Preemption for Efficiency Metrics
K. Effective and Compliance Date
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
B. Review under the Regulatory Flexibility Act
1. Estimated Small Business Burden
2. Duplication, Overlap, and Conflict With Other Rules and
Regulations
3. Significant Alternatives to the Proposed Rule
C. Review Under the Paperwork Reduction Act of 1995
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 Treasury and General Government Appropriations
Act, 2001
K. Review Under Executive Order 13211
L. Review Under Section 32 of the Federal Energy Administration
Act of 1974
V. Public Participation
A. Submission of Comments
B. Issues on Which DOE Seeks Comment
VI. Approval of the Office of the Secretary
I. Authority and Background
Title III of the Energy Policy and Conservation Act of 1975 (42
U.S.C. 6291, et seq.; ``EPCA'') sets forth a variety of provisions
designed to improve energy efficiency. (All
[[Page 32021]]
references to EPCA refer to the statute as amended through the American
Energy Manufacturing Technical Corrections Act (AEMTCA), Public Law
112-210 (Dec. 18, 2012)). Part B of title III, which for editorial
reasons was redesignated as Part A upon incorporation into the U.S.
Code (42 U.S.C. 6291-6309, as codified), establishes the ``Energy
Conservation Program for Consumer Products Other Than Automobiles.''
Under EPCA, this program consists of four parts: (1) testing, (2)
labeling, (3) Federal energy conservation standards, and (4)
certification and enforcement procedures. This SNOPR proposes test
procedures that manufacturers of integrated LED lamps (hereafter
referred to as ``LED lamps'') would use to meet two requirements,
namely, to: (1) satisfy any future energy conservation standards for
general service LED lamps, and (2) meet obligations under labeling
requirements for LED lamps promulgated by the Federal Trade Commission
(FTC).
First, this SNOPR would be used to assess the performance of LED
lamps relative to any potential energy conservation standards in a
future rulemaking that includes general service LED lamps. DOE is
currently developing energy conservation standards for general service
lamps (GSLs), a category of lamps that includes general service LED
lamps. See 78 FR 73737 (Dec. 9, 2013).
Second, the LED lamp SNOPR supports obligations under labeling
requirements promulgated by FTC under section 324(a)(6) of EPCA (42
U.S.C. 6294(a)(6)). The Energy Independence and Security Act of 2007
(EISA 2007) section 321(b) amended EPCA (42 U.S.C. 6294(a)(2)(D)) to
direct FTC to consider the effectiveness of lamp labeling for power
levels or watts, light output or lumens, and lamp lifetime. This SNOPR
supports FTC's determination that LED lamps, which had previously not
been labeled, require labels under EISA section 321(b) and 42 U.S.C.
6294(a)(6) in order to assist consumers in making purchasing decisions.
75 FR 41696, 41698 (July 19, 2010).
FTC published a final rule for light bulb \1\ labeling (Lighting
Facts) that required compliance on January 1, 2012. 75 FR 41696 (July
19, 2010). The FTC Lighting Facts label covers three types of medium
screw base lamps: general service incandescent lamps (GSIL), compact
fluorescent lamps (CFL), and general service LED lamps.\2\ The label
requires manufacturers to disclose information about the lamp's
brightness \3\ (lumen output), estimated annual energy cost, life \4\
(lifetime), light appearance (CCT), and energy use (input power). FTC
requires manufacturers to calculate the estimated annual energy cost by
multiplying together the energy used, annual operating hours, and an
estimate for energy cost per kilowatt-hour. FTC references DOE test
procedures, when available, for testing lamps for the FTC Lighting
Facts label. See 42 U.S.C. 6294(c). This SNOPR would enable FTC to
reference a DOE test procedure for LED lamps. DOE invites comments on
all aspects of the SNOPR for LED lamps.
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\1\ FTC uses the term `bulb,' while DOE uses the term `lamp.'
Bulb and lamp refer to the same product.
\2\ FTC defines general service LED lamps as a lamp that is a
consumer product; has a medium screw base; has a lumen range not
less than 310 lumens and not more than 2,600 lumens; and is capable
of being operated at a voltage range at least partially within 110
and 130 volts. This proposed test procedure rulemaking could be
applied to general service LED lamps as defined by FTC as well as
all other integrated LED lamps as discussed in section 0 of this
SNOPR.
\3\ Although `light output' is the technically correct term, FTC
uses the term `brightness' on the Lighting Facts label because FTC's
research indicated that consumers prefer the term `brightness' to
`light output.'
\4\ FTC uses the term `life' while DOE uses the term `lifetime.'
Life and lifetime have the same meaning.
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II. Summary of the Supplemental Notice of Proposed Rulemaking
In this SNOPR, DOE proposes test procedures for determining the
lumen output, input power, lamp efficacy, CCT, CRI, lifetime, and
standby mode power of an LED lamp. DOE proposes to define an LED lamp
using the ANSI \5\/IESNA \6\ RP-16-2010 \7\ definition of an integrated
LED lamp. DOE pursued an SNOPR for two main reasons: (1) to revise the
method of measuring lifetime based on public comment and (2) to add
directions for calculating the metrics lamp efficacy and CRI and
standby mode power to support the ongoing general service lamp
rulemaking. To determine lumen output, input power, CCT, and CRI, DOE
proposes to incorporate by reference IES LM-79-2008.\8\ DOE reviewed
several potential approaches to testing lamp lumen output, input power,
CCT, and CRI, and determined that this IES standard is the most
appropriate based on discussions with industry experts. IES LM-79-2008
appears to yield reliable results, and industry generally uses it to
measure photometric characteristics of LED lamps. To determine the
standby mode power, DOE proposes to incorporate by reference
International Electrotechnical Commission (IEC) 62301.\9\ In addition,
DOE proposes to calculate the efficacy of an LED lamp in units of
lumens per watt by dividing the measured initial lamp lumen output in
lumens by the measured lamp input power in watts. Lastly, no industry
standards are available for determining the lifetime of LED lamps.
Therefore, the SNOPR proposes a method for measuring and projecting LED
lamp lifetime that uses a continuous equation based on the underlying
exponential decay function in the ENERGY STAR Program Requirements for
Lamps (Light Bulbs): Eligibility Criteria--Version 1.0.\10\
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\5\ American National Standards Institute.
\6\ Illuminating Engineering Society of North America (also
abbreviated as IES).
\7\ ``Nomenclature and Definitions for Illuminating
Engineering.'' Approved by ANSI on October 16, 2009. Approved by IES
on November 15, 2009.
\8\ ``Approved Method: Electrical and Photometric Measurements
of Solid-State Lighting Products.'' Approved by IES on December 31,
2007.
\9\ ``Household electrical appliances--Measurement of standby
power.'' Edition 2.0 2011-01.
\10\ ``ENERGY STAR Program Requirements for Lamps (Light Bulbs):
Eligibility Criteria--Version 1.0.'' U.S. Environmental Protection
Agency, August 28, 2013.
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III. Discussion
A. Scope of Applicability
EISA 2007 section 321(a)(1)(B) added the definition for LED as a p-
n junction \11\ solid state device, the radiated output of which,
either in the infrared region, the visible region, or the ultraviolet
region, is a function of the physical construction, material used, and
exciting current \12\ of the device. (42 U.S.C. 6291(30)(CC)) In the
NOPR, published on April 9, 2012, DOE stated that this rulemaking
applies to LED lamps that meet DOE's proposed definition of an LED
lamp, which is based on the term as defined by ANSI/IESNA RP-16-2010,
``Nomenclature and Definitions for Illuminating Engineering.'' This
standard defines integrated LED lamps as an integrated assembly that
comprises LED packages (components) or LED arrays (modules)
(collectively referred to as an LED source), LED driver, ANSI standard
base, and other optical, thermal, mechanical and electrical components
(such as phosphor layers, insulating materials, fasteners to hold
components within the lamp together, and electrical wiring). The LED
lamp is intended to connect directly to a branch circuit through a
corresponding ANSI standard
[[Page 32022]]
socket. 77 FR 21038, 21041 (April 9, 2012)
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\11\ P-n junction is the boundary between p-type and n-type
material in a semiconductor device, such as LEDs. P-n junctions are
active sites where current can flow readily in one direction but not
in the other direction--in other words, a diode.
\12\ Exciting current is the current passing through an LED chip
during steady state operation.
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The National Electrical Manufacturers Association (hereafter
referred to as NEMA) agreed with the proposed scope and incorporation
of ANSI/IESNA RP-16-2010 for the definition of LED lamps. (NEMA, Public
Meeting Transcript, No. 7 at p. 2 \13\) DOE received no adverse comment
on this proposal. Thus, in this SNOPR, DOE proposes to maintain the
scope and definition of LED lamps.
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\13\ A notation in the form ``NEMA, Public Meeting Transcript,
No. 7 at p. 2'' identifies a statement made in a public meeting that
DOE has received and has included in the docket of this rulemaking.
This particular notation refers to a comment: (1) submitted during
the public meeting on May 3, 2012; (2) in document number 7 in the
docket of this rulemaking; and (3) appearing on page 2 of the
transcript.
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B. Standby and Off-Mode
EPCA directs DOE to amend test procedures ``to include standby mode
and off mode energy consumption . . . with such energy consumption
integrated into the overall energy efficiency, energy consumption, or
other energy descriptor for each covered product, unless the Secretary
determines that--(i) the current test procedures for a covered product
already fully account for and incorporate the standby and off mode
energy consumption of the covered product . . .'' 42 U.S.C.
6295(gg)(2)(A(i) Because LED lamps are placed in Part A of EPCA, they
are covered consumer products, and thus the standby and off mode
applicability of these products must be reviewed.
First, to provide context for standby and off-modes, active mode is
defined as the condition in which an energy-using product--is connected
to a main power source; has been activated; and provides one or more
main functions.10 CFR 430.2 DOE's proposals for active mode test
metrics include lumen output, input power, lamp efficacy, CCT, CRI, and
lifetime.
Standby mode is defined as the condition in which energy-using
product--is connected to a main power source; and offers one or more of
the following user-oriented or protective functions: to facilitate the
activation or deactivation of other functions (including active mode)
by remote switch (including remote control), internal sensor, or timer;
or continuous functions, including information or status displays
(including clocks) or sensor-based functions.10 CFR 430.2 Some LED
lamps can be operated by a remote control to activate active mode or to
change the appearance of the light (color or dimming). Therefore,
standby mode applies to LED lamps.
Off mode is defined as the condition in which an energy using
product--is connected to a main power source; and is not providing any
standby or active mode function.10 CFR 430.2 LED lamps do not operate
in off mode because when connected to a main power source, the LED lamp
is either in active mode or standby mode. No other modes of operation
exist for LED lamps beyond active and standby mode.
EPCA directs DOE to amend its test procedures for all covered
products to integrate measures of standby mode and off mode energy
consumption, if technically feasible. (42 U.S.C. 6295(gg)(2)(A))
Standby mode and off mode energy must be incorporated into the overall
energy efficiency, energy consumption, or other energy descriptor for
each covered product unless the current test procedures already account
for and incorporate standby and off mode energy consumption or such
integration is technically infeasible. If an integrated test procedure
is technically infeasible, DOE must prescribe a separate standby mode
and off mode energy use test procedure for the covered product, if
technically feasible. Id. Any such amendment must consider the most
current versions of IEC Standard 62301, ``Household electrical
appliances--measurement of standby power,'' and IEC Standard 62087,
``Methods of measurements for the power consumption of audio, video,
and related equipment,'' \14\ as applicable.
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\14\ IEC standards are available online at www.iec.ch.
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DOE proposes separate test methods for standby and active mode
metrics. This proposal is consistent with other lighting products
(fluorescent lamp ballasts and metal halide ballasts) which use
separate test methods for active and standby modes. Any future energy
conservation standards that cover LED lamps will consider the most
effective method of addressing both active and standby mode energy use.
DOE proposes a method of measuring standby mode power in section III.E.
DOE requests comment on its characterization of the modes of
operation that apply to LED lamps.
C. Proposed Approach for Determining Lumen Output, Input Power, Lamp
Efficacy, Correlated Color Temperature, and Color Rendering Index
1. NOPR Proposals
The NOPR proposed to incorporate IES LM-79-2008 for determining
lumen output, input power, and CCT, with some modifications. 77 FR at
21041 (April 9, 2012) IES LM-79-2008 specifies the test setup and
conditions at which the measurements and calculations must be
performed. These include ambient conditions, power supply
characteristics, lamp orientation, and stabilization methods for LED
lamps, and instrumentation and electrical settings. These requirements,
and any related comments, are further discussed in the sections III.C.1
through III.C.4.
Kristopher Kritzer (hereafter referred to as Kritzer) expressed
support for adopting the complete NOPR test method and backed DOE's
efforts to adopt industry practices for testing LED lamps. (Kritzer,
No. 3 at p. 1) Lutron Electronics Company, Inc. (hereafter referred to
as Lutron) and NEMA did not support all test methods proposed in the
NOPR, but did agree that IES LM-79-2008 should be used to determine
lumen output, input power, and CCT. (Lutron, Public Meeting Transcript,
No. 7 at p. 25; NEMA, Public Meeting Transcript, No. 7 at p. 2)
However, several interested parties expressed concern with the overall
proposal. Delft University of Technology (which refers to itself as
TUD) and an anonymous commenter had reservations about adopting the
test methods proposed in the NOPR. TUD indicated that the NOPR proposal
will not guarantee tested LED products are well-qualified. (Anonymous,
No. 8 at p. 1; TUD, No. 15 at p. 1) NEMA, the California Investor Owned
Utilities (hereafter referred to as CA IOUs), and Philips Lighting
Electronics N.A. (hereafter referred to as Philips) urged that DOE not
modify or supplement any industry standard. (NEMA, No. 16 at p. 2, 7;
CA IOUs, No. 19 at p. 5, 6; Philips, Public Meeting Transcript, No. 7
at p. 114) Finally, the Appliance Standards Awareness Project, the
American Council for an Energy Efficient Economy, and the Natural
Resources Defense Council (hereafter referred to as the Joint Comment)
stated that test procedures need to mimic real world installations
whenever possible and, when knowledge of real world installations is
not available, the test method needs to approximate a worst-case
installation scenario. (Joint Comment, No. 18 at p. 1)
IES is the recognized technical authority on illumination, and the
IES LM-79-2008 standard was prepared by the IES subcommittee on Solid-
State Lighting Sources of the IESNA Testing Procedure Committee. IES
LM-79-2008 was also developed in collaboration with the ANSI Solid
State Lighting Joint Working Group C78-09 and C82-09 comprising
individuals from several
[[Page 32023]]
organizations. DOE believes that the committee members who worked on
developing the IES LM-79-2008 standard represent relevant industry
groups and interested parties. Based on an independent review by DOE
and general acceptance by industry, DOE proposes that IES LM-79-2008
specifies much of the information that is required for providing a
complete test procedure for determining lumen output, input power, CCT,
and CRI of LED lamps. DOE agrees that the LED lamp test procedure needs
to mimic real world installations and believes that the procedures
described in the IES LM-79-2008 standard are representative of such
conditions. IES LM-79-2008 specifies the test conditions and setup at
which the measurements and calculations must be performed. However, DOE
proposes some clarifications to establish a repeatable procedure for
all LED lamp testing. These clarifications to IES LM-79-2008 include
mounting orientation and electrical setting requirements. These
requirements, and any clarifications proposed by DOE, are further
discussed in the sections III.C.2 through III.C.4.
2. Test Conditions
In the NOPR, DOE proposed that the ambient conditions for testing
LED lamps be as specified in section 2.0 \15\ of IES LM-79-2008. 77 FR
at 21041. These conditions include setup and ambient temperature
control, as well as air movement requirements. Both are discussed in
further detail below.
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\15\ IES standards use the reference 2.0, 3.0, etc. for each
primary section heading. Sub-sections under each of these sections
are referenced as 2.1, 2.2, 3.1, 3.2, etc. This SNOPR refers to each
IES section exactly as it is referenced in the standard.
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Section 2.2 of IES LM-79-2008 specifies that photometric
measurements shall be taken at an ambient temperature of 25 degrees
Celsius ([deg]C) 1 [deg]C. In the NOPR, DOE indicated that
a tolerance of 1[deg]C for the ambient temperature is practical, limits
the impact of ambient temperature on measurements, and would not be
burdensome because the instruments used to measure the temperature
provide greater accuracy than required, allowing the test laboratories
to maintain the temperature within the required tolerance for testing.
Id. Section 2.2 of IES LM-79-2008 further specifies that the
temperature shall be measured at a point not more than one meter from
the LED lamp and at the same height as the lamp. The standard requires
that the temperature sensor that is used for measurements be shielded
from direct optical radiation from the lamp or any other source to
reduce the impact of radiated heat on the ambient temperature
measurement. The NOPR stated that this setup for measuring and
controlling ambient temperature is appropriate for testing because it
requires that the lamp be tested at room temperature and in an
environment that is commonly used for testing other lighting
technologies. Id. DOE did not receive adverse comments, and therefore
maintains this proposal for ambient temperature conditions in the
SNOPR.
In the NOPR, DOE proposed that the requirement for air movement
around the LED lamp be as specified in section 2.4 of IES LM-79-2008,
which requires that the air flow around the LED lamp be such that it
does not affect the lumen output measurements of the tested lamp. Id.
DOE also considered specifying a method for determination of a draft-
free environment, such as that in section 4.3 of IES LM-9-2009,\16\
which requires that a single ply tissue paper be held in place of the
lamp to allow for visual observation of any drafts.
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\16\ ``IES Approved Method for the Electrical and Photometric
Measurement of Fluorescent Lamps.'' Approved January 31, 2009.
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Philips, Osram Sylvania, Inc. (hereafter referred to as OSI), and
NEMA all indicated that the surrounding air temperature and airflow for
LED lamps does not have a noticeable impact on long-term lumen
degradation. Based on this, DOE believes that the IES LM-79-2008 air
movement requirements proposed in the NOPR are more than adequate to
ensure the accuracy of test data. (Philips, Public Meeting Transcript,
No. 7 at p. 27; OSI, Public Meeting Transcript, No. 7 at pp. 27-28;
NEMA, Public Meeting Transcript, No. 7 at pp. 2-3; NEMA, No. 16 at p.
2-3) However, other stakeholders suggested adding quantitative
requirements for air movement. The People's Republic of China
(hereafter referred to as P.R. China) suggested that air movement in
the vicinity of the luminaire not exceed 0.2 m/s. For lamps designed
with a larger tolerance for ambient temperature changes, faster air
movement may be acceptable. (P.R. China, No. 12 at p. 3) The Joint
Comment noted that the air movement procedures in IES LM-79-2008 are
informative, but not very specific. Therefore, they recommended that
DOE investigate a quantitative approach so that air flow around the
device is better understood. However, the Joint Comment expressed
concern that direct measurement of the airflow (anemometry) would
increase the testing burden to manufacturers substantially; instead,
they recommended DOE investigate a suitable proxy measure to judge the
stability of the airflow around the lamp. As an example, they suggested
DOE may want to consider stability criteria on a measurement of the
case temperature. The Joint Comment noted that it is likely that other
parameters may also provide valuable information about the airflow
while minimizing testing burden. (Joint Comment, No. 18 at p. 3)
Although DOE agrees that the air movement requirement in IES LM-79-
2008 could be more precise, DOE is maintaining its proposal from the
NOPR not to modify the surrounding air temperature and airflow
specifications provided in IES LM-79-2008. DOE does not believe that
additional requirements to establish a draft-free environment would
improve measurement accuracy relative to current industry practice.
Furthermore, specifying a quantitative procedure for measuring air
movement would result in an unnecessary increase to testing burden.
Therefore, in this SNOPR, DOE maintains its proposal to retain the
requirements in IES LM-79-2008 to ensure that air movement is minimized
to acceptable levels. These requirements would apply to lamps measured
in both active mode and standby mode.
3. Test Setup
a. Power Supply
In the NOPR, DOE proposed that section 3.1 and 3.2 of IES LM-79-
2008 be incorporated by reference to specify requirements for both
alternating current (AC) and direct current (DC) power supplies. 77 FR
at 21042. Section 3.1 specifies that an AC power supply shall have a
sinusoidal voltage waveshape at the input frequency required by an LED
lamp such that the root mean square (RMS) \17\ summation of the
harmonic components does not exceed three percent of the fundamental
frequency \18\ while operating the LED lamp. Section 3.2 of IES LM-79-
2008 also requires that the voltage of an AC power supply (RMS voltage)
or DC power supply (instantaneous voltage) applied to the LED lamp be
within 0.2 percent of the specified lamp input voltage (see
section III.C.3.d for discussion of the proposed electrical settings,
including input voltage). These requirements are achievable with
[[Page 32024]]
minimal testing burden and provide reasonable stringency in terms of
power quality based on their similarity to voltage tolerance
requirements for testing of other lighting technologies. DOE did not
receive adverse comment on this proposal and, therefore, this proposal
remains unchanged for the SNOPR. These power supply requirements would
apply to lamps measured in both active mode and standby mode.
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\17\ Root mean square (RMS) voltage/current is a statistical
measure of the magnitude of a voltage/current signal. RMS voltage/
current is equal to the square root of the mean of all squared
instantaneous voltages/currents over one complete cycle of the
voltage/current signal.
\18\ Fundamental frequency, often referred to as fundamental, is
defined as the lowest frequency of a periodic waveform.
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b. Instrumentation
In the NOPR, DOE proposed that instrumentation requirements for the
AC power meter and the AC and DC voltmeter and ammeter, as well as the
acceptable tolerance for these instruments, be as specified in section
8.0 of IES LM-79-2008. Id. Section 8.1 of IES LM-79-2008 specifies that
for DC-input LED lamps, a DC voltmeter and DC ammeter shall be
connected between the DC power supply and the LED lamp under test. The
DC voltmeter shall be connected across the electrical power input of
the LED lamp, and the input electrical power shall be calculated as the
product of the measured input voltage and current. Section 8.2 of IES
LM-79-2008 specifies that the tolerance for the DC voltage and current
measurement instruments shall be 0.1 percent. For AC-input
LED lamps, section 8.1 of IES LM-79-2008 further specifies that an AC
power meter shall be connected between the AC power supply and the LED
lamp under test. The AC power, input voltage, and current shall be
measured. Section 8.2 of IES LM-79-2008 specifies that the tolerance of
the AC voltage and current measurement instruments shall be 0.2 percent and the tolerance of the AC power meter shall be
0.5 percent. In the NOPR, DOE concluded that the electrical
instrumentation requirements set forth in section 8.0 of IES LM-79-2008
are achievable and provide reasonable stringency in terms of
measurement tolerance based on their similarity to instrument tolerance
requirements for testing of other lighting technologies. Id. DOE did
not receive adverse comment on these electrical instrumentation
requirements and, therefore, this proposal remains unchanged for the
SNOPR.
Regarding photometric instrumentation used for measuring lumen
output, CCT, and CRI, DOE proposed in the NOPR that either a sphere-
spectroradiometer, sphere-photometer, or goniophotometer system be used
for lumen output measurement of the LED lamp as specified in IES LM-79-
2008. DOE requested comment on the differences in values measured by an
integrating sphere (via photometer or spectroradiometer) versus a
goniophotometer. 77 FR at 21042 NEMA commented that both systems are
appropriate for lumen determination, but acknowledged that a perfect
correlation between the two techniques is not possible. (NEMA, No. 16
at p. 3)
While DOE recognizes that the integrating sphere and
goniophotometer (a goniometer fitted with a photometer as the light
detector) are both valid means of photometric measurement, DOE is
concerned about the potential for a difference in the measured values.
A test procedure that yields more than one possible value depending on
instrumentation presents problems for certification and enforcement. If
DOE and the manufacturer use different test methods, DOE could find
that a lamp certified as compliant could be tested as non-compliant
during a verification or enforcement proceeding. IES LM-79-2008 does
not explicitly specify the scanning resolution (i.e., quantity and
location of measurements around the lamp), and instead provides
guidance that must be implemented differently for each lamp. DOE also
determined that further specification of the goniophotometer method is
unreasonable, because the scanning resolution specification would need
to be adequate for the lamp that requires the finest resolution. This
would likely present an overly burdensome test method for many other
lamps that could be measured at a lower resolution. In contrast, use of
an integrating sphere enables photometric characteristics of the LED
lamp to be determined with a single measurement. Therefore, integrating
spheres are the preferred method for photometric measurement due to the
reduction in time required for testing.
In consideration of the lack of measurement correlation between
integrating spheres and goniophotometers and the reduced burden and
much higher incidence of use of integrating spheres, DOE proposes in
the SNOPR to require all photometric measurements, including lumen
output, CCT, and CRI to be carried out in an integrating sphere and
that goniometer systems must not be used. Therefore, DOE proposes that
the instrumentation used for lumen output measurements be as described
in sections 9.1 and 9.2 of IES LM-79-2008, and CCT and CRI measurements
be as described in section 12.0 of IES LM-79-2008 with the exclusion of
section 12.2 of IES LM-79-2008, as goniometers must not be used. DOE
invites interested parties to comment on the proposal to require all
photometric values be measured by an integrating sphere (via photometer
or spectroradiometer). These instrumentation requirements would apply
to lamps measured in both active mode and standby mode.
c. Lamp Mounting and Orientation
In the NOPR, DOE considered testing LED lamps as specified in
section 6.0 of IES LM-79-2008, which states that LED lamps shall be
tested in the operating orientation recommended by the lamp
manufacturer for the intended use of the LED lamp. Id. As discussed in
the NOPR, DOE determined that manufacturers do not typically specify
the operating orientation for an LED lamp in their product literature.
Further, DOE indicated that it is possible manufacturers would
recommend an orientation for testing that provides the highest lumen
output rather than the orientation in which the lamp is most frequently
operated in practice. Therefore, the NOPR proposed that an LED lamp be
mounted as specified in section 2.3 of IES LM-79-2008 and be positioned
in the base-up, base-down, and horizontal orientations for testing.
Numerous commenters raised concerns about DOE's proposal. General
Electric Lighting (hereafter referred to as GE), Philips, NEMA, Samsung
Electronics (hereafter referred to as Samsung), and P.R. China
commented that the base-up and base-down orientations constitute the
best and worst-case scenarios. (GE, Public Meeting Transcript, No. 7 at
p. 29; Philips, Public Meeting Transcript, No. 7 at pp. 29-30; NEMA,
No. 16 at p. 3; Samsung, No. 14 at p. 1; China, No. 12 at p. 3) Samsung
stated that testing in the base up and base down positions is also
consistent with ENERGY STAR test procedures. (Samsung, No. 14 at p. 1)
In addition, GE and NEMA commented that testing in the horizontal
position with either type of sphere will add uncertainty to the lumen
output measurement, and that testing in the horizontal position with a
goniophotometer is very difficult or even impossible. (GE, Public
Meeting Transcript, No. 7 at pp. 42-43; NEMA, No. 16 at p. 3)
Underwriter Laboratories (hereafter referred to as UL) indicated that
shadowing is an issue with testing in the horizontal position. Lamps
are usually supported from above or below, and if tested horizontally
the support structure could interfere with the light measurement. (UL,
Public Meeting Transcript, No. 7 at p. 54) NEMA commented that current
FTC instruction for CFLs does not require testing in multiple
orientations, only that the manufacturer specify if an orientation
[[Page 32025]]
change will result in a greater than five percent difference in
measured performance. (NEMA, No. 16 at p. 6) The Republic of Korea
(hereafter referred to as South Korea) suggested that DOE be consistent
with both International Electrotechnical Commission (IEC) 62612 \19\
and IES LM-79-2008, which require that the orientation of lamps during
testing follow the manufacturer's recommendations. (South Korea, No. 17
at p. 2) Finally, P.R. China noted that testing in the horizontal
position will increase the cost of the testing as well as the total
time required for testing. (P.R. China, No. 12 at p. 3)
---------------------------------------------------------------------------
\19\ IEC/PAS 62612: Self-ballasted LED-lamps for general
lighting services--Performance requirements.
---------------------------------------------------------------------------
Other commenters supported DOE's proposals and suggested further
research. The Joint Comment and the CA IOUs agreed with DOE's proposal
to include the horizontal position for lumen output testing because it
is likely a worst-case condition. This is because heat sink fins are
most effective at dissipating heat when air flow is parallel to the
direction of the fins, rather than when air flow is perpendicular to
the fins. Because most heat sink fins are parallel to the body of the
lamp, they are likely to dissipate heat differently when the lamp is
oriented vertically than when oriented horizontally. When heat is not
dissipated effectively in a lamp, lumen output generally decreases.
(Joint Comment, No. 18 at p. 4; CA IOUs, No. 19 at p. 6) In addition,
the CA IOUs indicated that they expect to have LED lamp performance
data collected in all three orientations by the end of 2012
(subsequently published in February 2013).\20\ The CA IOUs further
commented that manufacturer concerns about testing in the horizontal
position are not an issue for testing in a sphere-spectroradiometer or
sphere-photometer. The CA IOUs stated that accurate horizontal
measurements are regularly taken for other lamp technologies, and they
do not believe any unique challenge exists for measuring LED lamps that
do not exist for other lamps of similar shapes and base types. (CA
IOUs, No. 19 at p. 6) The Joint Comment suggested that DOE investigate
whether shadowing is a significant concern in a goniophotometer when
the lamp is configured horizontally. (Joint Comment, No. 18 at p. 4)
The Joint Comment also suggested that DOE consider the appropriateness
of testing at intermediate angles for certain types of lamps that
contain heat pipes, noting that heat pipes often have the best heat
transfer performance at inclinations of 60-70 degrees. (Joint Comment,
No. 18 at p. 4)
---------------------------------------------------------------------------
\20\ CLTC, ``Omni-Directional Lamp Testing'' Prepared for PG&E
and CLASP, February 25th, 2013. http://www.energy.ca.gov/appliances/2013rulemaking/documents/responses/Lighting_12-AAER-2B/California_IOUs_Response_to_the_Invitation_to_Participate_for_LED_Lamps_REFERENCE/PGandE_2013a_Omni-Directional_Lamp_Testing-Report_Draft.pdf.
---------------------------------------------------------------------------
In light of commenters' varying opinions about the impact of lamp
orientation on lamp performance, DOE collected test data for several
LED lamps tested in each of the three orientations. DOE investigated
two sets of photometric test data, the first provided by ENERGY STAR
and the second (mentioned by the CA IOUs in the previous paragraph)
from a collaborative testing effort between the Pacific Gas and
Electric Company (hereafter referred to as PG&E), California Lighting
Technology Center (hereafter referred to as CLTC), and the
Collaborative Labeling and Appliance Standards Program (hereafter
referred to as CLASP). Id. These test data represent 10 samples each of
47 different LED lamp products. Of the 47 lamp products tested, 36 were
mounted in base-up, base-down, and horizontal configurations, and 11
were mounted in base-up and base-down configurations. DOE analyzed the
data to determine the variation of input power, lumen output, CCT, and
CRI in each of the three orientations. The analysis of the test data
revealed that some lamp models exhibited variation between the three
orientations. Of the three orientations, analysis indicated that the
base-up and base-down orientations represent the best (highest lumen
output) and worst (lowest lumen output) case scenarios. Therefore, DOE
believes that there is no need to test horizontally.
The Joint Comment stated that other lamp orientations may represent
the best-case scenario and suggested that DOE investigate testing at
intermediate angles, such as 60 to 70 degrees. DOE notes that
intermediate angles could represent a best-case scenario for some
lamps; however, testing LED lamps at these angles is not common
industry practice. Although there is no data available for testing LED
lamps at intermediate angles, DOE consulted an LED lamp manufacturer as
to whether intermediate angle testing could be a best-case scenario for
some LED lamps. The manufacturer indicated that this could improve
efficiency theoretically; however, this possible improvement would be
negligible and likely within the measurement error of the lumen output
measuring equipment. From this, DOE has determined that these
performance gains would not be measureable. Therefore, DOE is not
proposing testing of LED lamps at intermediate angles.
As mentioned above, DOE also received comments about whether it was
possible to test LED lamps in all potential orientations. GE, NEMA, and
UL indicated that testing in the horizontal position could interfere
with the lumen output measurement. (GE, Public Meeting Transcript, No.
7 at pp. 42-43; NEMA, No. 16 at p. 3; UL, Public Meeting Transcript,
No. 7 at p. 54) DOE researched this concern by consulting with the
Lighting Research Center (LRC), which has extensive lamp testing
experience, and believes that testing lumen output in the horizontal
position does not lead to significant measurement error when using the
majority of sphere-spectroradiometer, sphere-photometer, and
goniophotometer systems. For either a sphere-spectroradiometer or
sphere-photometer system, the bracket, which secures the lamp in place,
can be designed and configured to eliminate any significant measurement
error due to shadowing. For large goniophotometer systems, there would
be sufficient space to make a bracket to hold the lamp in any
orientation without risk of significant shadowing. It is possible that
smaller goniophotometer systems could have mounting and bracket
limitations that result in error when testing in the horizontal
orientation due to shadowing. However, as discussed in section
III.C.3.b, DOE proposes in the SNOPR to require all photometric
measurements to be carried out in an integrating sphere and that
goniometer systems must not be used.
In the SNOPR, DOE proposes that LED lamps be positioned such that
an equal number of units are oriented in the base-up and base-down
orientations. This proposal specifies two commonly used orientations
for LED lamps that span the highest and lowest light-output scenarios,
creating a dataset that represents average performance in practice.
These lamp mounting and orientation requirements would apply to lamps
measured in both active mode and standby mode. DOE requests comment on
the proposal for an equal number of lamps to be operated in the base-up
and base-down orientations during lumen output, input power, CCT, and
CRI testing.
d. Electrical Settings
In the NOPR, DOE proposed requiring testing of LED lamps at the
rated voltage as specified in IES LM-79-2008. For lamps with multiple
operating voltages, DOE proposed that lamps be tested at
[[Page 32026]]
120 volts because 120 volts is the most common operating voltage of
available lamps. However, if the lamp is not rated at 120 volts, DOE
proposed that it be tested at the highest rated voltage. Id. NEMA
disagreed with DOE's proposal to test at rated voltage only, arguing
the proposal was in conflict with FTC regulations that require testing
lamps at 120 volts and the rated voltage. (NEMA, No. 16 at p. 3)
In this SNOPR, DOE maintains the NOPR proposal but, in addition,
indicates that manufacturers may also test at other operating voltages
as long as the final DOE test procedure is used for making energy
representations. These electrical settings would apply to lamps
measured in both active mode and standby mode. To ensure the SNOPR
proposal is not in conflict with the FTC Lighting Facts label
requirements, as was suggested by NEMA, DOE reviewed the FTC
regulations detailed in 16 CFR 305.15. The FTC regulation states that a
general service lamp shall be measured at 120 volts, regardless of the
lamp's design or rated voltage. If a lamp's design voltage is 125 volts
or 130 volts, the disclosures of the wattage, light output, energy
cost, and lifetime must disclose the voltage at which these metrics
were measured. DOE's proposal is not in conflict with FTC's Lighting
Facts requirements because manufacturers must test at 120 volts as
required by FTC and, if the LED lamp is rated for additional voltages,
the lamp may also be tested at the highest rated voltage. This supports
FTC's program and does not provide conflicting instructions.
In the NOPR, DOE proposed incorporating section 7.0 of IES LM-79-
2008, which specifies electrical settings for LED lamps with multiple
modes of operation, such as variable CCT and dimmable lamps. 77 FR at
21043. Section 7.0 of IES LM-79-2008 indicates LED lamps with variable
CCT shall be tested in each mode of operation, and for dimmable lamps,
directs that they be tested at the maximum input power.
Philips commented that when specifying electrical settings for
variable CCT lamps it is important that DOE consider the scenario that
the testing is intended to reflect (i.e., worst-case versus most common
operating conditions) because lumen output can change based on the CCT
mode. (Philips, Public Meeting Transcript, No. 7 at p. 32) OSI agreed
with this point and indicated that in the future it is foreseeable that
LED lamps with variable CCT, CRI, and lumen output will be available.
(OSI, Public Meeting Transcript, No. 7 at pp. 32-33) Both P.R. China
and Samsung stated that LED lamps with multiple modes of operation are
currently available. (P.R. China, No. 12 at p. 4; Samsung, No. 14 at p.
1) GE and Samsung indicated that multiple mode lamps in the future
could operate at continuously variable CCT making testing at a distinct
CCT impossible. (GE, Public Meeting Transcript, No. 7 at p. 32;
Samsung, No. 14 at p. 1) OSI commented that testing at the worst-case
scenario could be a possible option for LED lamps with variable CCT,
while Samsung suggested requiring both a best- and worst-case scenario.
(OSI, Public Meeting Transcript, No. 7 at pp. 33; Samsung, No. 14 at p.
1) P.R. China suggested DOE follow international standard IEC/PAS
62717-2011,\21\ which states that LED modules with adjustable color
point must be adjusted/set to one fixed value as indicated by the
manufacturer or responsible vendor. (P.R. China, No. 12 at p. 3) At the
May 3, 2012 NOPR public meeting (hereafter the May 2012 public
meeting), NEMA argued against testing at a CCT, CRI, or lumen output
setting that would rarely be used in the field. For lamps that can vary
CCT over the power range, NEMA suggested testing the lamps only at the
CCT that occurs at full power. (NEMA, Public Meeting Transcript, No. 7
at p. 33; NEMA, No. 16 at p. 3) Finally, regarding dimming, NEMA agreed
with DOE's proposal to measure dimmable lamps at full power as this
will reflect the rating on the packaging. (NEMA, No. 16 at p. 3)
---------------------------------------------------------------------------
\21\ IEC/PAS 62717: LED modules for general lighting--
Performance requirements.
---------------------------------------------------------------------------
DOE believes that LED lamps with multiple modes of operation,
including variable CCT and CRI as well as dimmable lamps, should be
tested at maximum input power because this is the highest energy
consuming state. Therefore, DOE proposes to require testing for such
lamps at the mode that occurs at maximum input power, since this is the
highest energy consuming state. When multiple modes (such as multiple
CCTs and CRIs) occur at the same maximum input power, the manufacturer
can select any of these modes for testing. Manufacturers may also test
at other modes as long as the final DOE test procedure is used for
making representations about the energy consumption of an LED lamp. All
measurements (lumen output, input power, efficacy, CCT, CRI, lifetime,
and standby mode power) must be conducted at the same mode of
operation. DOE invites comment on its proposals for testing lamps for
which multiple modes (such as multiple CCTs and CRIs) can occur at the
same maximum input power.
4. Test Method
a. Lamp Seasoning
In the NOPR, DOE proposed requiring energizing and operating LED
lamps for 1,000 hours to season them before beginning photometric
measurements. 77 FR at 21043. DOE proposed a 1,000 hour seasoning time
because it has been indicated by industry \22\ \23\ that light output
of an LED source (and therefore, potentially the lamp) can change
during the first 1,000 hours of operation. DOE also noted that IES TM-
21-2011 \24\ specifies that the data obtained from the first 1,000
hours of operating an LED source shall not be used to project the
lifetime of an LED source.
---------------------------------------------------------------------------
\22\ Cheong, Kuan Yew. ``LED Lighting Standards Update.'' CREE,
August 5, 2011. Page 31. www.nmc.a-star.edu.sg/LED_050811/Kuan_
CREE.pdf
\23\ Richman, Eric. ``Understanding LED Tests: IES LM-79, LM-80,
and TM-21.'' DOE SSL Workshop, July 2011. Page 13. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/richman_tests_sslmiw2011.pdf
\24\ ``Projecting Long Term Lumen Maintenance of LED Light
Sources.'' Approved by IES on July 25, 2011.
---------------------------------------------------------------------------
Cree, Philips, Feit Electric Company, NEMA, P.R. China, the Joint
Comment, CA IOUs, Northwest Energy Efficiency Alliance (hereafter
referred to as NEEA), and South Korea all commented that LED lamps not
be seasoned for 1,000 hours prior to collecting lumen output data. They
argued that due to the evolving nature of these products, there is no
common seasoning time. (Cree, Public Meeting Transcript, No. 7 at pp.
34-35; Philips, Public Meeting Transcript, No. 7 at p. 35, 36; Feit,
Public Meeting Transcript, No. 7 at p. 45; NEMA, Public Meeting
Transcript, No. 7 at p. 36; P.R. China, No. 12 at p. 4; NEMA, No. 16 at
p. 3; Joint Comment, No. 18 at pp. 5-6; CA IOUs, No. 19 at p. 5; NEEA,
No. 20 at p. 2; South Korea, No. 17 at p. 2) Cree indicated that sudden
increases or decreases in light output in the first 1,000 hours of
operation depend on several factors in the construction of the LED
lamp. (Cree, Public Meeting Transcript, No. 7 at pp. 36-37) P.R. China,
NEEA, and the CA IOUs stated that DOE should remain consistent with the
specifications of IES LM-79-2008, and require no seasoning prior to
photometric measurements. (P.R. China, No. 12 at p. 4; NEEA, No. 20 at
p. 2; CA IOUs, No. 19 at p. 5)
The Joint Comment indicated that when taking photometric
measurements, it is not obvious if seasoning is necessary. They
suggested that DOE investigate and report on the
[[Page 32027]]
necessity of seasoning lamps prior to photometric measurements, as this
seasoning is in direct conflict with procedures established in IES LM-
79-2008. Should DOE decide that there is sufficient variability in
devices that can be mitigated by seasoning; they recommend that DOE
collaborate with industry to minimize testing burden and potential re-
testing of current LED sources/lamps. (Joint Comment, No. 18 at pp. 5-
6) The National Institute of Standards and Technology (hereafter
referred to as NIST) and Samsung, however, commented that seasoning LED
lamps for 1,000 hours prior to collecting lumen output data is
reasonable. (NIST, Public Meeting Transcript, No. 7 at p. 47; Samsung,
No. 14 at p. 1) NIST argued that including a seasoning time of 1,000
hours would help identify faulty products. (NIST, Public Meeting
Transcript, No. 7 at p. 47)
In the SNOPR, DOE proposes to eliminate the requirement to season
lamps for 1,000 hours prior to taking photometric measurements.
Although some LED lamps do experience changes in light output during
the first 1,000 hours of operation, independent research and
manufacturer comments indicate that this is not true for all LED lamps.
Each LED lamp is unique, and as a result, initial trends in light
output are not consistent from lamp to lamp. Therefore, seasoning all
lamps for a predetermined duration does not provide a more accurate
initial test measurement, though it does increase testing burden. The
current industry-accepted test procedure, IES-79-2008, reflects this
understanding by not allowing lamp seasoning. Therefore, the SNOPR
proposes to remain consistent with section 4.0 of IES LM-79-2008, which
indicates LED lamps shall not be seasoned before beginning photometric
measurements. These seasoning requirements would apply to lamps
measured in both active mode and standby mode. DOE requests comment on
this proposal.
b. Lamp Stabilization
In the NOPR, DOE proposed stabilizing lamps for the time specified
in section 5.0 of IES LM-79-2008. DOE further proposed that stability
of the LED lamp is reached when the variation [(maximum--minimum)/
minimum] of at least three readings of light output and electrical
power over a period of 30 minutes, taken 15 minutes apart, is less than
0.5 percent. 77 FR at 21043. This calculation was included to add
clarification to the method specified in section 5.0 of IES LM-79-2008.
For stabilization of a number of products of the same model, section
5.0 of IES LM-79-2008 suggests that preburning \25\ of the product may
be used if it has been established that the method produces the same
stabilized condition as when using the standard method described above.
---------------------------------------------------------------------------
\25\ IES LM-79-2008 defines preburning as the operation of a
light source prior to mounting on a measurement instrument, to
shorten the required stabilization time on the instrument.
---------------------------------------------------------------------------
NEMA agreed that the lamp stabilization method in IES LM-79-2008 be
used for the LED lamp test procedure but argued that the standard did
not need further clarification. (NEMA, Public Meeting Transcript, No. 7
at pp. 38-39; NEMA, No. 16 at p. 3) However, GE advocated for
presenting the lamp stabilization equation as a percent. (GE, Public
Meeting Transcript, No. 7 at p. 39)
DOE reconsidered its NOPR proposal, but came to the same conclusion
for the SNOPR. IES LM-79-2008 does not clearly specify the calculation
for determining the stabilization value, leaving this requirement open
to interpretation. Therefore, DOE continues to propose in the SNOPR
that variation of at least three readings of light output and
electrical power over a period of 30 minutes, taken 15 minutes apart is
calculated as [maximum--minimum]/minimum. DOE expects this proposal is
the same or very similar to the stabilization calculation methods
already used in practice. As in the NOPR, DOE continues to propose in
this SNOPR that stabilization of multiple products of the same model
can be carried out as specified in section 5.0 of IES LM-79-2008. These
stabilization requirements would apply to lamps measured in both active
mode and standby mode.
c. Lumen Output Metric
In the NOPR, DOE proposed that the test method for measuring the
lumen output of an LED lamp be as specified in section 9.0 of IES LM-
79-2008 and proposed the same lumen output measurement method for all
LED lamps, including directional \26\ LED lamps. Id. For directional
LED lamps, DOE suggested measuring total lumen output from the lamp
rather than beam lumens \27\ because other directional lamp
technologies currently measure and report total lumen output on the FTC
Lighting Facts label.
---------------------------------------------------------------------------
\26\ Directional lamps are designed to provide more intense
light to a particular region or solid angle. Light provided outside
that region is less useful to the consumer, as directional lamps are
typically used to provide contrasting illumination relative to the
background or ambient light.
\27\ Please refer to the NOPR Test Procedures for Light-Emitting
Diode Lamps (Docket No. EERE-2011-BT-TP-0071) for a detailed
explanation of why DOE is not proposing to measure beam lumens for
directional LED lamps (77 FR at 21043; April 9, 2012).
---------------------------------------------------------------------------
As discussed in section III.C.3.b, DOE proposes in the SNOPR that
goniometers may not be used for photometric measurements. As a result,
DOE proposes that the method for measuring lumen output in the SNOPR be
as specified in sections 9.1 and 9.2 of IES LM-79-2008. Section 9.3 of
IES LM-79-2008 discusses usage of goniometers, and DOE is not including
that method in the SNOPR proposal.
Regarding directional lamps, NEMA commented that industry has not
yet reached consensus regarding a light output metric for directional
lamps. (NEMA, Public Meeting Transcript, No. 7 at p. 43; NEMA, No. 16
at p. 4) Furthermore, NEMA highlighted that DOE has other rulemakings
specifically for reflector lamps that specify the use of total lumens.
Therefore, a deviation from measuring total lumens in the LED lamp test
procedure would have a significant impact on all types of directional
lamps. (NEMA, Public Meeting Transcript, No. 7 at p. 44) The CA IOUs
commented that if measuring beam lumens is only required for the LED
lamp test procedure and not all general service reflector lamps, this
could hinder the industry's ability to compare lamps across
technologies. (CA IOUs, No. 19 at p. 7) However, the CA IOUs supported
DOE's efforts to develop a beam efficacy metric and recommended that
this metric be applied to all directional lamp technologies. (CA IOUs,
No. 19 at p. 7) In contrast, P.R. China argued that testing total lumen
output instead of the beam lumen output and center-beam candle power
might bring inconsistency and confusion to the industry. Therefore,
they recommended that DOE reference the Energy Star Program
Requirements for Integral LED Lamps: Eligibility Criteria--Version 1.4
\28\ which specifies that the center-beam candle power and beam angle
be tested for directional lamps. (P.R. China, No. 12 at p. 4)
---------------------------------------------------------------------------
\28\ ``Energy Star Program Requirements for Integral LED Lamps:
Eligibility Criteria--Version 1.4.'' U.S. Environmental Protection
Agency, August 28, 2013.
---------------------------------------------------------------------------
Because total lumen output is the measurement reported on the FTC
Lighting Facts label for other directional lamp technologies, DOE
agrees with NEMA and the CA IOUs comments not to include measurements
for beam lumens in this test procedure. Therefore, DOE maintains its
proposal from the NOPR to measure the total lumen output for LED lamps.
Measuring the total lumen output for LED lamps
[[Page 32028]]
will enable industry and consumers to compare general service lamp
products across different technologies.
d. Input Power
Following seasoning and stabilization, input power to the LED lamp
is measured using the instrumentation specified in section III.C.3.b.
All test conditions and test setup requirements from sections III.C.2
and III.C.3 should also be followed.
e. Lamp Efficacy Metric
In the NOPR, DOE proposed test procedures for measuring lumen
output and input power, and also specified testing dimmable lamps at
full light output. 77 FR at 21041. However, commenters noted that
efficacy may appear in future mandates, and therefore recommended it be
included in DOE's test procedure for LED lamps. The CA IOUs commented
that a test procedure with an efficacy metric would be needed in the
future to comply with federal legislative mandates, and for this reason
they urged DOE to include an efficacy metric in the test procedure.
Both the CA IOUs and NEEA recommended that DOE adopt IES LM-79-2008,
which defines luminous efficacy as the quotient of the measured total
luminous flux (in lumens) and the measured electrical input power (in
watts), or lumens per watt. (CA IOUs, No. 19 at p. 3; NEEA, No. 20 at
p. 1)
As discussed in section I, this proposed test procedure will
support any potential future energy conservation standards for general
service LED lamps, which may include efficacy as a metric for setting
standards. Accordingly, for the SNOPR, DOE proposes that the efficacy
of an LED lamp be calculated by dividing measured initial lamp lumen
output in lumens by the measured lamp input power in watts, in units of
lumens per watt. DOE believes that providing a calculation for efficacy
of an LED lamp does not increase testing burden because the test
procedure already includes metrics for input power and lumen output.
DOE requests comment on the proposal to add a calculation for efficacy
of an LED lamp.
f. Measuring Correlated Color Temperature
In the NOPR, DOE proposed that the CCT of an LED lamp be calculated
as specified in section 12.4 of IES LM-79-2008. 77 FR at 21044. The CCT
is determined by measuring the relative spectral distribution,
calculating the chromaticity coordinates, and then matching the
chromaticity coordinates to a particular CCT of the Planckian radiator.
The setup for measuring the relative spectral distribution, which is
required to calculate the CCT of the LED lamp, shall be as specified in
section 12.0 of IES LM-79-2008. That section describes the test method
to calculate CCT using a sphere-spectroradiometer system and a
spectroradiometer or colorimeter system. Section 12.0 of IES LM-79-2008
also specifies the spectroradiometer parameters that affect CCT and the
method to evaluate spatial non-uniformity of chromaticity.
South Korea disagreed with the proposal in the NOPR and recommended
that DOE follow industry standard IEC/PAS 62612 which states that
nominal CCT values shall be reported (South Korea, No. 17 at pp. 3-4).
Nominal CCT values are defined by a region of the chromaticity diagram
and any lamp that falls in a certain region is assigned a single CCT
value. However, nominal CCT values do not address all regions of the
chromaticity diagram. Although manufacturers in the marketplace may
choose to design lamps that fall within regions defined by nominal CCT,
DOE's goal is to establish one test method that applies to all LED
lamps. Therefore, DOE is not proposing to follow a nominal CCT
methodology and maintains its proposal in the NOPR regarding the method
to calculate the CCT of an LED lamp. Furthermore, as discussed in
section III.C.3.b, DOE also proposes in the SNOPR to require all
photometric measurements (including CCT) be carried out in an
integrating sphere, and that goniometer systems must not be used.
Therefore, DOE proposes that the instrumentation used for CCT
measurements be as described in section 12.0 of IES LM-79-2008 with the
exclusion of section 12.2 of IES LM-79-2008.
g. Measuring Color Rendering Index
In the SNOPR, DOE proposes to add a requirement that the CRI of an
LED lamp be determined as specified in section 12.4 of IES LM-79-2008.
As discussed in section III.C.3.b, DOE also proposes in the SNOPR to
require all photometric measurements (including CRI) be carried out in
an integrating sphere. Therefore, the setup for measuring the relative
spectral distribution, which is required to calculate the CRI of the
LED lamp, must be as specified in section 12.0 of IES LM-79-2008 with
the exclusion of section 12.2 of IES LM-79-2008, as goniometer systems
must not be used. Section 12.4 of IES LM-79-2008 also specifies that
CRI be calculated according to the method defined in the International
Commission on Illumination (CIE) 13.3-1995.\29\ DOE proposes that the
test procedure for LED lamps include measurement methods for CRI in
order to support the upcoming general service lamps energy conservation
standard rulemaking. DOE requests comment on the proposal to add CRI to
the test procedure for LED lamps.
---------------------------------------------------------------------------
\29\ ``Method of Measuring and Specifying Colour Rendering
Properties of Light Sources.'' Approved by CIE in 1995.
---------------------------------------------------------------------------
D. Proposed Approach for Lifetime Measurements
1. LED Lamp Lifetime Definition
There are currently no industry standards that define or provide
instructions for measuring the lifetime \30\ of LED lamps. Thus, for
the NOPR, DOE conducted literature research and interviewed several
subject matter experts to understand how industry characterized
lifetime for these products. Based on the information gathered, DOE
proposed to measure lumen maintenance to determine the lifetime of LED
lamps. Although other lighting technologies define lamp lifetime as the
time at which 50 percent of tested samples stop producing light,
industry believes that an LED lamp has reached the end of its useful
life when it achieves a lumen maintenance of 70 percent (i.e. 70
percent of initial lumen output, or L70). 77 FR at 21046.
---------------------------------------------------------------------------
\30\ In the NOPR, DOE used the term ``rated lifetime.'' For the
SNOPR, DOE replaces the term ``rated lifetime'' with ``lifetime'' to
refer to the same parameter.
---------------------------------------------------------------------------
Philips, OSI, and Cree agreed that currently no industry accepted
procedure exists for measuring the lifetime of LED-based lighting
products. (Philips, Public Meeting Transcript, No. 7 at p. 64; OSI,
Public Meeting Transcript, No. 7 at pp. 74-75; Cree, Public Meeting
Transcript, No. 7 at p. 65) However, Litecontrol and NEMA disagreed
with DOE's proposal, stating that the report LED Luminaire Lifetime:
Recommendation for Testing and Reporting \31\ explicitly argues that
lumen maintenance alone cannot be used as a proxy for the lifetime of
LED-based lighting products. (Litecontrol, No. 11 at p. 1; NEMA, No. 16
at p. 5) Radcliffe Advisors and the CA IOUs emphasized that color shift
be considered when determining the lifetime because this could also
render a lamp un-usable or undesirable to a consumer before the lamp
reaches L70. (Radcliffe Advisors,
[[Page 32029]]
No. 13 at p. 1; CA IOUs, No. 19 at p. 4)
---------------------------------------------------------------------------
\31\ U.S. Department of Energy, ``LED Luminaire Lifetime:
Recommendation for Testing and Reporting,'' June 2011. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/led_luminaire-lifetime-guide_june2011.pdf.
---------------------------------------------------------------------------
In the absence of industry consensus regarding a definition or test
procedure for lifetime, NEMA, Lutron, the CA IOUs, and Radcliffe
Advisors emphasized that DOE should wait for industry to develop new
and revised standards that address lifetime and then reference them for
the purposes of the FTC Lighting Facts label. (NEMA, No. 16 at p. 2;
Lutron, Public Meeting Transcript, No. 7 at p. 80; CA IOUs, No. 19 at
p. 5; Radcliffe Advisors, No. 13 at p. 1) NEMA indicated that this
includes revisions of IES LM-79-2008, IES LM-80-2008,\32\ and emerging
standards IES LM-84 \33\ and IES TM-26.\34\ (NEMA, No. 16 at p. 2, 5,
7) The Joint Comment, NEMA, NEEA, and the CA IOUs encouraged DOE to
work with industry to develop a test procedure that would quantify the
lifetime of an LED lamp system. (Joint Comment, No. 18 at p. 1; NEMA,
No. 16 at p. 4; NEEA, No. 20 at pp. 2-3; CA IOUs, No. 19 at p. 5) NEMA,
Philips, and Radcliffe Advisors pointed out that there are several
industry groups working on this issue, such as the LED Systems
Reliability Consortium. (NEMA, No. 16 at p. 4; Philips, Public Meeting
Transcript, No. 7 at p. 64; Radcliffe Advisors, No. 13 at p. 1) Other
interested parties cited additional efforts; the CA IOUs commented that
DOE should coordinate efforts with ENERGY STAR while the Joint Comment
recommended that DOE coordinate test procedure development with work in
the European Union. (CA IOUs, No. 19 at p. 5; Joint Comment, No. 18 at
p. 5)
---------------------------------------------------------------------------
\32\ ``Measuring Lumen Maintenance of LED Light Sources.''
Approved by IES on September 22, 2008.
\33\ LM-84 ``IES Approved Method for Measuring Lumen and Color
Maintenance LED Lamps, Lighting engines, and Luminaires,'' will
provide the method for measurement of lumen and color maintenance of
LED lamps, light engines, and LED luminaires.
\34\ TM-26 ``Projecting Long-Term Lumen Maintenance for LED
Lamps and Luminaires,'' will provide an LED lamp and luminaire level
counterpart to IES TM-21-2011 using the IES LM-80-2008 (revision)
and LM-84 testing data for projecting long-term lumen maintenance.
---------------------------------------------------------------------------
DOE recognizes that there are degradation mechanisms other than
lumen maintenance, such as color shift, that can affect the useful
lifetime of LED lamps. However, color shift is not very well-
understood, well-studied, or commonly used even for traditional
incandescent lamps and CFLs.\31\ After conducting thorough research of
existing test procedures for all lighting products and industry
literature regarding LED lamp lifetime, DOE has tentatively concluded
that there is no industry consensus for how to characterize lifetime of
LED lamps in terms of performance metrics other than lumen maintenance.
Therefore, DOE is not proposing to use metrics such as color shift to
determine the lifetime of LED lamps.
Although industry may be working to develop new and revised
standards to define lifetime and establish test procedures for
measuring this quantity, the timeframe for their development is
unknown. DOE reviewed the efforts of other working groups, as suggested
by interested parties, but was unable to find any U.S. or international
standard that provides a test procedure for measuring and/or projecting
LED lamp lifetime. The only publicly available approach for measuring
LED lamp lifetime is ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0,\10\ which uses a lumen
maintenance of 70 percent (i.e. 70 percent of initial lumen output, or
L70) as an estimate for lifetime. Therefore, in this SNOPR,
DOE proposes to continue to define lifetime as the time at which the
lumen output of the LED lamp falls below 70 percent of the initial
lumen output.
2. NOPR Proposals
As mentioned above, there are currently no industry standards that
address how to measure lifetime for LED lamps. Therefore, DOE reviewed
methods to measure lifetime that were contained in industry standards
for related components and also investigated recent efforts in DOE and
ENERGY STAR working groups. In the NOPR, DOE presented four potential
lifetime measurement approaches, all of which characterized the
lifetime of LED lamps as the time required to reach a lumen maintenance
of 70 percent. 77 FR at 21044-5. Three of these approaches tested an
LED lamp to determine the lifetime and the fourth approach tested the
LED source as a proxy for the lifetime of the lamp. Ultimately, DOE
determines in this SNOPR that the test procedure for lifetime must
directly measure the performance of an LED lamp and not the LED source,
and proposes the revised lifetime measurement detailed in section
III.D.3.
Approach 1, based largely on the procedures in IES LM-79-2008,
directed manufacturers to measure the lumen output of the LED lamp
until it reaches 70 percent of its initial lumen output. In the NOPR,
DOE stated that Approach 1 is advantageous because it does not project
the time at which the lamp reaches L70 and therefore
measures the actual performance of the lamp over its useful life.
However, DOE determined that Approach 1 was not practical because it
may require up to six years of testing, by which time the LED lamp may
be obsolete. Id.
Approach 2 called for measuring lumen output of the LED lamp for a
specified period of time, 6,000 hours, and then projecting the time at
which the lamp reached L70 based on the minimum lumen
maintenance at 6,000 hours. This method was largely based on the ENERGY
STAR Specification for Integral LED Lamps Version 1.4 (see supra note
28). In addition, DOE proposed in the NOPR that a rapid-cycle stress
test be performed to assess catastrophic lamp failure (e.g. when a lamp
immediately ceases to emit light, rather than gradually decreasing in
light output). Approach 2 also enabled lifetime claims to be based on
the performance of an LED lamp, but was less time consuming than
Approach 1 because it only required 6,000 hours of testing and then
projected the lifetime based on the lumen maintenance at 6,000 hours.
However, DOE noted in the NOPR that the method used to develop the
ENERGY STAR lifetime projection is unverified and purely theoretical.
Furthermore, Approach 2 did not account for catastrophic lamp failure
beyond the 6,000 hour testing time. Id.
Similar to Approach 2, Approach 3, based on IES LM-79-2008,
directed measuring the lumen output of the LED lamp for a minimum of
6,000 hours. In the NOPR, DOE stated that the collected lumen output
data would then be used to project the L70 lifetime of the
LED lamp using an alternative procedure that would be developed by DOE.
This method would project lifetime based on the performance of an LED
lamp, but would not necessarily be based on a standardized method for
projecting lifetime. 77 FR at 21045.
Finally, Approach 4 required measuring the lumen output of LED
sources (the component of the LED lamp that produces light) at regular
intervals for a minimum of 6,000 hours, based largely on the procedures
in IES LM-80-2008. DOE would then project the time at which the lumen
output of the source reached 70 percent of its initial lumen output
using the projection method in IES TM-21-2011. In the NOPR, DOE
indicated that, although the preferred methodology is to project the
lifetime of an LED lamp rather than an LED source, an industry
standardized method only exists for projecting the lifetime of an LED
source and not an LED lamp. For this reason, DOE tentatively concluded
in the NOPR that Approach 4 was the most appropriate and proposed that
this method be used for estimating the lifetime of an LED lamp. Id.
[[Page 32030]]
DOE received many comments regarding its proposal for measuring
lifetime. Both Kritzer and Samsung agreed with NOPR Approach 4, as
written, for measuring the lifetime of LED lamps. (Kritzer, No. 3 at p.
1, Samsung, No. 14 at p. 1) Kritzer commented that it would be expected
that the proposed method would reduce the amount of time needed for
testing LED lamps and hence also reduce costs. (Kritzer, No. 3 at p. 1)
However, NEMA, Radcliffe Advisors, and the Joint Comment disagreed with
all suggested approaches within the NOPR document, including Approaches
1, 2, and 3 which DOE did not adopt as its proposal. (NEMA, No. 16 at
p. 4; Radcliffe Advisors, No. 13 at p. 1; Joint Comment, No. 18 at p.
1)
Despite their disagreement, NEMA did offer an interim solution to
use until new and revised industry standards are released. Their
proposal combined NOPR Approach 2 and 4. They indicated that NOPR
Approach 2 could be used by those manufacturers who do not have IES LM-
80-2008 data for the LED source within the lamp and that NOPR Approach
4 could be used for those products for which IES LM-80-2008 data does
exist. (NEMA, No. 16 at p. 4, 8) In addition, they suggested that DOE
not include the rapid cycle stress testing suggested in Approach 2.
They indicated that rapid cycle stress testing is practiced for some
lighting technologies; however, this technique is not widely practiced
by the LED industry and has not been verified as relevant to LED
lifetime and performance. (NEMA, No. 16 at p. 9)
DOE appreciates NEMA's interim proposal, but notes that combining
Approaches 2 and 4 would result in some manufacturers reporting
lifetime based on testing of an LED lamp and others reporting lifetime
based on testing of an LED source. The differences between Approaches 2
and 4 would lead to different results for lifetime. DOE cannot adopt
alternative test methods that yield different results as there would be
no basis for establishing any future energy conservation standards.
Furthermore, this combined approach still contains many of the
drawbacks related to the individual approaches.
Regarding Approach 4, DOE received several comments that outlined
the disadvantages of the NOPR proposal for determining the lifetime of
LED lamps. NEMA, Philips, OSI, TUD, the Joint Comment, the CA IOUs,
NEEA, Radcliffe Advisors, the Appliance Standards Awareness Project
(hereafter referred to as ASAP), and Litecontrol advocated basing the
lifetime on measurements of the whole LED lamp and not the LED source
component. They commented that it is undesirable for the lifetime of
LED lamps to be approximated by the lumen maintenance of the LED source
and stated that other components may cause lamp failure before the LED
source falls below 70 percent of its initial light output. (NEMA,
Public Meeting Transcript, No. 7 at p. 83, 84-85, 85; NEMA, No. 16 at
p. 2, 4, 5, 8, 9; Philips, Public Meeting Transcript, No. 7 at pp. 63-
64, 83; OSI, Public Meeting Transcript, No. 7 at p. 69, 100-101; TUD,
No. 15 at p. 1; Joint Comment, No. 18 at p. 1, 2, 4; CA IOUs, No. 19 at
p. 4; NEEA, No. 20 at p. 2, 3; Radcliffe Advisors, No. 13 at p. 1;
ASAP, Public Meeting Transcript, No. 7 at pp. 83-84; Litecontrol, No.
11 at p. 1)
Some interested parties suggested additional considerations for a
procedure that measured the performance of an LED lamp rather than an
LED source. The Joint Comment stated that the test procedure for LED
lamp lifetime include measurements and projections of driver lifetime.
They explained that industry has developed reliability models to
predict theoretical failure rates of LED drivers, and DOE should
investigate these models to determine if using them would help better
capture system effects of an LED lamp. (Joint Comment, No. 18 at p. 1,
4-5) The CA IOUs also suggested that DOE use accelerated testing based
on elevated temperatures, such as the method being explored by the LRC.
(CA IOUs, No. 19 at p. 5)
DOE has considered all comments received about the four approaches
discussed in the NOPR and has decided to significantly change its
approach for determining the lifetime of LED lamps in this SNOPR. DOE
agrees that there are several potential issues with requiring lumen
maintenance testing of the LED source component, as proposed in
Approach 4. DOE has preliminarily concluded in this SNOPR that the test
procedure for lifetime must directly measure the performance of an LED
lamp. DOE acknowledges that LED driver degradation and interactions
between the LED sources and other components are known to affect the
lifetime of integrated LED lamps. Regarding the proposal by the Joint
Comment, DOE conducted research of existing driver reliability modeling
and test procedures, including those specified in the military handbook
MIL-HDBK-217F,\35\ to determine whether driver failure could be
included in the projection of LED lamp lifetime. However, DOE
determined that no test procedures are available that use the expected
failure of the LED driver to predict the failure of the complete LED
lamp system. The CA IOUs suggested that DOE consider accelerated
testing based on elevated temperatures for the lifetime test procedure.
However, DOE research of existing literature and industry test
procedures indicates that accelerated test methods for LED lamp
lifetime are not available, and therefore, are not ready for inclusion
in the SNOPR.
---------------------------------------------------------------------------
\35\ Society of Reliability Engineers, Reliability Prediction of
Electronic Equipment, December 1991. http://www.sre.org/pubs/Mil-Hdbk-217F.pdf.
---------------------------------------------------------------------------
As mentioned above, DOE has decided to measure directly the
performance of an LED lamp and does not propose requiring testing of
LED sources or any individual lamp component. The complete SNOPR method
is described in section III.D.3. Although DOE has decided to make this
change, DOE did receive comments on specific aspects of the NOPR
proposal. These comments are discussed in further detail below.
a. Industry Standards
In the NOPR, DOE proposed measuring the lumen output of LED sources
based on IES LM-80-2008 and then projecting the time at which the lumen
output of the source reached 70 percent of the initial lumen output
based on IES TM-21-2011. 77 FR at 21045 NEMA, Cree, Radcliffe Advisors,
the CA IOUs, and Philips commented that the NOPR proposal modifies and
misapplies industry standards, and argued that both IES LM-80-2008 and
IES TM-21-2011 provide procedures to measure lumen maintenance of the
LED source and should not be used to estimate the lifetime of LED
lamps. (NEMA, No. 16 at p. 2, 5, 7; Cree, Public Meeting Transcript,
No. 7 at pp. 95-96, 109; Radcliffe Advisors, No. 13 at p. 1; CA IOUs,
No. 19 at p. 5, 6; Philips, Public Meeting Transcript, No. 7 at p. 114)
NEMA specified that DOE only reference IES LM-79-2008 because this
standard applies to LED lamps, which are the subject of this
rulemaking. (NEMA, No. 16 at p. 6)
DOE understands that both IES LM-80-2008 and IES TM-21-2011 are
industry standards for measuring and predicting the lumen maintenance
of an LED source. In the NOPR, DOE proposed referencing these standards
to measure the lumen maintenance of an LED source because DOE believed
it would be an adequate approximation for determining the lifetime of
LED lamps. However, based on the comments received in response to the
NOPR, DOE has changed its proposed procedure to
[[Page 32031]]
measure the lifetime of LED lamps. In this SNOPR, DOE proposes
assessing the lumen maintenance of an LED lamp and does not require
testing of LED sources. DOE's lifetime proposal, described in section
III.D.3, uses the procedures of IES LM-79-2008 to measure the lumen
output of an LED lamp.
b. LED Source In-Situ Temperature
In the NOPR, DOE proposed performing an in-situ temperature
measurement test (ISTMT) to determine the case temperature at which the
lumen maintenance data shall be obtained to project the lifetime of the
LED source. 77 FR at 21047 DOE proposed that the test setup,
conditions, test equipment, instrumentation, and test box material and
construction for the ISTMT be as specified in UL 1993-2009.\36\ UL, GE,
Cree, NEMA, and Feit argued that the test setup specified in UL 1993-
2009 is designed to represent a worst-case installation scenario. (UL,
Public Meeting Transcript, No. 7 at p. 110; GE, Public Meeting
Transcript, No. 7 at p. 91; Cree, Public Meeting Transcript, No. 7 at
p. 93; NEMA, No. 16 at p. 5; Feit, Public Meeting Transcript, No. 7 at
p. 93) Specifically, NEMA expressed concern that the test setup
described in UL 1993-2009 would elevate the ambient air to a
temperature greater than 25 [deg]C, which conflicts with the
requirement to measure photometric characteristics at 25 [deg]C. This
increase in temperature could also lead to changes in the photometric
performance of the LED sources. Furthermore, NEMA commented that using
UL 1993-2009 would force LED lamp manufacturers to increase design
margins for lumens and other lamp characteristics to account for the
temperature increase of the UL test conditions. This would lead to the
over-design of LED lamps. (NEMA, No. 16 at p. 7) GE and NEMA concluded
that UL 1993-2009 should not be used as part of the instruction for the
ISTMT. (GE, Public Meeting Transcript, No. 7 at p. 91; NEMA, No. 16 at
p. 5, 7) The Joint Comment indicated that DOE should carefully consider
whether UL 1993-2009 represents an average installation or a worst-case
scenario. (Joint Comment, No. 18 at p. 3) However, Intertek argued that
UL 1993-2009 is designed to represent typical installation conditions.
(Intertek, Public Meeting Transcript, No. 7 at p. 92, 93).
---------------------------------------------------------------------------
\36\ ``Self-Ballasted Lamps and Lamp Adapters.'' Published by UL
on August 28, 2009.
---------------------------------------------------------------------------
The Joint Comment explained that temperature plays a critical role
in the failure of LED lamps. They commented that an appropriate
lifetime test method would take careful account of all the real-world
installation parameters that could impact the natural operating
temperature of the device. The Joint Comment indicated that this would
include orientation, natural air circulation around the device, and all
the effects from other physical connections/thermal pathways. In
contrast with the manufacturers' recommendation, the Joint Comment
supported a test procedure that approximates a worst-case installation
scenario if knowledge about field installations is missing or
insufficient. (Joint Comment, No. 18 at p. 2-3) The Joint Comment
recommended that DOE carefully consider whether UL 1993-2009 represents
an average U.S. installation or a worst-case scenario and provide
justification as to why its use is appropriate. (Joint Comment, No. 18
at p. 3)
In this SNOPR, DOE has proposed a new test procedure for measuring
the lifetime of LED lamps that does not require determining the in-situ
temperature of the LED source. The test conditions for the new proposal
are discussed in section III.D.3.b.
c. LED Source Lumen Maintenance
IES LM-80-2008 requires manufacturers to test LED sources at three
temperatures: 55 [deg]C, 85 [deg]C, and a third temperature suggested
by the source manufacturer. A lamp manufacturer can then interpolate
the performance of the source at any temperature bounded by those three
temperatures, avoiding the need to conduct additional LED source
testing for their specific LED lamp. However, IES LM-80-2008 does not
provide a method for extrapolating LED source performance at an in-situ
temperature that is not bounded by those three temperatures. In this
case (an uncommon situation), DOE proposed in the NOPR that LED lamp
manufacturers would need to test the LED sources at the in-situ
temperature of their lamp to obtain the lumen maintenance data to
project the lifetime. 77 FR at 21046 DOE's NOPR proposal did not modify
IES LM-80-2008, instead it provided additional test methods for
situations outside the applicability of IES LM-80-2008.
DOE received several comments requesting that DOE not modify IES
LM-80-2008 and stating that proposed testing of LED sources would be
costly. NEMA, the CA IOUs, and NEEA commented that DOE should not
modify the test procedures specified in IES LM-80-2008. (NEMA, No. 16
at p. 5; CA IOUs, No. 19 at pp. 5-6; NEEA, No. 20 at p. 2).
Furthermore, NEEA commented that aligning DOE's test procedure and IES
LM-80-2008 will reduce the testing burden on manufacturers. (NEEA, No.
20 at p. 2) The CA IOUs elaborated that LED source testing at the case
temperature identified during the ISTMT would be impractical and/or
costly for industry because LED sources are often brought to market
with their IES LM-80-2008 testing already complete. (CA IOUs, No. 19 at
pp. 5-6)
Two commenters requested further clarification of IES LM-80-2008.
Regarding the temperature requirements, South Korea commented that
international standards do not prescribe any specific temperatures at
which to measure the lumen maintenance of the LED source. If DOE
determines it is important to test the sources at 55 [deg]C and 85
[deg]C, DOE should seek scientific justification for these
requirements. (South Korea, No. 17 at p. 3) Samsung also requested that
DOE specify the location on the LED source where temperature is
measured. (Samsung, No. 14 at p. 1)
DOE also received several comments indicating that DOE's proposal
for procurement of LED source lumen maintenance data could require
disassembly of a lamp in some cases. GE, OSI, and NEMA commented that
manufacturers would need to extract the LED source from the finished
lamp product if IES LM-80-2008 data is unavailable. (GE, Public Meeting
Transcript, No. 7 at p. 94, 95, 100; OSI, Public Meeting Transcript,
No. 7 at pp. 100-101; NEMA, No. 16 at p. 6) To avoid extracting the LED
source, GE recommended that DOE consider multiple lifetime measurement
approaches depending on the availability of IES LM-80-2008 data. (GE,
Public Meeting Transcript, No. 7 at pp. 78-79)
In the NOPR, DOE also proposed using the relevant guidelines from
an ENERGY STAR specification document to measure the lumen maintenance
for LED sources.\37\ 77 FR at 21048 Cree commented that for lamps that
use both white and red LED sources there is uncertainty as to whether
the IES LM-80-2008 data from the individual sources can be added
together to accurately represent their combined performance. Cree also
noted ENERGY STAR is currently accepting this practice. (Cree, Public
Meeting
[[Page 32032]]
Transcript, No. 7 at p. 106) Both NEMA and Radcliffe Advisors stated
that this is not an issue because DOE's test procedure should not
require testing of any individual component of an LED lamp. All testing
procedures should measure performance of the complete lamp product.
(NEMA, No. 16 at p. 4-5; Radcliffe Advisors, No. 13 at p. 1)
---------------------------------------------------------------------------
\37\ ENERGY STAR Program Guidance Regarding LED Package, LED
Array and LED Module Lumen Maintenance Performance Data Supporting
Qualification of Lighting Products, September 9, 2011.
www.energystar.gov/ia/partners/prod_development/new_specs/downloads/luminaires/ENERGY_STAR_Final_Lumen_Maintenance_Guidance.pdf.
---------------------------------------------------------------------------
DOE agrees there are drawbacks (including disassembly of the lamp
to extract an LED source) to testing the LED source component as a
proxy for estimating the lifetime of an LED lamp as outlined in IES LM-
80-2008. Therefore, DOE has developed a new proposal that only requires
testing of an LED lamp and is no longer using the test procedures in
IES LM-80-2008 or IES TM-21-2011. The new test procedure for LED lamps
indicates that after the test duration, lumen output must be measured
as specified in IES LM-79-2008. The lifetime of the LED lamp can then
be projected using an equation. The proposed method for lifetime
testing is discussed in more detail in section III.D.3.
d. Test Conditions
In the NOPR, DOE proposed that the temperature of the surrounding
air during testing be maintained between the case temperature and 5
[deg]C below the case temperature as specified in section 4.4.2 of IES
LM-80-2008. DOE also proposed that airflow around the LED sources be as
specified in section 4.4.3 of IES LM-80-2008, which states that the
airflow shall be maintained to minimize air drafts but allow some
movement of the air to avoid thermal stratification. 77 FR at 21046
NEMA and Cree commented that the upcoming IES LM-80-2008 revisions will
include recommendations on best practices for measuring and monitoring
air flow through the test system. (NEMA, Public Meeting Transcript, No.
7 at p. 97; Cree, Public Meeting Transcript, No. 7 at p. 97) However,
NEMA indicated that current test methods have led industry to believe
that the surrounding air temperature and airflow do not have noticeable
impact on long-term LED lumen degradation. They suggested that current
IES LM-79-2008 air movement requirements are more than adequate to
ensure the accuracy of test data. (NEMA, No. 16 at p. 5) TUD disagreed
with the specified test conditions, indicating that they cannot
sufficiently simulate all real world conditions. (TUD, No. 15 at p. 1)
As previously mentioned, for this SNOPR, DOE has developed a test
procedure that only requires testing of an LED lamp. Therefore, DOE no
longer references IES LM-80-2008, which applies to LED sources. The
SNOPR has proposed less stringent ambient temperature and airflow
conditions for periods when a lamp is operating but measurements are
not being taken. These requirements are discussed in more detail in
section III.D.3.b.
e. LED Source Orientation
In the NOPR, DOE proposed that the LED sources be operated in
accordance with section 4.4.4 of IES LM-80-2008, which requires
operating LED sources in the orientation specified by the source
manufacturer. Id. DOE noted that it is not specifying the orientation
for testing LED sources and invited interested parties to comment on
whether the operating orientation of the LED sources during testing
affects the lumen depreciation over time. Cree, Samsung, and NEMA
commented that DOE should not require additional marking or testing
based on orientation. (Cree, Public Meeting Transcript, No. 7 at p. 98;
Samsung, No. 14 at p. 1; NEMA, No. 16 at p. 6) NEMA stated that the
orientation specified in IES LM-80-2008 is only provided to establish a
common testing protocol, not because there is any evidence that
orientation affects performance. In this SNOPR, DOE is not referencing
the test procedures provided in IES LM-80-2008, which apply to LED
sources. Instead, DOE is proposing a new test procedure for lifetime
which measures the performance of LED lamps. Because DOE believes that
orientation impacts the performance of LED lamps, DOE is proposing that
lamps be tested in both the base-up and base-down positions. The
orientation requirements for lifetime are discussed in section
III.C.3.b.
f. External Driver Requirements
As specified in IES LM-80-2008, in the NOPR, DOE proposed using an
external driver that is compliant with manufacturer's guidance to drive
the LED source. 77 FR at 21047 Both Cree and NEMA opposed using
external drivers to test LED sources, while Samsung thought the use of
an external driver was appropriate. (Cree, Public Meeting Transcript,
No. 7 at p. 99; NEMA, No. 16 at p. 6; Samsung, No. 14 at p. 1) NEMA
indicated that the FTC label only regulates medium screw-base products
(as defined in CFR 430.2). Therefore, if the lamp is to connect to the
power supply via an ANSI base, there must be an integrated driver
rather than an external driver. (NEMA, No. 16 at p. 6) In this SNOPR,
DOE is proposing a new test procedure that measures the performance of
an LED lamp and is no longer utilizing the test procedures provided in
IES LM-80-2008. The new proposal does not require the use of an
external driver because an internal driver is included in an integrated
LED lamp. The SNOPR proposal for determining the lifetime of LED lamps
is detailed in section III.D.3.
g. Lumen Maintenance Measuring Equipment
IES LM-80-2008 specifies using a spectroradiometer to measure the
lumen output of an LED source. In the NOPR, DOE proposed using a
sphere-spectroradiometer, sphere-photometer, or a goniophotometer to
measure the lumen output of the LED source. 77 FR at 21043 Cree agreed
that all three instruments are appropriate to measure the lumen output
of LED sources. Cree indicated that IES LM-80-2008 does not specify the
use of a goniophotometer because this equipment cannot be used to
measure many of the other photometric and electrical characteristics
that the standard requires. (Cree, Public Meeting Transcript, No. 7 at
p. 103) NEMA disagreed with DOE's proposal and recommended that DOE not
modify the IES LM-80-2008 procedures. (NEMA, Public Meeting Transcript,
No. 7 at p. 104; NEMA, No. 16 at p. 6) Samsung commented that requiring
only a sphere-spectroradiometer would be suitable. (Samsung, No. 14 at
p. 1)
For this SNOPR, DOE is no longer proposing to use the test
procedures provided in IES LM-80-2008. Because DOE proposes to measure
the lifetime of LED lamps rather than LED sources, the SNOPR proposes
the use of the lumen output measuring equipment described in IES LM-79-
2008. As discussed in section III.C.3.b, DOE proposes that the
instrumentation used for lumen output measurement of LED lamps be as
described in sections 9.1 and 9.2 of IES LM-79-2008 and that goniometer
systems not be used.
h. LED Source Seasoning
Regarding seasoning of the LED source for lifetime measurements,
the Joint Comment argued that if DOE proposes a lifetime test method
that involves projection of the LED source using the Arrhenius equation
as the functional form of lumen degradation, the proposal should
include seasoning. (Joint Comment, No. 18 at pp. 5-6) DOE's proposal in
the SNOPR (discussed in section III.D.3) involves measurements of the
LED lamp, not the LED source. Therefore, DOE is not proposing a
seasoning requirement for LED sources in the SNOPR.
i. Maximum Lifetime
In the NOPR, DOE proposed projecting the lifetime as specified in
[[Page 32033]]
section 5.0 of IES TM-21-2011. DOE also proposed that if the projected
rate lifetime is greater than 25,000 hours, the maximum lifetime is
25,000 hours. If the projected lifetime is less than 25,000 hours, the
lifetime is the projected value. 77 FR at 21048
Litecontrol, Radcliffe Advisors, South Korea, Kritzer, an Anonymous
commenter, the CA IOUs, NEMA, and Philips disagreed with the proposal
to cap lifetime at 25,000 hours, stating that applying an arbitrary cap
discourages manufacturer improvements to lifetime. (Litecontrol, No. 11
at p. 1; Radcliffe Advisors, No. 13 at p. 2; South Korea, No. 17 at p.
3; Kritzer, No. 8 at p. 1; Anonymous, No. 8 at p. 1; CA IOUs, No. 19 at
p. 4; NEMA, Public Meeting Transcript, No. 7 at p. 65, 72-74; NEMA, No.
16 at p. 5; Philips, Public Meeting Transcript, No. 7 at p. 111) NEMA
commented that applying a cap of 25,000 hours is contrary to FTC
instruction, contradicts the recent L-Prize winning lamp's lifetime
rating,\38\ and limits payback analysis for rebate programs. (NEMA, No.
16 at p. 5) The Joint Comment indicated that the lifetime cap leaves
little incentive for manufacturers to test for longer periods of time
with larger samples to reduce measurement uncertainty. (Joint Comment,
No. 18 at p. 5) Kritzer pointed out that LED lamps are rapidly
improving in performance and limiting these products to a lifetime of
25,000 hours would affect their ability to compete with fluorescent
technologies, which advertise lifetimes as long as 40,000 hours.
(Kritzer, No. 8 at p. 1)
---------------------------------------------------------------------------
\38\ The Philips L-Prize Winning LED Bulb is rated at 30,000
hours and has undergone over 7,000 hours of lumen maintenance
testing. www.lightingprize.org/60watttest.stm.
---------------------------------------------------------------------------
Some interested parties suggested alternate proposals for limiting
maximum lifetime claims. South Korea proposed that the lifetime cap be
raised to 36,000 hours to be consistent with IES TM-21-2011, which
specifies that if the LED sources are tested beyond 6,000 hours they
can report up to 36,000 hours. (South Korea, No. 17 at p. 3) NIST
commented that the lifetime cap should only be raised if manufacturers
can provide statistics to prove their reported values. (NIST, Public
Meeting Transcript, No. 7 at p. 78) Alternatively, NEMA suggested that
methods for projecting lifetime beyond 25,000 hours could be drawn from
the ENERGY STAR solid-state lighting (hereafter referred to as SSL)
program and other products such as electronic fluorescent ballasts.
(NEMA, No. 16 at p. 7) The ENERGY STAR test procedure for lifetime
includes a projection method based on lumen maintenance testing of an
integrated lamp and does not require testing of the embedded LED
source. In addition, their projection method specifies that an LED lamp
has the potential to be rated at a lifetime greater than 25,000 hours
if additional testing beyond the minimum required 6,000 hours of lumen
maintenance testing is conducted (see supra note 28). The Joint Comment
agreed with the need to limit unreasonable lifetime claims and asked
DOE to work with industry to investigate a set of confidence criteria
to define a lifetime metric. (Joint Comment, No. 18 at p. 5) The Joint
Comment argued that the goal of the FTC Lighting Facts label should be
to give customers the most accurate information possible regarding the
quality and lifetime of this product, and that establishing proper test
procedures will help ensure this happens. (Joint Comment, No. 18 at p.
5)
After considering the comments about the NOPR lifetime cap
proposal, DOE has removed the 25,000 hour lifetime cap and developed a
proposal where the maximum lifetime of LED lamps depends on the test
duration. To prevent unreasonable lifetime claims based on a limited
amount of test data, DOE proposes that lifetime claims be limited to no
more than four times the duration of the test period. This limit
reflects ENERGY STAR's requirements to support lifetime claims beyond
25,000 hours, which require a test duration that is 25 percent of the
maximum projection. For example, to report a projected L70
lifetime of 30,000 hours, at least 7,500 hours of testing (and a lumen
maintenance of at least 70 percent at that time) would be required.
Requiring four times the duration of the test period is more
conservative than industry standard IES TM-21-2011 for LED sources,
which limits the L70 projection to no more than 5.5 or 6
times the testing time (depending on sample size). A more conservative
approach is reasonable because this test procedure applies to
integrated LED lamps rather than LED sources. DOE invites comment on
the proposed requirement to limit lifetime claims to four times the
duration of the test period.
j. Market Introduction
TUD commented that requiring a minimum test duration of 6,000 hours
could delay the market introduction of LED lamp products. (TUD, No. 15
at p. 1) In this SNOPR, DOE is proposing a new test method which does
not require a minimum duration of testing. Rather, DOE allows the
manufacturer to determine the test duration and then limits lifetime
claims to four times the test duration.
3. SNOPR Proposed Lifetime Method
In this SNOPR, DOE proposes a new test procedure for lifetime that
addresses many of the stakeholder concerns regarding the NOPR proposal
for measuring the lifetime of LED lamps. This proposal is simple,
straightforward, and allows significant flexibility if lifetimes of LED
products change in the future. As stated in section III.D.1, DOE
defines the lifetime of an LED lamp as the time at which a lamp reaches
a lumen maintenance of 70 percent (i.e., 70 percent of initial lumen
output, or L70). In this SNOPR, DOE proposes to measure the
lumen output of an LED lamp rather than the LED source contained in the
lamp. Thus, the test procedure directly measures the performance of the
actual product rather than an internal component. This considerably
simplifies compliance testing and provides a consistent procedure to be
used for all products. The methodology proposed in the SNOPR consists
of four main steps: (1) measuring the initial lumen output; (2)
operating the lamp for a period of time (test duration); (3) measuring
the lumen output at the end of the test duration; and (4) projecting
L70 using an equation adapted from the underlying
exponential decay function in ENERGY STAR's most recent specification
for integrated LED lamps, Program Requirements for Lamps (Light Bulbs):
Eligibility Criteria--Version 1.0. (see supra note 10) The equation
projects lifetime using the test duration and the lumen maintenance at
the end of the test duration as inputs. The following sections discuss
the methodology in greater detail.
a. Initial Lumen Output
Initial lumen output is the measured amount of light that a lamp
provides at the beginning of its life, after it is initially energized
and stabilized using the stabilization procedures in section III.C.4.b.
An initial lumen output measurement is required to calculate lumen
maintenance, which is an input for the lifetime projection. The test
procedure for lumen output is described in section III.B. The
methodology, test conditions, and setup requirements are unchanged when
measuring initial lumen output for the lifetime test procedure.
b. Test Duration
The period of time starting immediately after the initial lumen
output measurement and ending when the final lumen output measurement
is
[[Page 32034]]
recorded, is referred to as the ``test duration'' or time ``t.'' The
test duration does not include any time when the lamp is not energized.
If lamps are turned off (possibly for transport to another testing area
or during a power outage), DOE proposes that the time spent in the off-
state not be included in the test duration. DOE does not specify a
minimum test duration or measurement interval, so manufacturers can
customize the test duration based on the expected lifetime of the LED
lamp. During this time, the LED lamps are turned on (energized) and
operated for a period of time determined by the manufacturer. To reduce
test burden, the operating conditions required during the test duration
while measurements are not being taken are less stringent than those
required when taking photometric measurements (e.g., ambient
temperature). The following sections discuss the required operating
conditions for lamp operation between lumen output measurements in more
detail.
Ambient Temperature and Air Flow
DOE recognizes that while operating an LED lamp, lumen output can
vary with changes in ambient temperature, air flow, vibration, and
shock. For this reason, DOE proposes specific requirements for
quantities such as ambient temperature and air flow for photometric
measurements in section III.C.2. However, because lamps may need to be
operated for an extended period of time for the purpose of lifetime
testing, DOE proposes less stringent requirements when measurements are
not being taken. DOE proposes that ambient temperature be maintained
between 15 [deg]C and 40 [deg]C. DOE also proposes minimizing air
movement surrounding the test racks, and that the LED lamps not be
subject to excessive vibration or shock. These test conditions will
enable reliable, repeatable, and consistent test results without
significant test burden and are discussed in further detail below:
To determine ambient temperature requirements, DOE reviewed
industry standard IES LM-65-10 ``Approved Method Life Testing of
Compact Fluorescent Lamps.'' \39\ Section 4.3 of IES LM-65-10 requires
that ambient temperature be controlled between 15 [deg]C and 40 [deg]C.
Although industry standard IES LM-65-10 is intended for compact
fluorescent lamps, DOE proposes that this ambient temperature range is
appropriate for the operation of LED lamps because NEMA commented that
current test methods have led industry to believe that the surrounding
air temperature and airflow does not have a noticeable impact on long-
term LED lumen degradation. (NEMA, Public Meeting Transcript, No. 7 at
pp. 2-3; NEMA, No. 16 at p. 2-3) DOE believes that an ambient
temperature range between 15 [deg]C and 40 [deg]C encompasses the
majority of possible room temperature conditions while limiting test
burden. Therefore, in this SNOPR, DOE proposes that ambient temperature
be controlled between 15 [deg]C and 40 [deg]C. DOE requests comments on
this proposal.
---------------------------------------------------------------------------
\39\ ``Approved Method Life Testing of Compact Fluorescent
Lamps.'' Approved by IES on December 13, 2010.
---------------------------------------------------------------------------
DOE proposes that LED lamp testing racks be open and designed with
adequate lamp spacing and minimal structural components to maintain
ambient temperature conditions. Furthermore, similar to the
requirements in section 4.2 of IES LM-65-10, DOE proposes minimizing
airflow surrounding the LED lamp testing racks and that the lamps not
be subjected to excessive vibration or shock. DOE believes that these
requirements would minimize the impact of airflow and the physical
environment while minimizing test burden. DOE invites comments on the
minimization of vibration, shock, and air movement, as well as the
requirement for adequate lamp spacing during lamp operation in order to
maintain ambient temperature conditions.
Power Supply
DOE proposes that section 3.1 of IES LM-79-2008 be incorporated by
reference to specify requirements for both AC and DC power supplies.
This section specifies that an AC power supply shall have a sinusoidal
voltage waveshape at the input frequency required by the LED lamp such
that the RMS summation of the harmonic components does not exceed three
percent of the fundamental frequency while operating the LED lamp.
Section 3.2 of IES LM-79-2008 also requires that the voltage of an AC
power supply (RMS voltage) or DC power supply (instantaneous voltage)
applied to the LED lamp shall be within 0.2 percent of the
specified lamp input voltage. However, DOE determined that the IES LM-
79-2008 voltage tolerances are too burdensome to maintain for the
extended time period for which a lamp may need to be operated to
determine lifetime. When not taking measurements, DOE proposes to adopt
provisions similar to section 5.3 of IES LM-65-10 which requires that
the input voltage be monitored and regulated to within 2.0
percent of the rated RMS voltage. DOE believes that this requirement is
achievable with minimal test burden and provides reasonable stringency
in terms of power quality based on its similarity to voltage tolerance
requirements for other lamp types. DOE invites comments on the proposal
to adopt section 3.1 of IES LM-79-2008 requirements for both AC and DC
power supplies. DOE also requests comment on the requirement that input
voltage be monitored and regulated to within 2.0 percent of
the rated RMS voltage as specified in section 5.3 of IES LM-65-2010.
Lamp Mounting and Orientation
DOE proposes that the LED lamps be tested in the base-up and base-
down orientations for lumen maintenance testing. Section III.C.3.b
notes that LED lamp test data provided by ENERGY STAR, as well as PG&E,
CLASP, and CLTC, has revealed that there was variation between the
base-up, base-down and horizontal orientations (see supra note 20). Of
the three orientations, analysis revealed that the base-up and base-
down orientations represent the best (highest lumen output) and worst
(lowest lumen output) case scenarios.
Electrical Settings
DOE proposes adopting the electrical settings in section 7.0 of IES
LM-79-2008. Section III.C.3.d details the required electrical settings
for input voltage and how to operate lamps with multiple modes of
operation, such as variable CCT and dimmable lamps.
Operating Cycle
Lifetime test procedures for other lamp types sometimes require
``cycling,'' which means turning the lamp on and off at specific
intervals over the test period. However, industry has stated that
unlike other lighting technologies, the lifetime of LED lamps is
minimally affected by power cycling.\40\ Therefore, in this SNOPR, DOE
proposes to operate the LED lamp continuously and requests feedback on
the appropriateness of not requiring cycling in the test procedure for
lifetime.
---------------------------------------------------------------------------
\40\ NEMA Comments on ENERGY STAR Program Requirements Product
Specification for Lamps (Light Bulbs) Version 1.0, Draft 2http://energystar.gov/products/specs/sites/products/files/NEMA.pdf.
---------------------------------------------------------------------------
c. Lumen Output at the End of the Test Duration
Any lumen output measurement after the measurement of initial lumen
output, including that at the end of the test duration, is measured
under the
[[Page 32035]]
conditions and setup described in section III.B. DOE proposes
stabilizing the LED lamp before measuring lumen output at the end of
the test duration. Section III.C.4.b details the LED lamp stabilization
procedure.
d. Lumen Maintenance Calculation and Lifetime Projection
As discussed in section III.D.1, DOE proposes to define LED lamp
lifetime as the time required to reach a lumen maintenance of 70
percent (L70). Lumen maintenance is the measure of lumen
output after an elapsed operating time, expressed as a percentage of
the initial lumen output (the definition of initial lumen output is
provided in section III.D.3.a). DOE proposes that the lumen maintenance
at the end of the test duration equal the lumen output at the end of
the test duration (see section III.D.3.c) divided by the initial lumen
output.
DOE developed an equation to project the time at which an LED lamp
reaches L70 based on the underlying exponential decay
function used in the ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0 (see supra note 10). ENERGY
STAR utilizes an exponential decay function to calculate maximum
L70 life claims between 15,000 and 50,000 hours at
increments of 5,000 hours. The ENERGY STAR procedure requires a 6,000
hour test duration and provides lumen maintenance thresholds for each
incremental L70 lifetime claim. Unlike ENERGY STAR, DOE does
not have minimum lifetime requirements for LED lamps. Therefore, to
enable reporting of lifetimes less than 15,000 hours and greater than
50,000 hours, DOE has reorganized the underlying ENERGY STAR equation
to calculate L70 given the initial lumen output ``x0'', the
test duration ``t'', and the final lumen output at the end of the test
duration ``xt'' as inputs. DOE's equation is detailed below.
[GRAPHIC] [TIFF OMITTED] TP03JN14.011
L70 = Time to Reach 70% Lumen Maintenance
t = Test Duration
x0 = Initial Lumen Output
xt = Final Lumen Output at time ``t''
DOE requests comment on the proposed equation for projecting the
L70 lifetime of LED lamps.
DOE proposes that lifetime claims be limited to no more than four
times the test duration ``t.'' For example, if an LED lamp is tested
for 6,000 hours and has a lumen maintenance value of 93.1 percent at
that time, the L70 projection equation indicates that the
L70 lifetime is about 30,000 hours. However, the maximum
that could be reported based on the DOE proposal is only 24,000 hours
(four times the testing time of 6,000 hours). For lumen maintenance
values less than 70 percent, including lamp failures that result in
complete loss of light output, the SNOPR proposes that lifetime must
not be projected; instead, the lumen maintenance is equal to the
previously recorded lumen output measurement at the test duration where
the lumen maintenance is greater than or equal to 70 percent. DOE also
recognizes that it is possible that the calculated lumen maintenance at
time ``t'' could be greater than or equal to 100 percent. When this
occurs, DOE proposes that lifetime claims be determined by the maximum
projection limit. Due to the similarity of the DOE and ENERGY STAR
lifetime test procedures, manufacturers may choose to utilize lumen
maintenance measurements collected for the ENERGY STAR specification.
However, measurements must adhere to DOE's electrical setting
requirements proposed in section III.C.3.d and manufacturers must
include all LED lamps within the 10 lamp sample in the reported results
including lamp failures. DOE requests comments on its proposal to limit
the maximum lifetime to four times the test duration with no minimum
test duration.
Finally, DOE also notes that a manufacturer can report the test
duration as measured without applying the projection equation. This
approach applies to two scenarios. In the first scenario, a
manufacturer can test the lamp until it reaches 70 percent lumen
maintenance and use that test duration as the lifetime of the lamp.
This is equivalent to using the projection equation, because the output
of the projection equation would be the same as the test duration when
lumen maintenance of 70 percent is reached. In the second scenario, a
manufacturer can use the test duration associated with a lumen
maintenance greater than 70 percent. This scenario is equivalent to a
manufacturer using the projection equation, but electing to report a
more conservative value for business reasons. Reporting of conservative
values is permitted and is also discussed in section III.F.3.
E. Proposed Approach for Standby Mode Power
EPCA section 325(gg)(2)(A) in part directs DOE to establish test
procedures to include standby mode, ``taking into consideration the
most current versions of Standards 62301 and 62087 of the International
Electrotechnical Commission . . .'' (42 U.S.C. 6295(gg)(2)(A)) IEC
Standard 62087 applies only to audio, video, and related equipment, but
not to lighting equipment. Thus, IEC Standard 62087 does not apply to
this rulemaking, so DOE developed this SNOPR consistent with procedures
outlined in IEC Standard 62301, which applies generally to household
electrical appliances. However, to (1) develop a test method that would
be familiar to LED lamp manufacturers and (2) maintain consistent
requirements to the active mode test procedure, DOE referenced language
and methodologies presented in IES LM-79-2008 for test conditions and
test setup requirements.
A standby mode power measurement is an input power measurement made
while the LED lamp is connected to the main power source, but not
generating light (active mode). All test condition and test setup
requirements used for active mode measurements (e.g., input power) (see
sections III.C.2 and III.C.3) also apply to standby mode power
measurements. Once the test conditions and setup have been implemented,
the LED lamp should be seasoned and stabilized in accordance with the
requirements in sections III.C.4.a and III.C.4.b of this SNOPR. After
the lamp has stabilized, the technician should send a signal to the LED
lamp instructing it to enter standby mode (which is defined as
providing zero light output). Standby power is then measured in
accordance with section 5 of IEC 62301.
F. Basic Model, Sampling Plan, and Reported Value
1. Basic Model
In this SNOPR, DOE proposes amendments to the term ``basic model''
to include LED lamps. ``Basic model'' is currently defined (with some
exceptions) to mean all units of a given type of covered product (or
class thereof) manufactured by one manufacturer, having the same
primary energy source, and which have essentially identical electrical,
physical, and functional (or hydraulic) characteristics that affect
energy consumption, energy efficiency, water consumption, or water
efficiency; and with respect to general service fluorescent lamps,
general service incandescent lamps, and reflector lamps: Lamps that
have essentially identical light output and electrical
characteristics--including lumens per
[[Page 32036]]
watt (lm/W) and color rendering index (CRI). 10 CFR 430.2
DOE proposes to add a specification for LED lamps in the definition
of basic model in order to provide further guidance on the electrical,
physical, and functional characteristics that constitute a basic model.
Specifically, DOE proposes that a basic model for an integrated LED
lamp should represent lamps that have essentially identical light
output and electrical characteristics including lumens per watt, CRI,
CCT, and lifetime. Because these are the general characteristics by
which manufacturers identify their lamps in catalogs and marketing
material, DOE believes these parameters should be used to group lamps
of the same type.
DOE proposes to qualify the term ``basic model'' in 10 CFR 430.2
for LED lamps as lamps that have essentially identical light output and
electrical characteristics--including lumens per watt (lm/W), color
rendering index (CRI), correlated color temperature (CCT), and
lifetime.
DOE requests comments on the revision to the definition of ``basic
model'' to address LED lamps.
2. Sampling Plan
In the NOPR, DOE proposed a sampling plan for LED lamps to
determine input power, lumen output, and CCT, and a separate sampling
plan for LED sources to determine lifetime. DOE proposed testing a
minimum of 21 LED lamps to determine the input power, lumen output, and
CCT. DOE proposed that manufacturers select a minimum of three lamps
per month for seven months of production out of a 12 month period. If
lamp production occurs in fewer than seven months of the year, three or
more lamps must be selected for each month that production occurs,
distributed as evenly as possible to meet the minimum 21 unit
requirement. The seven months need not be consecutive and could be a
combination of seven months out of the 12 months. Sample sizes greater
than 21 must be multiples of three so that an equal number of lamps
were tested in each orientation (based on the lamp orientation
requirements in the NOPR). 77 FR at 21049 (April 9, 2012)
To determine the lifetime of LED lamps, DOE proposed in the NOPR
that the sample size for testing LED sources be as specified in section
4.2 of IES TM-21-2011. The IES TM-21-2011 industry standard requires a
minimum of ten units to be tested, but recommends a sample set of 20
units for projecting the lifetime of the LED sources. The method of
projection specified in IES TM-21-2011 cannot be used for less than ten
units. 77 FR at 21049
Regarding the sampling plan proposal for lumen output, CCT, and
wattage testing, NEMA and P.R. China commented that the sampling plan
should be based on the ENERGY STAR specification for integral LED
lamps, which requires a sample size of 10: five base-up and five base-
down. (NEMA, Public Meeting Transcript, No. 7 at p. 49; NEMA, No. 16 at
p. 8; P.R. China, No. 12 at pp. 4-5) In addition, ENERGY STAR has no
requirements for how lamps are selected for testing. NEMA opposed
gathering product samples over the course of a year because the
associated time to gather and test samples is much greater than a year.
(NEMA, No. 16 at p. 8) NEMA recommended that DOE not copy the sampling
requirements from other lighting technology rules. (NEMA, No. 16 at p.
9) In addition, NEMA, Cree, OSI, and South Korea commented that solid-
state lighting is still an emerging technology and requiring large test
samples and long testing time will significantly delay market
introduction. (NEMA, Public Meeting Transcript, No. 7 at p. 51; Cree,
Public Meeting Transcript, No. 7 at p. 52; OSI, Public Meeting
Transcript, No. 7 at p. 53; South Korea, No. 17 at pp. 2-3) Philips
added that LED lamp designs are evolving rapidly and often product
models are produced for less than a year before they are replaced by
more efficient designs. (Philips, Public Meeting Transcript, No. 7 at
p. 53) Lutron and Cree also commented that it is very important that
the LED lamp test procedure comply with FTC labeling requirements,
which allow for provisional labeling prior to completing all testing.
(Lutron, Public Meeting Transcript, No. 7 at pp. 51-52; Cree, Public
Meeting Transcript, No. 7 at p. 52) Alternatively, GE suggested that
DOE could retain the 21 lamp sample size, remove the requirement to
collect products for testing over the course of a year, and only test
product samples from initial production. (GE, Public Meeting
Transcript, No. 7 at pp. 52-53) Radcliffe Advisors commented that a 21
lamp sample size is small and does not have a rational basis. They
recommended that DOE give consideration to the relationship between
accuracy and the choice of sample size. (Radcliffe Advisors, No. 13 at
p. 1)
In reference to the sampling plan for determining the lifetime of
LED lamps, NEMA agreed with DOE's summary of IES TM-21-2011 stating
that it recommends a minimum of 20 LED sources be used during IES LM-
80-2008 testing to allow for lifetime projections of up to 36,000
hours. IES TM-21-2011 allows fewer LED sources to be used, but reduces
the maximum projection value to 25,000 hours. (NEMA, Public Meeting
Transcript, No. 7 at pp. 113-114) An Anonymous commenter suggested
allowing manufacturers to exclude from the overall average one unit
that fails during lifetime testing. (Anonymous, No. 8 at p. 1)
In this SNOPR, DOE proposes a new test procedure for lifetime that
measures the performance of an LED lamp and not its subcomponents
(i.e., the LED source). Therefore, DOE determined it did not need
different sampling requirements for lifetime relative to the non-
lifetime metrics. These sampling requirements proposed in the SNOPR for
all metrics are described below.
In order to address concerns regarding the sample size requirements
in the NOPR proposal, DOE collected photometric test data from two
sources, the first data set was provided by ENERGY STAR, and the second
from a collaborative effort between PG&E, CLASP, and CLTC (see supra
note 20). These test data, combined, represent 10 samples of 47
different LED lamp products each. Statistical analysis of the LED lamp
test data indicates that a minimum sample size of 10 lamps is
appropriate to estimate the average input power, initial lumen output,
efficacy, CCT, and CRI given the variation present in the data set.
Standby mode power is assumed to vary to the same degree as input power
(active mode). In addition, 37 LED lamps from the data set were tested
for lumen output after 3,000 hours of operation. DOE used this data to
help determine the sample size required for estimating the lifetime of
the LED lamp. Analysis of the test data revealed that a minimum sample
size of 10 should also be sufficient to estimate lumen output for the
LED lamp after an elapsed operating time. In addition, requiring a
minimum sample size of 10 LED lamps aligns with ENERGY STAR's sampling
procedure. Therefore, the SNOPR proposes testing a minimum of 10 LED
lamps to determine the input power, lumen output, efficacy, CCT, CRI,
lifetime, and standby mode power. DOE also proposes that all LED lamps
within the sample, including those that fail prematurely, be included
in the reported results for input power, lumen output, efficacy, CCT,
CRI, lifetime, and standby mode power. DOE's view is that LED lamp
failure should not be exempt from reporting, because this would
potentially mislead consumers, particularly with respect to lamp
lifetime. Furthermore, DOE proposes
[[Page 32037]]
that no selection process be required for the LED lamp test procedure.
Lamps for testing can be selected at any time from production units.
DOE invites interested parties to comment on the appropriateness of
adopting a minimum sample size of 10 LED lamps for input power, lumen
output, efficacy, CCT, CRI, lifetime, and standby mode power.
3. Reported Value
As in the NOPR (77 FR at 21049), DOE proposes that the CCT of the
units be averaged and that average be rounded as specified in section
III.G. The average CCT is calculated using the following equation:
[GRAPHIC] [TIFF OMITTED] TP03JN14.012
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit.
The LED lamp test data provided by ENERGY STAR as well as PG&E,
CLASP, and CLTC (see supra note 20) indicates variability within a
sample for measured lumen output, both at the initial lumen output
reading and after an elapsed operating time. Therefore, DOE proposes
that the reported value of lumen output as well as the reported value
of lifetime be equal to the lower of the average lumen output of the
sample set and the lower 99 percent confidence limit (LCL) of the
sample mean divided by 0.97.\41\ Additionally, the LED lamp test data
indicates that variability in the CRI and efficacy should be expected
within a sample. Therefore, DOE proposes that the reported value of CRI
be equal to the lower of the average CRI of the sample set and the
lower 99 percent confidence limit of the sample mean divided by 0.99,
and that the reported value of efficacy be equal to the lower of the
average efficacy of the sample set and the lower 99 percent confidence
limit of the sample mean divided by 0.98.\42\ DOE proposes the
following equation to calculate LCL for lumen output, lifetime, CRI,
and efficacy:
---------------------------------------------------------------------------
\41\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that the
variability for measured lumen output is within a margin of 3
percent. Thus, DOE proposes to divide the LCL value by 0.97 to
adjust for this expected variation. For example, if the mean lumen
output of 10 LED lamp units is 100 lumens with a standard deviation
of three, the LCL value will be three percent lower than the mean,
and dividing by 0.97 would result in a value that is equal to the
lumen output mean of 100 lumens. In this case, the LCL divided by
0.97 is equal to the sample mean, and 100 lumens would be reported.
If the variation within a sample set exceeds DOE's expectation, the
sample set would have a smaller LCL, such that a value less than 100
lumens would be reported.
\42\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that
variability for CRI is within a margin of 1 percent and for efficacy
is within a margin of 2 percent. Thus, DOE proposes to divide the
LCL value for CRI by 0.99 and the LCL value for efficacy by 0.98 to
adjust for this expected variation.
[GRAPHIC] [TIFF OMITTED] TP03JN14.013
where, x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees of freedom.
Similarly, the LED lamp test data provided by ENERGY STAR as well
as PG&E, CLASP, and CLTC (see supra note 20) indicates variability
within a sample for measured input power. Therefore, DOE proposes that
the reported value of input power and standby mode power be equal to
the greater of the average lumen output of the sample set and the upper
99 percent confidence limit (UCL) of the sample mean divided by
1.01.\43\ DOE proposes the following equation to calculate UCL:
---------------------------------------------------------------------------
\43\ Based on the collected LED lamp test data, provided by
ENERGY STAR as well as PG&E, CLASP, and CLTC, DOE expects that the
variability for measured input power is within a margin of 1
percent. Thus, DOE proposes to divide the UCL value by 1.01 to
adjust for this expected variation.
[GRAPHIC] [TIFF OMITTED] TP03JN14.014
where, x is the sample mean; s is the sample standard deviation; n is
the number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees of freedom.
The proposed reported value requirements for lumen output, input
power, CRI, lamp efficacy, lifetime, and standby mode power represent
the ``best'' value that manufacturers may report. For lumen output,
CRI, lamp efficacy, and lifetime, the reported value may be rounded to
a lower value. For input power and standby mode power, the reported
value may be rounded to higher values. CCT must be reported as
calculated, as the concept of a conservative value does not apply to
these metrics. If conservative rounding is used, manufacturers must
report the conservatively rounded value to DOE so that values reported
to DOE match those used in all representations.
DOE invites interested parties to comment on the proposed reported
value requirements.
G. Rounding Requirements
In the SNOPR, DOE proposes rounding requirements for determining
lumen output, input power, efficacy, CCT, CRI, estimated annual energy
cost, lifetime, and standby mode power. Each of these is discussed in
the following sections.
1. Lumen Output
In the NOPR, DOE proposed that the lumen output of all units be
averaged and the value be rounded to the nearest tens digit. 77 FR at
21044 NEMA, OSI, and Cooper Lighting indicated that tight tolerances on
rounding requirements are undesirable. (NEMA, No. 16 at p. 4; OSI,
Public Meeting Transcript, No. 7 at pp. 55-56; Cooper, Public Meeting
Transcript, No. 7 at p. 56) NEMA commented that this will only set up
unrealistic expectations of accuracy and repeatability. (NEMA, No. 16
at p. 4) In their written comment, NEMA suggested that for lumen output
DOE round values of 0-499 to the nearest five lumens, 500-999 to the
nearest ten lumens, and 1000-9999 lumens to three significant digits.
If the lumen output is greater than or equal to 10,000, NEMA
recommended that DOE round to two significant digits. (NEMA, No. 16 at
p. 4) ASAP offered another solution, suggesting that DOE determine
appropriate rounding requirements based on the resolution of the test
measurement. (ASAP, Public Meeting Transcript, No. 7 at p. 56)
DOE agrees that rounding requirements should reflect realistic
expectations of accuracy and repeatability. Based on a review of
commercially available LED lamp products as well as testing equipment
measurement capabilities, DOE determined that three significant figures
is an achievable level of accuracy for LED lamps. Therefore, for this
SNOPR, DOE proposes rounding of three significant figures \44\ so that
lumen outputs of all sizes are provided a similar level of specificity.
---------------------------------------------------------------------------
\44\ If the number 3,563 is rounded to three significant digits
it becomes 3,560--with the 3, 5, and 6 being the significant digits.
---------------------------------------------------------------------------
2. Input Power
In the NOPR, DOE proposed that the input power of all test units be
averaged and the average value be rounded to the nearest tenths digit.
77 FR at 21044 NEMA agreed that this is acceptable. (NEMA, No. 16 at p.
4) In the SNOPR, DOE maintains its proposal for the rounding
requirements for input power.
[[Page 32038]]
3. Lamp Efficacy
In the SNOPR, DOE proposes that the efficacy of LED lamps be
rounded to the nearest tenth as this is consistent with rounding for
other lighting technologies and is achievable with today's equipment.
4. Correlated Color Temperature
In the NOPR, DOE proposed that the CCT of all units be averaged and
the value be rounded to the tens digit. 77 FR at 21044 However, NEMA
argued that most consumers can only distinguish lamp color temperature
variations on the order of 100 K. Therefore, NEMA suggested that any
CCT rating be rounded to the nearest hundreds digit. They stated that
DOE's proposal of rounding CCT values to the nearest tens digit would
cause undue consumer confusion when comparing products. (NEMA, No. 16
at p. 4)
In rulemakings for other lamp types, DOE established CCT rounding
requirements to the nearest tens place based on the precision of the
test procedure. In a rulemaking for general service fluorescent lamps,
DOE consulted with NIST and concluded that, because all laboratories
are able to measure CCT to three significant figures (a typical value
is four digits), DOE should require manufacturers to round CCT to the
nearest ten kelvin. 74 FR 31829, 31835 (July 6, 2009). In this SNOPR,
DOE continues this requirement and proposes rounding to the nearest
tens digit for measurements of individual lamp units.
However, DOE also recognizes NEMA's comment that consumers may not
be able to distinguish changes in CCT as small as 10 K. By using CCT
values rounded to the nearest 10 K, consumers could be confused, since
products with different CCT values may not have a perceptible
difference in appearance. DOE does not have data or market studies
quantifying the smallest difference in CCT that can be perceived by
consumers, but welcomes comment on this topic. DOE has observed that
the vast majority of CCT values provided in LED product literature are
rounded to the nearest hundreds place. DOE proposes to round the
reported value (i.e., certified or rated value) of the entire sample
(all lamp units collectively) to the nearest hundreds place to avoid
consumer confusion around any representations of CCT. DOE seeks comment
on this proposal.
5. Color Rendering Index
In the SNOPR, DOE proposes that the CRI of LED lamps be rounded to
the nearest whole number as this is consistent with rounding for other
lighting technologies.
6. Annual Energy Cost
Consistent with FTC's final rule that established the Lighting
Facts label (75 FR 41702 (July 19, 2010)), in the NOPR DOE proposed
calculating the estimated annual energy cost for LED lamps, expressed
in dollars per year, as the product of the average input power, in
kilowatts, the electricity cost rate of 11 cents per kilowatt-hour, and
the estimated average annual use at three hours per day, which is 1,095
hours per year. 77 FR at 21044 DOE proposed that the estimated annual
energy cost be rounded to the nearest cent because the cost of
electricity is specified to the nearest cent.
Although NEMA pointed out that the usage patterns and associated
hours used in the NOPR do not agree with DOE's 2010 U.S. Lighting
Market Characterization,\45\ NEMA agreed with DOE's proposed formula to
calculate annual energy cost and the associated rounding to the nearest
cent. (NEMA, No. 16 at p. 4) For consistency with FTC's calculations
for other lamp types, DOE proposes to maintain the rounding
requirements for estimated annual energy cost.
---------------------------------------------------------------------------
\45\ Navigant Consulting, Inc., ``2010 U.S. Lighting Market
Characterization'' Prepared for the DOE Solid-State Lighting
Program, January, 2012. http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
---------------------------------------------------------------------------
7. Lifetime
In the SNOPR, DOE proposes that lifetime be rounded to the nearest
whole hour. This is consistent with the unit of time used for lifetime
metrics for other lamp technologies and is a level of accuracy a
laboratory is capable of measuring with a standard time-keeping device.
8. Life
In the NOPR, DOE proposed that the life of LED lamps be calculated
in terms of years based on three hours per day of operation. 77 FR at
21048 This is consistent with the FTC Lighting Facts label requirements
for other lamp technologies. DOE also proposed that the resulting value
be rounded to the nearest tenth of a year. Cooper Lighting recommended
that DOE consider rounding to two significant digits rather than to
tenths of a year to better capture the range in product lifetimes
across the different lighting technologies. (Cooper, Public Meeting
Transcript, No. 7 at p. 109) NEMA stated that tight rounding tolerances
only set up unrealistic expectations for the performance of LED lamps
and indicated that rounding the lifetime to the nearest tenth of a year
can be confusing to customers if they do not realize that the lifetime
values are based on three hours of use per day. (NEMA, No. 16 at p. 4,
8) Furthermore, both NEMA and the CA IOUs argued that lifetime be
reported in hours, because year-ratings are confusing to consumers, who
might assume a calendar lifetime rather than a lifetime based on hourly
use. (NEMA, No. 16 at p. 8; CA IOUs, No. 19 at p. 4) DOE proposes to
retain the rounding requirements provided in the NOPR which states that
the life of LED lamps be calculated in terms of years based on three
hours per day of operation and that the resulting value be rounded to
the nearest tenth of a year. As stated previously, this is consistent
with the FTC Lighting Facts label requirements for other lamp
technologies. FTC determines how the prescribed metrics appear on its
Lighting Facts label, as well as the overall format of the label.
Interested parties may contact FTC for concerns regarding the Lighting
Facts label.
9. Standby Mode Power
In the SNOPR, DOE proposes rounding standby mode power to the
nearest tenths place, consistent with its proposal for rounding input
power for active mode in section III.G.2.
H. Acceptable Methods for Initial Certification or Labeling
Because testing for lifetime could require six months or more from
start to finish, DOE anticipates the potential need for initial
certification requirements (such as those currently provided in 10 CFR
429.12(e)(2)) or early or interim labeling requirements. Any initial
certification requirements, if adopted, would be established by the
ongoing general service lamp energy conservation standard rulemaking.
See 78 FR 73737 (Dec. 9, 2013) Early labeling requirements, if adopted,
would be established by FTC. However, to support these potential needs,
DOE considered acceptable methods for use with initial certification or
labeling.
Test methods with shorter overall start to finish time requirements
are not available for measuring or projecting lifetime. Therefore,
initial certification and labeling is best substantiated by comparisons
to similarly designed lamps produced by the same manufacturer. A future
rulemaking addressing standards for LED lamps could require
manufacturers to provide a description of why the comparison to another
lamp is valid, including a description of the expected impact of design
differences on lifetime (if any).
[[Page 32039]]
DOE requests comment on the notion of early certification and labeling,
and the acceptable methods for substantiating those claims.
I. Laboratory Accreditation
In the NOPR, DOE did not require testing LED lamps by an accredited
laboratory. DOE received several comments during the May 2012 public
meeting as well as written comment submissions inquiring whether DOE
plans to require using accredited laboratory facilities.
Cree commented that DOE should consider requiring certification of
laboratories that are performing these tests as this is a requirement
for the ENERGY STAR program. (Cree, Public Meeting Transcript, No. 7 at
p. 57) OSI clarified that DOE should consider laboratory accreditation,
and not a certification program. Accreditation is the process by which
an authoritative third party gives formal recognition that a body or
person is competent to carry out specific testing. Certification is a
procedure by which a third party gives written assurance (certificate
of conformity) that a product, process, or service conforms to
specified requirements. (OSI, Public Meeting Transcript, No. 7 at pp.
60-61) NIST commented that laboratories are accredited for industry
standards. If testing in accredited laboratories is required for the
DOE's LED test procedure, this could confuse clients expecting industry
standards to be followed without modification. (NIST, Public Meeting
Transcript, No. 7 at p. 104) South Korea requested that in the final
rule DOE detail its certification procedures, its requirements for
testing laboratories, its designation process for testing laboratories,
and future prospects concerning these matters. (South Korea, No. 17 at
p. 4) Finally, Samsung suggested that DOE accept testing by existing
laboratories that have received accreditation from the International
Laboratory Accreditation Cooperation (ILAC). They argued that the ILAC
promotes international acceptance of test results and inspection
reports. (Samsung, No. 14 at p. 2)
Regarding the National Voluntary Laboratory Accreditation Program
(NVLAP) accreditation, DOE proposes in the SNOPR to require lumen
output, input power, lamp efficacy, CCT, CRI, lifetime, and standby
mode power (if applicable) testing be conducted by test laboratories
accredited by NVLAP or an accrediting organization recognized by ILAC.
NVLAP is a member of the ILAC organization, so test data collected by
any laboratory accredited by an accrediting body recognized by ILAC
would be acceptable. DOE requests comment on its proposal to require
accreditation by NVLAP or an entity recognized by ILAC, and on the
costs and benefits associated with such a requirement.
The FTC has developed a Lighting Facts Label to help inform
consumers about the efficiency and performance attributes of general
service lamp products. The label became effective January 1, 2012, and
requires that a lamp's lumen output, energy cost, lifetime, CCT and
wattage appear on the product packaging. Concerns regarding the FTC
Lighting Facts Label requirements were raised at the May 2012 NOPR
public meeting and in several comment submissions. These comments
pertained to the physical appearance and content displayed on the FTC
Lighting Facts Label, the time it would take for FTC to certify LED
lamp testing results, and whether using lumen maintenance as a proxy
for lifetime could confuse or mislead consumers. The comments received
are highlighted below:
OSI commented that FTC needs to take into account that
product information on small packages is often printed too small,
making the information illegible and/or difficult to identify. (OSI,
Public Meeting Transcript, No. 7 at p. 81)
An Anonymous commenter asked for DOE to indicate how long
it would take FTC to certify the results and grant permission to
advertise the lifetime values required for the FTC Lighting Facts
label. (Anonymous, No. 8 at p. 1)
NEMA, Radcliffe Advisors, OSI, Cooper Lighting, NEEA, the
Joint Comment, and the CA IOUs commented that the proposed definition
of lifetime would not be directly comparable to other general service
lamp products, which could mislead or confuse consumers. (NEMA, Public
Meeting Transcript, No. 7 at pp. 76-77; NEMA, No. 16 at p. 2; Radcliffe
Advisors, No. 13 at p. 1; OSI, Public Meeting Transcript, No. 7 at pp.
74-75; Cooper Lighting, Public Meeting Transcript, No. 7 at p. 77;
NEEA, No. 20 at p. 2; Joint Comment, No. 18 at pp. 1-2; CA IOUs, No. 19
at p. 4) Cree, Radcliffe Advisors, and the CA IOUs recommend that for
LED lamps, FTC consider changing its label to ``lumen maintenance''
rather than ``lifetime,'' or not provide a lifetime value at all.
(Cree, Public Meeting Transcript, No. 7 at p. 66, 67; Radcliffe
Advisors, No. 13 at p. 1; CA IOUs, No. 19 at p. 4, 5) OSI pointed out
that the FTC Lighting Facts label provides the opportunity to educate
consumers on the meaning of lumen maintenance and how this differs from
metrics used to define lifetime for other lighting products. (OSI,
Public Meeting Transcript, No. 7 at pp. 74-75)
DOE recognizes these concerns about the FTC Lighting Facts label.
However, DOE does not have authority over how to display metrics on the
FTC Lighting Facts label or the format of the label. Interested parties
may contact FTC about these issues.
J. State Preemption for Efficiency Metrics
In the NOPR, DOE proposed test procedures for measuring lumen
output and input power, and also specified testing dimmable lamps at
full light output. 77 FR 21028 (April 9, 2012) Only those metrics
required for the FTC Lighting Facts label were included in the NOPR
test procedure. The FTC Lighting Facts label does not require reporting
of metrics such as power factor, total harmonic distortion (THD), and
dimming; therefore none were included in the NOPR test procedure for
LED lamps. However, commenters noted that these metrics may appear in
state mandates in the future, and therefore recommended they be
included in DOE's test procedure for LED lamps in order to avoid state
preemption.
The CA IOUs commented that DOE not preempt California from
developing test procedures for other performance metrics such as
efficacy, power factor, THD, and dimming. The CA IOUs commented that
including in DOE's proposal test methods for power factor, THD, and
dimming would likely require significant additional time and industry
coordination. They asked that DOE specifically identify these metrics
and procedures as exempt from preemption. (CA IOUs, No. 19 at p. 2, 3)
Representations about the energy consumption of an LED lamp must
fairly disclose the results of testing in accordance with the DOE test
procedure. See 42 U.S.C. 6293(c). The DOE test procedure for LED lamps
will preempt any state regulation regarding the testing of the energy
efficiency of LED lamps. See 42 U.S.C. 6297(a)(1). States that have
regulations mandating efficiency standards for LED lamps must therefore
use the DOE test procedure when providing for the disclosure of
information with respect to any measure of LED lamp energy consumption.
To support the general service lamp rulemaking, DOE proposes to define
a calculation for the efficacy of an LED lamp as measured initial lamp
lumen output in lumens divided by measured lamp input power in watts.
See section III.C.4.d for details regarding the calculation for
efficacy of an LED lamp.
[[Page 32040]]
K. Effective and Compliance Date
If adopted, the effective date for this test procedure would be 30
days after publication of the test procedure final rule in the Federal
Register. Pursuant to EPCA, manufacturers of covered products must use
the applicable test procedure as the basis for determining that their
products comply with the applicable energy conservation standards
adopted pursuant to EPCA and for making representations about the
efficiency of those products. (42 U.S.C. 6293(c); 42 U.S.C. 6295(s))
For those energy efficiency or consumption metrics covered by the DOE
test procedures, manufacturers must make representations in accordance
with the DOE test procedure methodology and sampling plan beginning 180
days after publication of the final rule in the Federal Register.
IV. Procedural Issues and Regulatory Review
A. Review Under Executive Order 12866
The Office of Management and Budget (OMB) has determined that test
procedure rulemakings do not constitute ``significant regulatory
actions'' under section 3(f) of Executive Order 12866, Regulatory
Planning and Review, 58 FR 51735 (Oct. 4, 1993). Accordingly, this
action was not subject to review under the Executive Order by the
Office of Information and Regulatory Affairs (OIRA) in the Office of
Management and Budget.
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 DOE rulemaking process. 68 FR 7990. DOE has made
its procedures and policies available on the Office of the General
Counsel's Web site: http://energy.gov/gc/office-general-counsel.
DOE reviewed the test procedures considered in this SNOPR under the
provisions of the Regulatory Flexibility Act (RFA) and the policies and
procedures published on February 19, 2003. As discussed in more detail
below, DOE found that because the proposed test procedures have not
previously been required of manufacturers, all manufacturers, including
small manufacturers, may potentially experience a financial burden
associated with this new testing requirement. While examining this
issue, DOE determined that it could not certify that the proposed rule,
if promulgated, would not have a significant impact on a substantial
number of small entities. Therefore, DOE has prepared an IRFA for this
rulemaking. The IRFA describes the potential impacts on small
businesses associated with LED lamp testing and labeling requirements.
DOE has transmitted a copy of this IRFA to the Chief Counsel for
Advocacy of the Small Business Administration (SBA) for review.
1. Estimated Small Business Burden
SBA has set a size threshold for electric lamp manufacturers to
describe those entities that are classified as ``small businesses'' for
the purposes of the RFA. DOE used the SBA's small business size
standards to determine whether any small manufacturers of LED lamps
would be subject to the requirements of the rule. 65 FR 30836, 30849
(May 15, 2000), as amended at 65 FR 53533, 53545 (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 and are available at www.sba.gov/sites/default/files/Size_Standards_Table.pdf. LED lamp manufacturing is classified under NAICS
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.
In the NOPR, DOE identified 17 potential small businesses that
manufacture LED lamps. In total, DOE estimated that the use of the NOPR
test method for determining light output, input power, and CCT would
result in testing-related labor costs of $57,000 for each of the
identified small businesses. In addition, DOE estimated that the test
method described in the NOPR for determining lifetime would result in
related labor costs of $11,000 for each manufacturer. Finally, in the
NOPR, DOE estimated initial setup costs of $12,000. DOE also indicated
that the setup cost would be a one-time cost to manufacturers and that
the labor costs to perform testing would be smaller than $68,000 after
the first year of testing. 77 FR at 21050-1 (April 9, 2012)
OSI indicated that they believe the number of impacted small
businesses is greater than DOE's estimate of 17 and speculated that the
actual number could be between two and ten times greater. (OSI, Public
Meeting Transcript, No. 7 at pp. 117-118) NEMA suggested that DOE
contact Jim Brodrick, Program Manager of the U.S. DOE SSL program, to
help determine a better estimate for the total number of small
businesses that will likely be affected by implementing this test
procedure. (NEMA, Public Meeting Transcript, No. 7 at p. 119)
For this SNOPR, DOE reexamined the number of small businesses that
will potentially be affected by the LED lamps test procedure. This
reevaluation indicated that the test procedure requirements proposed in
this SNOPR will apply to about 41 small business manufacturers of LED
lamps. DOE compiled this revised list of manufacturers by reviewing the
DOE LED Lighting Facts label list of partner manufacturers,\46\ the SBA
database, ENERGY STAR's list of qualified products,\47\ and performing
a general search for LED manufacturers. DOE determined which companies
manufacture LED lamps by reviewing company Web sites, the SBA Web site
when applicable, calling companies directly, and/or reviewing the
Hoovers Inc. company profile database. Through this revised process,
DOE identified 41 small businesses that manufacture LED lamps. DOE was
also able to collect annual revenue estimates for several of the small
business LED lamp manufacturers using the Hoovers.com company profile
database. DOE determined that the median revenue of the identified
small business manufacturers is $890,000.\48\ DOE requests comment on
the estimated number of small businesses that would be impacted by the
proposed rulemaking.
---------------------------------------------------------------------------
\46\ DOE LED Lighting Facts Partner List, http://www.lightingfacts.com/Partners/Manufacturer.
\47\ ENERGY STAR Qualified Lamps Product List, http://downloads.energystar.gov/bi/qplist/Lamps_Qualified_Product_List.xls?dee3-e997.
\48\ According to Hoovers.com, there are some small business LED
lamp manufacturers with revenue as little as $120,000 per year.
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DOE also received several comments about the estimate of testing
burden. GE, Feit, and OSI expressed concern that DOE was
underestimating the cost burden to small manufacturers because the
costs associated with NOPR Approach 4 for lifetime testing would be
significant if IES LM-80-2008 data were unavailable. (GE, Public
Meeting Transcript, No. 7 at p. 117; Feit, Public Meeting Transcript,
No. 7 at p. 120; OSI,
[[Page 32041]]
Public Meeting Transcript, No. 7 at p. 117) ICF International commented
that DOE's estimate for the cost of initial setup was low. ICF
International estimated that if a manufacturer were to purchase all
required testing equipment, train personnel to operate it, and then go
through the accreditation process, it could cost more than $100,000.
(ICF International, Public Meeting Transcript, No. 7 at p. 119, 120)
Cree and Intertek also commented that instrumentation costs could be
significant, pointing out that a Type C goniophotometer could cost as
much as $200,000 and that a two meter integrating sphere with
accessories could cost about $60,000. (Cree, Public Meeting Transcript,
No. 7 at p. 120; Intertek, Public Meeting Transcript, No. 7 at pp. 121-
122) In addition to instrumentation costs, an anonymous commenter also
indicated that the cost of storing inventory during lifetime testing
would be significant and should be included in the cost burden
estimate. (Anonymous, No. 8 at p. 1) When estimating the burden to
small manufacturers, NEMA suggested that DOE also include FICA taxes,
unemployment taxes, workman's compensation, health care insurance,
holiday and vacation time, and retirement benefits in addition to the
office, laboratory, equipment, and other overhead costs for the
engineers and their support staff. (NEMA, No. 16 at p. 8) Finally, GE
commented that it would be unlikely that small business manufacturers
would want to set up an accredited laboratory for testing. They
speculated that small manufacturers would likely send their LED lamps
out for third party testing. (GE, Public Meeting Transcript, No. 7 at
p. 115)
In the NOPR, DOE determined that the labor rate to create the
initial setup and conduct the testing for input power, lumen output,
CCT, and lifetime of LED lamps would be $39.79 per hour.\49\ 77 FR at
21050 However, in its analysis for the SNOPR, DOE determined that an
electrical engineer is likely over qualified, and would not be hired by
manufacturers to conduct these required tasks. DOE's view is that an
electrical engineering technician is a better representation of the
personnel likely to perform the initial setup and required tests for
LED lamps. DOE estimated that the wages for an electrical engineering
technician are $24.18 per hour.\49\ This cost is only representative of
the hourly billing rate for an electrical engineering technician and
does not include any other compensation costs. DOE estimated that
providing additional benefits \50\ would add 31 percent \51\ to the
overall cost to the manufacturer, increasing the cost of employing an
electrical engineering technician to $31.68 per hour. For the SNOPR,
DOE also applied this labor rate to measurement of standby mode power.
---------------------------------------------------------------------------
\49\ Obtained from the Bureau of Labor Statistics (National
Compensation Survey: Occupational Earnings in the United States
2008, U.S. Department of Labor (August 2009), Bulletin 2720, Table 3
(``Full-time civilian workers,'' mean and median hourly wages)
http://bls.gov/ncs/ocs/sp/nctb0717.pdf.
\50\ Additional benefits include; paid leave, supplemental pay,
insurance, retirement and savings, Social Security, Medicare,
unemployment insurance and workers compensation.
\51\ Obtained from the Bureau of Labor Statistics (News Release:
Employer Cost For Employee Compensation--December 2012, U.S.
Department of Labor (December 2012), www.bls.gov/news.release/ecec.nr0.htm.
---------------------------------------------------------------------------
DOE estimates that the labor costs associated with conducting the
input power, lumen output, CCT, CRI, and standby mode power testing
contribute to overall burden. However, DOE believes that calculating
the efficacy of an LED lamp does not result in any incremental testing
burden beyond the cost of carrying out lumen output and input power
testing. DOE estimates that testing for input power, lumen output, CCT,
CRI, and standby mode would require approximately four hours per lamp
by an electrical engineering technician. DOE expects standby mode power
testing to require a negligible incremental amount of time in addition
to the time required for the other metrics. Therefore, DOE maintained
its estimate of four hours per lamp used in the NOPR (77 FR at 21050)
for testing for input power, lumen output, CCT, and CRI. DOE estimates
about 41 small business manufacturers of LEDs would be impacted, each
offering about 23 different basic models. In total, using the DOE test
method to determine light output, input power, CCT, CRI, and standby
mode power would result in an estimated incremental labor burden of
$29,140 for each manufacturer. DOE expects that the majority of
manufacturers are already testing for lumen output, input power, CCT,
and CRI as these metrics are well established and required within the
industry standard IES LM-79-2008. However, DOE's sample size, input
power, and orientation settings may differ from those selected for a
manufacturer's existing data. Therefore, DOE included the cost of
carrying out these tests in its assessment of testing burden.
In addition, DOE estimates that lifetime testing would also
contribute to overall cost burden. The initial setup would require a
custom-built rack to mount up to 120 lamps for testing, which may
require up to 120 hours of labor to build. The cost for an electrical
engineering technician to build such a rack would be approximately
$3,800. Similar to the NOPR analysis, DOE estimated that the material
cost to build a custom-built rack holding 120 sockets would be $3,600,
and the power supply and regulator costs would be $4,000 and $1,500
respectively. Therefore, the revised SNOPR estimate for the total cost
to build one rack is approximately $12,900. DOE estimated that a total
of two racks would be needed to hold about 23 different LED lamp
models, each tested in sample sets of 10 lamps (a total of 230 LED
lamps). Therefore, DOE estimates the total cost to build two test racks
to be $25,800. However, DOE notes that LED lamp manufacturers may
already have sufficient testing racks for their own internal uses and
for FTC labeling requirement testing. DOE expects that manufacturers of
LED lamps would already have other instrumentation necessary for
testing because IES LM-79-2008 is the recommended standard for testing
LED lamps for the FTC Lighting Facts label. The labor cost for lifetime
testing also contributes to overall burden. DOE estimates that the
combination of monitoring the lamps during the test duration, measuring
lumen maintenance, and calculating lifetime at the end of the test
duration would require approximately four hours per lamp by an
electrical engineering technician. This estimate does not include the
initial lumen output measurement required for the lifetime test
procedure, because the testing burden for that measurement is already
included in the estimate for input power, lumen output, CCT, and CRI
testing. DOE estimates about 41 small business manufacturers of LEDs,
each offering about 23 different basic models, would be affected. In
total, DOE expects that using this test method to determine lifetime
would result in testing-related labor costs of $29,140 for each
manufacturer.
As discussed in section III.I, DOE is also proposing to require
test facilities conducting LED lamp light output, input power, CCT,
CRI, lifetime, and standby mode power (if applicable) testing to be
NVLAP-accredited or accredited by an organization recognized by NVLAP.
However, NVLAP imposes a variety of fees during the accreditation
process including fixed administrative fees, variable assessment fees,
and proficiency testing fees. If a laboratory already has NVLAP
accreditation for other industry standards, there would be no
[[Page 32042]]
incremental administrative fees associated with the SNOPR proposal.
However, if a laboratory does not already have NVLAP accreditation for
other industry standards, there would be an administrative fee of
$5,050 assessed annually. NVLAP also collects an assessment fee
corresponding to the amount of time the assessor requires to complete
evaluation of the laboratory. A laboratory seeking to expand its scope
of accreditation to include IES LM-79-2008 as well as DOE's lifetime
test procedure for LED lamps would most likely not experience an
increase in cost. However, a laboratory with no existing NVLAP
accreditations would likely require two full days of an assessor's time
at the cost of $7,470 per assessment. Assessments are required during
the initial accreditation, on the first anniversary (year 1), and then
every other year following the first anniversary (year 3, 5, 7, etc.).
Finally, every laboratory seeking accreditation to IES LM-79-2008 is
required to participate in SSL proficiency testing. A $2,800 fee is
involved with this proficiency testing.
For each manufacturer producing 23 basic models, assuming testing
instrumentation is already available, DOE's estimate of the first year
NVLAP accreditation cost would be $15,320, initial setup cost would be
$25,800, and the labor costs to carry out testing would be
approximately $58,280. Therefore, in the first year, for manufacturers
without testing racks or NVLAP accreditation who choose to test in-
house, DOE estimates a total cost burden of $99,400 or about $432 per
LED lamp tested. DOE expects the setup cost to be a onetime cost to
manufacturers. Further, DOE expects that the labor costs to perform
testing would be smaller than $58,280 after the first year because only
new products or redesigned products would need to be tested.
Alternatively, if a manufacturer opts to send lamps to a third-party
test facility, DOE estimates testing of lumen output, input power, CCT,
CRI, lifetime, and standby mode power to cost $500 per lamp. In total,
the LED lamp test procedure would result in expected third party
testing costs of $115,000 for each manufacturer of 23 basic models.
DOE was able to collect annual revenue estimates for several of the
small business LED lamp manufacturers using the Hoovers.com company
profile database. DOE determined that the median revenue of the
identified small business manufacturers is $890,000, therefore, initial
testing costs would represent about 11.2 percent of revenue when
completed in a manufacturer's own laboratory, and 12.9 percent when
completed through a third-party test facility. As mentioned earlier,
the setup cost would be a one-time cost to manufacturers, and the labor
costs to perform testing would be smaller after the first year of
testing. Furthermore, when amortized over subsequent years, testing
costs would be significantly less. DOE requests comments on its
analysis of initial setup and labor costs as well as the average annual
burden for conducting testing of LED lamps.
2. 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 proposed rule being considered today.
3. Significant Alternatives to the Proposed Rule
DOE tentatively determined that there are no alternatives to the
proposed test procedure, including test procedures that incorporate
industry test standards other than the proposed standards. IES LM-79-
2008, the test procedure referenced in this SNOPR, is the most commonly
used industry standard that provides instructions for the electrical
and photometric measurement of LED lamps. DOE also reviewed the efforts
of other working groups, as suggested by interested parties, but was
unable to find any U.S. or international standard that provides a test
procedure for measuring and/or projecting LED lamp lifetime. The only
publicly available approach for measuring LED lamp lifetime is the
ENERGY STAR Program Requirements for Lamps (Light Bulbs): Eligibility
Criteria--Version 1.0 (see supra note 10).
C. Review Under the Paperwork Reduction Act of 1995
DOE established regulations for the certification and recordkeeping
requirements for certain covered consumer products and commercial
equipment. 76 FR 12422 (March 7, 2011). The collection-of-information
requirement for the certification and recordkeeping was subject to
review and approval by OMB under the Paperwork Reduction Act (PRA).
This requirement was approved by OMB under OMB Control Number 1910-
1400. Public reporting burden for the certification was 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.
There is currently no information collection requirement related to
certifying compliance for LED lamps. Notwithstanding any other
provision of the law, no person is required to respond to, nor must 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
In this proposed rule, DOE is proposing a test procedure for LED
lamps that will be used to support the upcoming general service lamps
energy conservation standard rulemaking as well as FTC's Lighting Facts
labeling program. DOE has determined that this rule falls into a class
of actions that are categorically excluded from review under the
National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.) and
DOE's implementing regulations at 10 CFR part 1021. Specifically, this
proposed rule would adopt existing industry test procedures for LED
lamps, so it would not affect the amount, quality or distribution of
energy usage, and, therefore, would not result in any environmental
impacts. Thus, this rulemaking is covered by Categorical Exclusion A5
under 10 CFR part 1021, subpart D. Accordingly, neither an
environmental assessment nor an environmental impact statement is
required.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism,'' 64 FR 43255 (August 4, 1999)
imposes certain requirements on 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. DOE has examined this proposed rule and has
determined that it would not have a substantial direct effect on the
States, on the relationship between the national government and the
States, or on the distribution of power and responsibilities among the
various
[[Page 32043]]
levels of government. EPCA governs and prescribes Federal preemption of
State regulations as to energy conservation for the products that are
the subject of this 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(d)) No further action is required by
Executive Order 13132.
F. Review Under Executive Order 12988
Regarding the review of existing regulations and the promulgation
of new regulations, section 3(a) of Executive Order 12988, ``Civil
Justice Reform,'' 61 FR 4729 (Feb. 7, 1996), 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; (3) provide a clear legal standard for affected
conduct rather than a general standard; and (4) promote simplification
and burden reduction. 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
sections 3(a) and 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,
the 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; also available
at http://energy.gov/gc/office-general-counsel. DOE examined this
proposed rule according to UMRA and its statement of policy and
determined that the rule contains neither an intergovernmental mandate,
nor a mandate that may result in the expenditure of $100 million or
more in any year, so these requirements do not apply.
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 (March 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 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 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 this proposed rule 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 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 promulgated 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.
This proposed regulatory action to establish a test procedure for
measuring the lumen output, input power, efficacy, CCT, CRI, lifetime,
and standby mode power of LED lamps is not a significant regulatory
action under Executive Order 12866. Moreover, it would not have a
significant adverse effect on the supply, distribution, or use of
energy, nor has it been designated as a significant energy action by
the Administrator of OIRA. Therefore, it is not a significant energy
action, and, accordingly, DOE has not prepared a Statement of Energy
Effects.
L. Review Under Section 32 of the Federal Energy Administration Act of
1974
Under section 301 of the Department of Energy Organization Act
(Pub. L. 95-91; 42 U.S.C. 7101), DOE must comply with section 32 of the
Federal Energy Administration Act of 1974, as amended by the Federal
Energy Administration Authorization Act of 1977. (15 U.S.C. 788; FEAA)
Section 32 essentially provides in relevant part that, where a proposed
rule authorizes or requires use of commercial standards, the notice of
proposed rulemaking must inform the public of the use and background of
such standards. In addition, section 32(c) requires DOE to consult with
the
[[Page 32044]]
Attorney General and the Chairman of the FTC concerning the impact of
the commercial or industry standards on competition.
The proposed rule incorporates test methods contained in the
following commercial standards: ANSI/IESNA RP-16-2010 ``Nomenclature
and Definitions for Illuminating Engineering'' and IES LM-79-2008
``Approved Method: Electrical and Photometric Measurements of Solid-
State Lighting Products.'' The Department has evaluated these standards
and is unable to conclude whether they fully comply with the
requirements of section 32(b) of the FEAA, (i.e., that they were
developed in a manner that fully provides for public participation,
comment, and review). DOE will consult with the Attorney General and
the Chairman of the FTC concerning the impact of these test procedures
on competition prior to prescribing a final rule.
V. Public Participation
A. Submission of Comments
DOE will accept comments, data, and information regarding this
proposed rule no later than the date provided in the DATES section at
the beginning of this proposed rule. Interested parties may submit
comments 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 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. 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.
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, 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 on 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, 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 written in English, free of any defects or viruses, and not
secured. 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 two well-marked copies: one copy
of the document 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).
B. 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 its characterization of the modes of
operation (active, standby, and off modes) that apply to LED lamps.
2. DOE requests comment on the proposal for an equal number of
lamps to be operated in the base-up and base-down orientations during
lumen output, input power, CCT, CRI, lifetime, and standby mode
testing.
3. DOE invites interested parties to comment on the proposal to
require all photometric values, including lumen output, CCT, and CRI,
be measured by an integrating sphere (via photometer or
spectroradiometer) and that goniometer systems must not be used.
[[Page 32045]]
4. DOE invites interested parties to comment on the proposal to
remain consistent with section 4.0 of IES LM-79-2008, which indicates
no seasoning is required for LED lamps before beginning photometric
measurements.
5. DOE requests comments on the test conditions when lamps are
operating but no measurements are being taken. Specifically, DOE
requests comment on requiring ambient temperature to be controlled
between 15 [deg]C and 40 [deg]C; the minimization of vibration, shock,
and air movement, as well as the requirement for adequate lamp spacing;
the proposal to adopt the section 3.1 of IES LM-79-2008 requirements
for both AC and DC power supplies; and the requirement that input
voltage be monitored and regulated to within 2.0 percent of
the rated RMS voltage as specified in section 5.3 of IES LM-65-2010.
6. DOE requests comment on the proposed test method for CRI.
7. DOE requests comment on the proposed calculation for lamp
efficacy.
8. For lifetime testing, DOE proposes to continuously operate the
LED lamp and requests feedback on the appropriateness of not requiring
an operating cycle during lumen maintenance testing.
9. DOE requests comment on the proposed equation to project the
L70 lifetime of LED lamps.
10. DOE requests comment on the revision to the definition of
``basic model'' to address LED lamps.
11. DOE requests comment on the appropriateness of adopting a
minimum sample size of 10 LED lamps for input power, lumen output, CCT,
CRI, lifetime, and standby mode.
12. DOE requests comment on the proposal to allow measurements
collected for the ENERGY STAR Program Requirements for Lamps (Light
Bulbs): Eligibility Criteria--Version 1.0 to be used for calculating
reported values of lumen output, input power, lamp efficacy, CCT, CRI,
and lifetime.
13. DOE requests comment on the proposal to round CCT values for
individual units to the tens place; and the proposal to round the
certified CCT values for the sample to the hundreds place.
14. DOE requests comment on its proposal to require accreditation
by NVLAP or an entity recognized by ILAC, and on the costs and benefits
associated with laboratory accreditation.
15. DOE requests comment on the estimated number of entities that
would be affected by the proposed rulemaking and the number of these
companies that are ``small businesses.''
16. DOE requests comments on its analysis of initial setup and
labor costs as well as the average annual burden for conducting testing
of LED lamps.
VI. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of this proposed
rule.
List of Subjects
10 CFR Part 429
Confidential business information, Energy conservation, Household
appliances, Imports, Reporting and recordkeeping requirements.
10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Incorporation by reference, Intergovernmental relations, Small
businesses.
Issued in Washington, DC, on May 16, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
For the reasons stated in the preamble, DOE is proposing to amend
parts 429 and 430 of Chapter II of Title 10, Subchapter D of the Code
of Federal Regulations to read as set forth below:
PART 429--CERTIFICATION, COMPLIANCE, AND ENFORCEMENT FOR CONSUMER
PRODUCTS AND COMMERCIAL AND INDUSTRIAL EQUIPMENT
0
1. The authority citation for part 429 continues to read as follows:
Authority: 42 U.S.C. 6291-6317.
Sec. 429.12 [Amended]
0
2. Section 429.12(b)(13) is amended by removing ``429.54'' and adding
``429.69'' in its place.
0
3. Section 429.56 is added to read as follows:
Sec. 429.56 Integrated light-emitting diode lamps.
(a) Determination of Represented Value. (1) Manufacturers must
determine the represented value, which includes the certified rating,
for each basic model of integrated light-emitting diode lamps by
testing, in conjunction with the following sampling provisions:
(i) Units to be tested. (A) The general requirements of Sec.
429.11(a) are applicable except that the sample must be comprised of
production units; and
(B) For each basic model of integrated light-emitting diode lamp,
the minimum number of units tested shall be no less than 10 and the
same units must be used for testing all metrics. If more than 10 units
are tested as part of the sample, the total number of units must be a
multiple of two. For each basic model, a sample of sufficient size
shall be randomly selected and tested to ensure that:
(1) Represented values of initial lumen output, lifetime, lamp
efficacy, and color rendering index (CRI) of a basic model for which
consumers would favor higher values must be less than or equal to the
lower of:
(i) The mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.015
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit;
Or,
(ii) The lower 99 percent confidence limit (LCL) of the true mean
divided by 0.97 for initial lumen output, life, and lifetime; the lower
99 percent confidence limit (LCL) of the true mean divided by 0.98 for
lamp efficacy; and the lower 99 percent confidence limit (LCL) of the
true mean divided by 0.99 for CRI, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.016
and, x is the sample mean; s is the sample standard deviation; n is the
number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n -1 degrees of freedom
(from Appendix A of this part).
(2) Represented values of input power and standby mode power of a
basic model for which consumers would favor lower values must be
greater than or equal to the higher of:
(i) The mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.017
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit;
Or,
(ii) The upper 99 percent confidence limit (UCL) of the true mean
divided by 1.01, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.018
and, x is the sample mean; s is the sample standard deviation; n is the
number of samples; and t0.99 is the t statistic for a 99
percent one-tailed confidence interval with n - 1 degrees
[[Page 32046]]
of freedom (from Appendix A of this part);
(3) Represented values of correlated color temperature (CCT) of a
basic model must be equal to the mean of the sample, where:
[GRAPHIC] [TIFF OMITTED] TP03JN14.019
and, x is the sample mean; n is the number of units; and xi
is the i\th\ unit.
(ii) [Reserved]
(2) [Reserved]
(b) [Reserved]
(c) Rounding requirements for representative values, including
certified and rated values, of lumen output, input power, efficacy,
CCT, CRI, lifetime, standby mode power, and estimated annual energy
cost. (1) The represented value of input power must be rounded to the
nearest tenth of a watt.
(2) The represented value of lumen output must be rounded to three
significant digits.
(3) The represented value of lamp efficacy must be rounded to the
nearest tenths place.
(4) The represented value of correlated color temperature must be
rounded to the nearest 100 Kelvin.
(5) The represented value of color rendering index must be rounded
to the nearest whole number.
(6) The represented value of lifetime must be rounded to the
nearest whole hour.
(7) The represented value of standby mode power must be rounded to
the nearest tenth of a watt.
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
4. 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
5. Section 430.2 is amended by revising the definition of ``Basic
model'' and adding in alphabetical order the definition of ``Integrated
light-emitting diode lamp'' to read as follows:
Sec. 430.2 Definitions.
* * * * *
Basic model means all units of a given type of covered product (or
class thereof) manufactured by one manufacturer, having the same
primary energy source, and which have essentially identical electrical,
physical, and functional (or hydraulic) characteristics that affect
energy consumption, energy efficiency, water consumption, or water
efficiency; and
(1) With respect to general service fluorescent lamps, general
service incandescent lamps, and incandescent reflector lamps: Lamps
that have essentially identical light output and electrical
characteristics--including lumens per watt (lm/W) and color rendering
index (CRI).
(2) With respect to integrated light-emitting diode lamps: Lamps
that have essentially identical light output and electrical
characteristics--including lumens per watt (lm/W), color rendering
index (CRI), correlated color temperature (CCT), and lifetime.
(3) With respect to faucets and showerheads: Have the identical
flow control mechanism attached to or installed within the fixture
fittings, or the identical water-passage design features that use the
same path of water in the highest flow mode.
(4) With respect to furnace fans: Are marketed and/or designed to
be installed in the same type of installation.
* * * * *
Integrated light-emitting diode lamp means an integrated LED lamp
as defined in ANSI/IESNA RP-16 (incorporated by reference; see Sec.
430.3).
* * * * *
0
6. Section 430.3 is amended by:
0
a. Adding paragraphs (n)(8) and (n)(9); and
0
b. Removing ``and X'' in paragraph (o)(4) and adding in its place, ``X
and BB'' .
The additions read as follows:
Sec. 430.3 Materials incorporated by reference.
* * * * *
(n) IESNA. * * *
(8) ANSI/IESNA RP-16-2010, Nomenclature and Definitions for
Illuminating Engineering, approved October 15, 2005; IBR approved for
Sec. 430.2.
(9) IES LM-79-2008 (``IES LM-79''), Approved Method: Electrical and
Photometric Measurements of Solid-State Lighting Products, approved
December 31, 2007; IBR approved for Appendix BB to subpart B of this
part.
* * * * *
0
7. Section 430.23 is amended by adding paragraph (dd) to read as
follows:
Sec. 430.23 Test procedures for the measurement of energy and water
consumption.
* * * * *
(dd) Integrated light-emitting diode lamp. (1) The input power of
an integrated light-emitting diode lamp must be measured in accordance
with section 3 of Appendix BB of this subpart. Individual unit input
power must be rounded to the nearest tenth of a watt.
(2) The lumen output of an integrated light-emitting diode lamp
must be measured in accordance with section 3 of Appendix BB of this
subpart. Individual unit lumen output must be rounded to three
significant digits.
(3) The lamp efficacy of an integrated light-emitting diode lamp
must be calculated in accordance with section 3 of Appendix BB of this
subpart. Individual unit lamp efficacy must be rounded to the nearest
tenths place.
(4) The correlated color temperature of an integrated light-
emitting diode lamp must be measured in accordance with section 3 of
Appendix BB of this subpart. Individual unit correlated color
temperature must be rounded to the nearest 10 Kelvin.
(5) The color rendering index of an integrated light-emitting diode
lamp must be measured in accordance with section 3 of Appendix BB of
this subpart. Individual unit color rendering index must be rounded to
the nearest whole number.
(6) The lifetime of an integrated light-emitting diode lamp must be
measured in accordance with section 5 of Appendix BB of this subpart.
Individual unit lifetime must be rounded to the nearest hour.
(7) The life of an integrated light-emitting diode lamp must be
calculated by dividing the represented rated lifetime (see 10 CFR
429.56) by the estimated annual operating hours as specified in 16 CFR
305.15(b)(3)(iii). The life must be rounded to the nearest tenth of a
year.
(8) The estimated annual energy cost for an integrated light-
emitting diode lamp, expressed in dollars per year, must be the product
of the average input power in kilowatts as determined in accordance
with Appendix BB to this subpart, an electricity cost rate as specified
in 16 CFR 305.15(b)(1)(ii), and an estimated average annual use as
specified in 16 CFR 305.15(b)(1)(ii). The resulting estimated annual
energy cost for an individual unit must be rounded to the nearest cent
per year.
(9) The standby mode power must be measured in accordance with
section 5 of Appendix BB of this subpart. Individual unit standby mode
power must be rounded to the nearest tenth of a watt.
0
8. Section 430.25 is revised to read as follows:
Sec. 430.25 Laboratory Accreditation Program.
(a) Testing for general service fluorescent lamps, general service
[[Page 32047]]
incandescent lamps, and incandescent reflector lamps must be performed
in accordance with Appendix R to this subpart. Testing for medium base
compact fluorescent lamps must be performed in accordance with Appendix
W to this subpart. Testing for fluorescent lamp ballasts must be
performed in accordance with Appendix Q1 to this subpart. This testing,
with the exception of lifetime testing of general service incandescent
lamps, must be conducted by test laboratories accredited by the
National Voluntary Laboratory Accreditation Program (NVLAP) or an
accrediting organization recognized by International Laboratory
Accreditation Cooperation (ILAC). NVLAP is a program of the National
Institute of Standards and Technology, U.S. Department of Commerce.
NVLAP standards for accreditation of laboratories that test are set
forth in 15 CFR part 285. The following metrics should be measured by
test laboratories accredited by NVLAP or an accrediting organization
recognized by International Laboratory Accreditation Cooperation
(ILAC):
(1) Fluorescent lamp ballasts: ballast luminous efficiency (BLE);
(2) General service fluorescent lamps: lamp efficacy, color
rendering index;
(3) General service incandescent reflector lamps: lamp efficacy;
(4) General service incandescent lamps: lamp efficacy; and
(5) Medium base compact fluorescent lamps: initial efficacy, lamp
life. Testing for BLE may also be conducted by laboratories accredited
by Underwriters Laboratories or Council of Canada. Testing for
fluorescent lamp ballasts performed in accordance with Appendix Q to
this subpart is not required to be conducted by test laboratories
accredited by NVLAP or an accrediting organization recognized by NVLAP.
(b) Testing of integrated light-emitting diode lamps must be
performed in accordance with Appendix BB of this subpart. Testing must
be conducted in test laboratories accredited by NVLAP or an accrediting
organization recognized by International Laboratory Accreditation
Cooperation (ILAC) for the following metrics: input power, lumen
output, lamp efficacy, correlated color temperature, color rendering
index, lifetime, and standby mode power. A manufacturer's own
laboratory, if accredited, may conduct the testing.
0
9. Appendix BB to subpart B of part 430 is added to read as follows:
Appendix BB to Subpart B of Part 430--Uniform Test Method for Measuring
the Input Power, Lumen Output, Lamp Efficacy, Correlated Color
Temperature (CCT), Color Rendering Index (CRI), Lifetime, and Standby
Mode Power of Integrated Light-Emitting Diode (LED) Lamps
Note: After [DATE 180 DAYS AFTER PUBLICATION OF FINAL RULE IN
THE Federal Register], any representations made with respect to the
energy use or efficiency of light-emitting diode lamps must be made
in accordance with the results of testing pursuant to this appendix.
Given that after [DATE 180 DAYS AFTER PUBLICATION OF FINAL RULE IN
THE Federal Register] representations with respect to the energy use
or efficiency of light-emitting diode lamps must be made in
accordance with tests conducted pursuant to this appendix,
manufacturers may wish to begin using this test procedure as soon as
possible.
1. Scope: This appendix specifies how to measure input power,
lumen output, lamp efficacy, CCT, CRI, lifetime, and standby mode
power for integrated LED lamps.
2. Definitions
2.1. The definitions specified in section 1.3 of IES LM-79
except section 1.3(f) (incorporated by reference; see Sec. 430.3)
apply.
2.2. Initial lumen output means the measured lumen output after
the lamp is initially energized and stabilized using the
stabilization procedures in section 3 of Appendix BB of this
subpart.
2.3. Rated input voltage means the voltage(s) marked on the lamp
as the intended operating voltage. If not marked on the lamp, assume
120 V.
2.4. Lamp efficacy means the ratio of measured initial lumen
output in lumens to the measured lamp input power in watts, in units
of lumens per watt.
2.5. CRI means color rendering index as defined in Sec. 430.2.
2.6. Test duration means the operating time of the LED lamp
after the initial lumen output measurement and before, during, and
including the final lumen output measurement.
2.7. Lifetime means the time at which the lumen output is equal
to 70 percent of the initial lumen output measured using section 4
of Appendix BB of this subpart.
3. Active Mode Test Method for Determining Lumen Output, Input
Power, CCT, CRI, and Lamp Efficacy
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3).
3.1. Test Conditions and Setup
3.1.1. The ambient conditions, power supply, electrical
settings, and instrumentation must be established in accordance with
the specifications in sections 2.0, 3.0, 7.0, and 8.0 of IES LM-79
(incorporated by reference; see Sec. 430.3), respectively.
3.1.2. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
3.1.3. The integrated LED lamp must be operated at the rated
voltage throughout testing. For an integrated LED lamp with multiple
rated voltages including 120 volts, the integrated LED lamp must be
operated at 120 volts. If an integrated LED lamp with multiple rated
voltages is not rated for 120 volts, the integrated LED lamp must be
operated at the highest rated input voltage. Additional tests may be
conducted at other rated voltages.
3.1.4. The integrated LED lamp must be operated at maximum input
power. If multiple modes occur at the same maximum input power (such
as variable CCT or CRI), the manufacturer can select any of these
modes for testing; however, all measurements described in section 3
and section 4 must be taken at the same selected mode.
3.2. Test Method, Measurements, and Calculations
3.2.1. The integrated LED lamp must be stabilized prior to
measurement as specified in section 5.0 of IES LM-79 (incorporated
by reference; see Sec. 430.3). The stabilization variation is
calculated as [maximum-minimum)/minimum] of at least three readings
of the input power and lumen output over a period of 30 minutes,
taken 15 minutes apart.
3.2.2. The input power in watts must be measured as specified in
section 8.0 of IES LM-79 (incorporated by reference; see Sec.
430.3).
3.2.3. Lumen output must be measured as specified in section 9.1
and 9.2 of IES LM-79 (incorporated by reference; see Sec. 430.3).
Goniometers must not be used.
3.2.4. CCT must be determined according to the method specified
in section 12.0 of IES LM-79 (incorporated by reference; see Sec.
430.3) with the exclusion of section 12.2 of IES LM-79. Goniometers
must not be used.
3.2.5. CRI must be determined according to the method specified
in section 12.0 of IES LM-79 (incorporated by reference; see Sec.
430.3) with the exclusion of section 12.2 of IES LM-79. Goniometers
must not be used.
3.2.6. Lamp efficacy must be determined by dividing measured
initial lumen output by the measured input power.
4. Active Mode Test Method for Lifetime
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3).
4.1. Measure Initial Lumen Output. Measure the Initial Lumen Output
According to Section 3 of This Appendix
4.2. Test Duration. Operate the integrated LED lamp for a period
of time (the test duration) after the initial lumen output
measurement and before, during, and including the final lumen output
measurement.
4.2.1. There is no minimum test duration requirement for the
integrated LED lamp. The test duration is selected by the
manufacturer. See section 4.5.3 for instruction on the maximum
lifetime.
[[Page 32048]]
4.2.2. The test duration only includes time when the integrated
LED lamp is energized and operating.
4.2.3. Operating conditions and setup during the test duration
other than time during which lumen output measurements are being
conducted are specified in section 4.3 of this appendix.
4.3. Operating Conditions and Setup Between Lumen Output
Measurements
4.3.1. Ambient temperature must be controlled between 15 [deg]C
and 40 [deg]C.
4.3.2. The integrated LED lamps must be spaced to allow airflow
around each lamp.
4.3.3. The integrated LED lamps must not be subjected to
excessive vibration or shock during lamp operation.
4.3.4. Line voltage waveshape must be as described in section
3.1 of IES LM-79 (incorporated by reference; see Sec. 430.3).
4.3.5. Input voltage must be monitored and regulated to within
2 percent of the voltage required in section 3.1.3 for
the duration of the test.
4.3.6. Electrical settings must be as described in section 7.0
IES LM-79 (incorporated by reference; see Sec. 430.3).
4.3.7. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
4.3.8. The integrated LED lamp must be operated at maximum input
power. If multiple modes occur at the same maximum input power (such
as variable CCT and CRI), the manufacturer can select any of these
modes for testing. Measurements of all quantities described in
sections 3 and 4 of this appendix must be taken at the same selected
mode.
4.4. Measure Final Lumen Output. Measure the lumen output at the
end of the test duration according to section 3.
4.5.Calculate Lumen Maintenance and Lifetime
4.5.1. Calculate the lumen maintenance of the lamp after the
test duration ``t'' by dividing the final lumen output
``xt'' by the initial lumen output ``x0''.
Initial and final lumen output must be measured in accordance with
sections 4.1 and 4.4 of this appendix, respectively.
4.5.2. For lumen maintenance values greater than 1, the lifetime
(in hours) is limited to a value less than or equal to four times
the test duration.
4.5.3. For lumen maintenance values less than 1 but greater than
or equal to 0.7, the lifetime (in hours) is calculated using the
following equation:
[GRAPHIC] [TIFF OMITTED] TP03JN14.020
Where: t is the test duration in hours; x0 is the initial
lumen output; xt is the final lumen output at time t, and
ln is the natural logarithm function.
The maximum lifetime is limited to four times the test duration
t.
4.5.4. For lumen maintenance values less than 0.7, including
lamp failures that result in complete loss of light output, lifetime
is equal to the previously recorded lumen output measurement at a
shorter test duration where the lumen maintenance is greater than or
equal to 70 percent, and lifetime shall not be calculated in
accordance with section 4.5.3 of this appendix.
5. Standby Mode Test Method for Determining Standby Mode Power
In cases where there is a conflict, the language of the test
procedure in this appendix takes precedence over IES LM-79
(incorporated by reference; see Sec. 430.3) and IEC 62301
(incorporated by reference; see Sec. 430.3).
5.1. Test Conditions and Setup
5.1.1. The ambient conditions, power supply, electrical
settings, and instrumentation must be established in accordance with
the specifications in sections 2.0, 3.0, 7.0, and 8.0 of IES LM-79
(incorporated by reference; see Sec. 430.3), respectively.
5.1.2. An equal number of integrated LED lamps must be
positioned in the base up and base down orientations throughout
testing.
5.1.3. The integrated LED lamp must be operated at the rated
voltage throughout testing. For an integrated LED lamp with multiple
rated voltages, the integrated LED lamp must be operated at 120
volts. If an integrated LED lamp with multiple rated voltages is not
rated for 120 volts, the integrated LED lamp must be operated at the
highest rated input voltage.
5.2. Test Method, Measurements, and Calculations
5.2.1. Standby mode power consumption must be measured for
integrated LED lamps if applicable.
5.2.2. The integrated LED lamp must be stabilized prior to
measurement as specified in section 5.0 of IES LM-79 (incorporated
by reference; see Sec. 430.3). The stabilization variation is
calculated as [maximum--minimum)/minimum] of at least three readings
of the input power and lumen output over a period of 30 minutes,
taken 15 minutes apart.
5.2.3. The integrated LED must be configured in standby mode by
sending a signal to the integrated LED lamp instructing it to have
zero light output.
5.2.4. The standby mode power in watts must be measured as
specified in section 5 of IEC 62301 (incorporated by reference; see
Sec. 430.3).
[FR Doc. 2014-12127 Filed 6-2-14; 8:45 am]
BILLING CODE 6450-01-P