[Federal Register Volume 80, Number 16 (Monday, January 26, 2015)]
[Rules and Regulations]
[Pages 4042-4153]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-00317]
[[Page 4041]]
Vol. 80
Monday,
No. 16
January 26, 2015
Part II
Department of Energy
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10 CFR Part 430
Energy Conservation Program: Energy Conservation Standards for General
Service Fluorescent Lamps and Incandescent Reflector Lamps; Final Rule
Federal Register / Vol. 80 , No. 16 / Monday, January 26, 2015 /
Rules and Regulations
[[Page 4042]]
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DEPARTMENT OF ENERGY
10 CFR Part 430
[Docket Number EERE-2011-BT-STD-0006]
RIN 1904-AC43
Energy Conservation Program: Energy Conservation Standards for
General Service Fluorescent Lamps and Incandescent Reflector Lamps
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Final rule.
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SUMMARY: The Energy Policy and Conservation Act of 1975 (EPCA), as
amended, prescribes energy conservation standards for various consumer
products and certain commercial and industrial equipment, including
general service fluorescent lamps (GSFLs) and incandescent reflector
lamps (IRLs). EPCA also requires the U.S. Department of Energy (DOE) to
determine whether more-stringent standards would be technologically
feasible and economically justified, and would save a significant
amount of energy. In this final rule, DOE is adopting more-stringent
energy conservation standards for GSFLs. It has determined that the
amended energy conservation standards for these products would result
in significant conservation of energy, and are technologically feasible
and economically justified. DOE concluded in this final rule that
amending energy conservation standards for IRLs would not be
economically justified.
DATES: The effective date of this rule is March 27, 2015. Compliance
with the amended standards established for GSFLs and IRLs in this final
rule is January 26, 2018.
ADDRESSES: The docket, which includes Federal Register notices, public
meeting attendee lists and transcripts, comments, and other supporting
documents/materials, is available for review at regulations.gov. All
documents in the docket are listed in the regulations.gov index.
However, some documents listed in the index, such as those containing
information that is exempt from public disclosure, may not be publicly
available.
A link to the docket Web page can be found at:
www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24. The regulations.gov Web page will contain simple
instructions on how to access all documents, including public comments,
in the docket.
For further information on how to review the docket, contact Ms.
Brenda Edwards at (202) 586-2945 or by email:
[email protected].
FOR FURTHER INFORMATION CONTACT: Ms. Lucy deButts, U.S. Department of
Energy, Office of Energy Efficiency and Renewable Energy, Building
Technologies Program, EE-2J, 1000 Independence Avenue SW., Washington,
DC 20585-0121. Telephone: (202) 287-1604. Email:
[email protected].
Ms. Elizabeth Kohl, U.S. Department of Energy, Office of the
General Counsel, GC-71, 1000 Independence Avenue SW., Washington, DC
20585-0121. Telephone: (202) 586-7796. Email:
[email protected].
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Summary of the Final Rule and Its Benefits
A. Benefits and Costs to Consumers
B. Impact on Manufacturers
C. National Benefits
D. Conclusion
II. Introduction
A. Authority
B. Background
1. Current Standards
2. Corrections to Codified Standards
3. History of Standards Rulemaking for General Service
Fluorescent Lamps and Incandescent Reflector Lamps
4. Test Procedure
a. Standby and Off Mode Energy Consumption
III. General Discussion
A. Product Classes and Scope of Coverage
B. Technological Feasibility
1. General
2. Maximum Technologically Feasible Levels
C. Energy Savings
1. Determination of Savings
2. Significance of Savings
D. Economic Justification
1. Specific Criteria
a. Economic Impact on Manufacturers and Consumers
b. Savings in Operating Costs Compared to Increase in Price
c. Energy Savings
d. Lessening of Utility or Performance of Products
e. Impact of Any Lessening of Competition
f. Need for National Energy Conservation
g. Other Factors
2. Rebuttable Presumption
IV. Issues Affecting Rulemaking Schedule
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
2. Additional General Service Fluorescent Lamp Wattages
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
2. Incandescent Reflector Wattages
D. Summary of Scope of Coverage
VI. Methodology and Discussion
A. Market and Technology Assessment
1. General Service Fluorescent Lamp Technology Options
a. Highly Emissive Coatings
b. Higher Efficiency Lamp Fill Gas Composition
c. Higher Efficiency Phosphors
d. Summary of GSFL Technology Options
2. Incandescent Reflector Lamp Technology Options
a. Thinner Filaments
b. Efficient Filament Coiling
c. Efficient Filament Orientation
d. Higher Efficiency Inert Fill Gas
e. Higher Pressure Tungsten-Halogen Lamps
f. Infrared Glass Coatings
g. Efficient Filament Placement
h. Integrally Ballasted Low Voltage Lamps
i. Summary of IRL Technology Options
B. Screening Analysis
1. General Service Fluorescent Lamp Design Options
2. Incandescent Reflector Lamp Design Options
a. Higher Temperature Operation
b. Thinner Filaments
c. Higher Efficiency Reflector Coatings
d. Higher Pressure Tungsten-Halogen Lamps
C. Product Classes
1. General Service Fluorescent Lamp Product Classes
a. Two-Foot U-Shaped Lamps
b. Long-Life Lamps
c. Summary of GSFL Product Classes
2. Incandescent Reflector Lamp Product Classes
a. Rated Voltage
b. Modified Spectrum
c. Summary of IRL Product Classes
D. Engineering Analysis
1. General Approach
2. General Service Fluorescent Lamp Engineering
a. Data Approach
b. Representative Product Classes
c. Baseline Lamps
d. More Efficacious Substitutes
e. General Service Fluorescent Lamp Systems
f. Max Tech
g. Efficacy Levels
h. Scaling to Other Product Classes
i. Rare Earth Phosphors
3. Incandescent Reflector Lamp Engineering
a. Representative Product Classes
b. Baseline Lamps
c. More Efficacious Substitutes
d. Max Tech
e. Efficacy Levels
f. Scaling to Other Product Classes
g. Xenon
h. Proprietary Technology
E. Product Pricing Determination
F. Energy Use
1. Operating Hours
2. Lighting Controls
a. General Service Fluorescent Lamp Lighting Controls
b. Incandescent Reflector Lamp Lighting Controls
[[Page 4043]]
G. Life-Cycle Cost Analysis and Payback Period Analysis
1. Consumer Product Price
2. Sales Tax
3. Installation Cost
4. Annual Energy Use
5. Product Energy Consumption Rate
6. Electricity Prices
7. Electricity Price Projections
8. Replacement and Disposal Costs
9. Lamp Purchase Events
10. Product Lifetime
a. Lamp Lifetime
b. Ballast Lifetime
11. Discount Rates
12. Analysis Period
13. Compliance Date of Standards
14. Incandescent Reflector Lamp Life-Cycle Cost Results in the
NOPR
H. Consumer Subgroup Analysis
I. Shipments Analysis
J. National Impact Analysis--National Energy Savings and Net
Present Value Analysis
1. National Energy Savings
2. Net Present Value of Consumer Benefit
a. Total Annual Installed Cost
b. Total Annual Operating Cost Savings
K. Manufacturer Impact Analysis
1. Manufacturer Production Costs
2. Shipment Projections
3. Markup Scenarios
4. Product and Capital Conversion Costs
5. Other Comments From Interested Parties
a. High Cost to Manufacturers versus Relatively Low Energy
Savings
b. Impacts on Competition
c. Impact of GSFL and IRL Standards on Alternative Lighting
Technologies
6. Manufacturer Interviews
L. Emissions Analysis
M. Monetizing Carbon Dioxide and Other Emissions Impacts
1. Social Cost of Carbon
a. Monetizing Carbon Dioxide Emissions
b. Development of Social Cost of Carbon Values
c. Current Approach and Key Assumptions
2. Valuation of Other Emissions Reductions
N. Utility Impact Analysis
O. Employment Impact Analysis
P. Proposed Standards in April 2014 NOPR
1. GSFLs Proposed Standards
2. IRL Proposed Standards
VII. Analytical Results
A. Trial Standard Levels
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
a. Life-Cycle Cost and Payback Period
b. Consumer Subgroup Analysis
c. Rebuttable-Presumption Payback
2. Economic Impacts on Manufacturers
a. Industry Cash-Flow Analysis Results
b. Impacts on Employment
c. Impacts on Manufacturing Capacity
d. Impacts on Subgroups of Manufacturers
e. Cumulative Regulatory Burden
3. National Impact Analysis
a. Significance of Energy Savings
b. Net Present Value of Consumer Costs and Benefits
c. Alternative Scenario Analyses
d. Indirect Impacts on Employment
4. Impact on Utility or Performance of Equipment
5. Impact of Any Lessening of Competition
6. Need of the Nation to Conserve Energy
7. Summary of National Economic Impacts
C. Conclusions
1. Benefits and Burdens of Trial Standard Levels Considered for
General Service Fluorescent Lamps
2. Summary of Benefits and Costs (Annualized) of the Adopted
Standards for General Service Fluorescent Lamps
3. Benefits and Burdens of Trial Standard Levels Considered for
Incandescent Reflector Lamps
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
B. Review Under the Regulatory Flexibility Act
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
b. Manufacturer Participation
c. GSFL Industry Structure and Nature of Competition
d. Comparison Between Large and Small Entities
2. Description and Estimate of Compliance Requirements
3. Duplication, Overlap, and Conflict With Other Rules and
Regulations
4. Significant Alternatives to the Rule
C. Review Under the Paperwork Reduction Act
D. Review Under the National Environmental Policy Act of 1969
E. Review Under Executive Order 13132
F. Review Under Executive Order 12988
G. Review Under the Unfunded Mandates Reform Act of 1995
H. Review Under the Treasury and General Government
Appropriations Act, 1999
I. Review Under Executive Order 12630
J. Review Under the Treasury and General Government
Appropriations Act, 2001
K. Review Under Executive Order 13211
L. Review Under the Information Quality Bulletin for Peer Review
M. Congressional Notification
IX. Approval of the Office of the Secretary
I. Summary of the Final Rule and Its Benefits
Title III, Part B \1\ of the Energy Policy and Conservation Act of
1975 (EPCA or the Act), Pub. L. 94-163 (42 U.S.C. 6291-6309, as
codified), established the Energy Conservation Program for Consumer
Products Other Than Automobiles.\2\ These products include GSFLs and
IRLs, the subject of this final rule.
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\1\ For editorial reasons, upon codification in the U.S. Code,
Part B was redesignated Part A.
\2\ All references to EPCA in this document refer to the statute
as amended through the American Energy Manufacturing Technical
Corrections Act (AEMTCA), Pub. L. 112-210 (Dec. 18, 2012).
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Pursuant to EPCA, any new or amended energy conservation standard
must be designed to achieve the maximum improvement in energy
efficiency that DOE determines is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, the new
or amended standard must result in significant conservation of energy.
(42 U.S.C. 6295(o)(3)(B)) In accordance with these and other statutory
provisions discussed in this rule, DOE is adopting amended energy
conservation standards for GSFLs. The amended standards, which are the
minimum lumen output per watt of a lamp, are shown in Table I.1. These
amended standards apply to all products listed in Table I.1, and
manufactured in, or imported into, the United States on or after
January 26, 2018. For IRLs, DOE considered an efficacy level (EL) as a
means of increasing energy savings. However, based on the analyses
presented in this final rule, DOE concluded that standards for IRLs are
not economically justified and therefore, is not amending IRL
standards. On July 14, 2009, DOE published a final rule in the Federal
Register, which prescribed the current energy conservation standards
for GSFLs and IRLs manufactured on or after July 14, 2012. 74 FR 34080.
Table I.1--Energy Conservation Standards for General Service Fluorescent Lamps
[Compliance starting January 26, 2018]
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Percent
Correlated color Adopted level increase over
Lamp type Covered wattages W temperature Kelvin lm/W * current
standards
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4-Foot Medium Bipin................ >=25 W............. <=4,500 K............. 92.4 3.8
>4,500 K and <=7,000 K 88.7 0.8
[[Page 4044]]
2-Foot U-Shaped.................... >=25 W............. <=4,500 K............. 85.0 1.2
>4,500 K and <=7,000 K 83.3 2.8
8-Foot Slimline.................... >=49 W............. <=4,500 K............. 97.0 0.0
>4,500 K and <=7,000 K 93.0 0.0
8-Foot Recessed Double Contact High All................ <=4,500 K............. 92.0 0.0
Output. >4,500 K and <=7,000 K 88.0 0.0
4-Foot Miniature Bipin Standard >=25 W............. <=4,500 K............. 95.0 10.5
Output. >4,500 K and <=7,000 K 89.3 10.2
4-Foot Miniature Bipin High Output. >=44 W............. <=4,500 K............. 82.7 8.8
>4,500 K and <=7,000 K 76.9 6.8
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* A ``lumen'' is a measurement of the radiometric energy emission from a light source weighted by the response
function of a human eye, called the photopic spectral luminous efficiency function, V([lambda]). Test
procedures for measuring lumens are also specified at 10 CFR part 430, subpart B, appendix R.
A. Benefits and Costs to Consumers
Table I.2 presents DOE's evaluation of the economic impacts of
these standards on consumers of GSFLs, as measured by the average life-
cycle cost (LCC) savings and the median payback period (PBP). The
weighted-average LCC savings are positive for all product classes with
amended standards.
Table I.2--Impacts of Energy Conservation Standards on Consumers of
General Service Fluorescent Lamps
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Weighted-average
Product class Weighted-average mean payback
LCC savings 2013$ period * years
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4-foot medium bipin <=4,500 K... 5.98 3.1
4-foot T5 miniature bipin 5.68 4.0
standard output <=4,500 K......
4-foot T5 miniature bipin high 4.74 2.8
output <=4,500 K...............
8-foot single pin slimline **0.00 **0.0
<=4,500 K......................
8-foot recessed double contact **0.00 **0.0
HO <=4,500 K...................
------------------------------------------------------------------------
* Does not include weighting for ``NER'' Scenarios. ``NER'' indicates
standard levels that do not reduce operating costs, which prevents the
consumer from recovering the increased purchase cost.
** Standards were not amended.
B. Impact on Manufacturers
The industry net present value (INPV) is the sum of the discounted
cash flows to the industry from the base year through the end of the
analysis period (2015 to 2047). Using a real discount rate of 9.2
percent, DOE estimates that the INPV for manufacturers of GSFLs is
$1,551.6 million in 2013$. Under these standards, DOE expects that
manufacturers may lose up to 21.3 percent of their INPV, which is
approximately $330.0 million. Additionally, based on DOE's interviews
with the manufacturers of GSFLs, DOE does not expect any plant closings
or significant loss of employment.
C. National Benefits \3\
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\3\ All monetary values in this section are expressed in 2013
dollars and are discounted to 2014.
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DOE's analyses indicate that these standards would save a
significant amount of energy. The energy savings over the entire
lifetime of GSFLs installed during the 30-year period that begins in
the year of compliance with amended standards (2018-2047), in
comparison to the base case without amended standards, amount to 2.5
quadrillion Btu (quads) \4\ for GSFLs. This represents a savings of 7.1
percent relative to the energy use of this product in the base case
without amended standards. No savings are realized for IRLs, as DOE is
not amending the standards for IRLs.
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\4\ A quad is equal to 10\15\ British thermal units (Btu).
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The cumulative net present value (NPV) of total consumer costs and
savings of these standards for GSFLs ranges from $2.0 billion (at a 7-
percent discount rate) to $5.5 billion (at a 3-percent discount rate).
This NPV expresses the estimated total value of future operating-cost
savings minus the estimated increased product costs for products
purchased in 2018-2047.
In addition, these standards for GSFLs would have significant
environmental benefits. The energy savings from the 30-year product
purchase period with these standards, relative to the base case without
amended standards, would result in cumulative greenhouse gas emission
reductions of approximately 160 million metric tons (Mt) \5\ of carbon
dioxide (CO2), 650 thousand tons of methane, 140 thousand
tons of sulfur dioxide (SO2), 230 thousand tons of nitrogen
oxides (NOX), 2.0 thousand tons of nitrous oxide
(N2O), and 0.43 tons of mercury (Hg).\6\ The cumulative
reduction in CO2 emissions through 2030 amounts to 90 Mt,
which is
[[Page 4045]]
equivalent to the emissions associated with annual electricity use of
approximately 12 million homes.
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\5\ A metric ton is equivalent to 1.1 short tons. Results for
NOX and Hg are presented in short tons.
\6\ DOE calculated emissions reductions relative to the Annual
Energy Outlook (AEO) 2014 Reference case, which generally represents
current legislation and environmental regulations for which
implementing regulations were available as of October 31, 2013.
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The value of the CO2 reductions is calculated using a
range of values per metric ton of CO2 (otherwise known as
the Social Cost of Carbon, or SCC) developed by a recent Federal
interagency process.\7\ The derivation of the SCC values is discussed
in section VI.M.1. Using discount rates appropriate for each set of SCC
values, DOE estimates that the net present monetary value of the
CO2 emissions reductions for GSFLs is between $1.36 billion
and $17.6 billion, with a value of $5.72 billion using the central SCC
case represented by $40.5/t in 2015.\8\ DOE also estimates that the net
present monetary value of the NOX emissions reductions is
$400 million at a 3-percent discount rate, and $240 million at a 7-
percent discount rate.\9\
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\7\ Technical Update of the Social Cost of Carbon for Regulatory
Impact Analysis Under Executive Order 12866. Interagency Working
Group on Social Cost of Carbon, United States Government. May 2013;
revised November 2013. http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
\8\ The values only include CO2 emissions, not
CO2 equivalent emissions; other gases with global warming
potential are not included.
\9\ DOE is currently investigating valuation of avoided Hg and
SO2 emissions for future rule makings.
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Table I.3 summarizes the national economic costs and benefits
expected to result from these standards for GSFLs.
Table I.3--Summary of National Economic Benefits and Costs of Amended
Energy Conservation Standards for General Service Fluorescent Lamps *
------------------------------------------------------------------------
Present value Discount rate
Category Billion 2013$ (%)
------------------------------------------------------------------------
Benefits
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Operating Cost Savings............ 11.2 7
18.9 3
CO2 Reduction Monetized Value 1.3 5
($12.0/t case) **................
CO2 Reduction Monetized Value 5.72 3
($40.5/t case) **................
CO2 Reduction Monetized Value 8.92 2.5
($62.4/t case) **................
CO2 Reduction Monetized Value 17.6 3
($119/t case) **.................
NOX Reduction Monetized Value (at 0.24 7
$2,684/ton)...................... 0.40 3
Total Benefits [dagger]........... 17.1 7
25.1 3
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Costs
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Incremental Installed Costs 9.17 7
[Dagger]......................... 13.5 3
Including Emissions Reduction 7.96 7
Monetized Value [dagger]......... 11.6 3
------------------------------------------------------------------------
* This table presents the costs and benefits associated with GSFLs
shipped in 2018-2047. These results include impacts on consumers that
accrue after 2047 from the products purchased in 2018-2047. The
results account for the incremental variable and fixed costs incurred
by manufacturers due to the standard, some of which may be incurred in
preparation for the rule.
** The CO2 values represent global monetized values of the SCC, in
2013$, in 2015 under several scenarios of the updated SCC values. The
first three cases use the averages of SCC distributions calculated
using 5%, 3%, and 2.5% discount rates, respectively. The fourth case
represents the 95th percentile of the SCC distribution calculated
using a 3% discount rate. The SCC time series incorporate an
escalation factor.
[dagger] Total Benefits for both the 3% and 7% cases are derived using
the series corresponding to average SCC with 3-percent discount rate
($40.5/t case).
The benefits and costs of these standards, for products sold in
2018-2047, can also be expressed in terms of annualized values. The
annualized monetary values are the sum of (1) the annualized national
economic value of the benefits from operating the product that meets
the amended standard (consisting primarily of operating cost savings
from using less energy, minus increases in product purchase prices and
installation costs), which is another way of representing consumer NPV,
and (2) the annualized monetary value of the benefits of emission
reductions, including CO2 emission reductions.\10\
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\10\ To convert the time-series of costs and benefits into
annualized values, DOE calculated a present value in 2014, the year
used for discounting the NPV of total consumer costs and savings.
For the benefits, DOE calculated a present value associated with
each year's shipments in the year in which the shipments occur
(e.g., 2020 or 2030), and then discounted the present value from
each year to 2014. The calculation uses discount rates of 3 and 7
percent for all costs and benefits except for the value of
CO2 reductions, for which DOE used case-specific discount
rates. Using the present value, DOE then calculated the fixed annual
payment over a 30-year period, starting in the compliance year, that
yields the same present value.
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Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. consumer monetary savings that occur as a result of market
transactions, whereas the value of CO2 reductions is based
on a global value. Second, the assessments of operating cost savings
and CO2 savings are performed with different methods that
use different time frames for analysis. The national operating cost
savings is measured for the lifetime of GSFLs shipped in 2018-2047. The
SCC values, on the other hand, reflect the present value of all future
climate-related impacts resulting from the emission of one metric ton
of carbon dioxide in each year. These impacts continue well beyond
2100.
Estimates of annualized benefits and costs of these standards for
GSFLs are shown in Table I.4. The results under the primary estimate
are as follows. Using a 7-percent discount rate for benefits and costs
other than CO2 reduction, for which DOE used a 3-percent
discount rate along with the SCC series that has a value of $40.5/t in
2015, the cost of the standards in this rule is $841 million per year
in increased equipment costs, while the
[[Page 4046]]
benefits are $1,030 million per year in reduced equipment operating
costs, $310 million in CO2 reductions, and $22.4 million in
reduced NOX emissions. In this case, the net benefit amounts
to $516 million per year. Using a 3-percent discount rate for all
benefits and costs and the SCC series that has a value of $40.5/t in
2015, the cost of the standards in this rule is $724 million per year
in increased equipment costs, while the benefits are $1,020 million per
year in reduced operating costs, $310 million in CO2
reductions, and $21.6 million in reduced NOX emissions. In
this case, the net benefit amounts to $627 million per year.\11\
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\11\ The annualized consumer operating cost savings,
NOX reduction monetized value, and consumer incremental
product costs are higher with a 7-percent discount rate than with a
3-percent discount rate. This is in contrast to the present values
in Table I.3. Under certain conditions, different present values may
lead to similar annualized values when calculated with different
discount rates. In this case, the combined effects of (a) projecting
to 2018 the present values that DOE calculated in 2014, and (b)
annualizing the projected values with 3 percent and 7 percent
discount rates over the 30-year analysis period, lead to similar
annualized values. For consumer incremental product costs, the
effect is more pronounced because the time series covers only 30
years, instead of the longer period covered for operating cost
savings and NOX reduction monetized value.
Table I.4--Annualized Benefits and Costs of Amended Energy Conservation Standards for General Service
Fluorescent Lamps *
----------------------------------------------------------------------------------------------------------------
million 2013$/year
-----------------------------------------------------
Discount rate LowNet benefits HighNet benefits
Primary estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings.... 7%................... 1,030 1,010 1,050
3%................... 1,020 1,000 1,050
CO2 Reduction Monetized Value 5%................... 97.5 97.1 97.5
($12.0/t case) **.
CO2 Reduction Monetized Value 3%................... 310 308 310
($40.5/t case) **.
CO2 Reduction Monetized Value 2.5%................. 448 446 448
($62.4/t case) **.
CO2 Reduction Monetized Value ($119/ 3%................... 950 946 950
t case) **.
NOX Reduction Monetized Value (at 7%................... 22.4 22.3 22.4
$2,684/ton) **. 3%................... 21.6 21.5 21.6
Total Benefits [dagger]............ 7% plus CO2 range.... 1,150 to 2,000 1,130 to 1,980 1,170 to 2,030
7%................... 1,360 1,340 1,390
3% plus CO2 range.... 1,140 to 2,000 1,120 to 1,970 1,170 to 2,030
3%................... 1,360 1,330 1,390
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Costs
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product Costs. 7%................... 841 882 841
3%................... 724 763 724
----------------------------------------------------------------------------------------------------------------
Net Benefits
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Total [dagger]..................... 7% plus CO2 range.... 300 to 1,160 241 to 1,090 328 to 1,180
7%................... 516 452 540
3% plus CO2 range.... 415 to 1,270 350 to 1,200 443 to 1,300
3%................... 627 561 655
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* This table presents the annualized costs and benefits associated with GSFLs shipped in 2018-2047. These
results include benefits to consumers that accrue after 2047 from the products purchased in 2018-2047. The
results account for the incremental variable and fixed costs incurred by manufacturers due to the standard,
some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the Reference
case energy prices from AEO 2014 and decreasing incremental product cost, due to price learning. The Low
Benefits Estimate uses the Low Economic Growth energy prices from AEO 2014 and constant real product prices.
The High Benefits Estimate assumes the Low Economic Growth energy price estimates from AEO 2014 and the same
decreasing incremental product costs as in the Primary Benefits Estimate.
** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average
SCC with 3-percent discount rate ($40.5/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2
range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and those values
are added to the full range of CO2 values.
D. Conclusion
Based on the analyses culminating in this final rule, DOE found
that for GSFLs the benefits to the nation of the standards (energy
savings, consumer LCC savings, positive NPV of consumer benefit, and
emission reductions) outweigh the burdens (loss of INPV and LCC
increases for some users of these products). DOE has concluded that the
standards in this rule represent the maximum improvement in energy
efficiency that is technologically feasible and economically justified,
and would result in significant conservation of energy.
II. Introduction
The following section briefly discusses the statutory authority
underlying this rule, as well as some of the relevant historical
background related to the establishment of existing standards for GSFLs
and IRLs.
A. Authority
Title III, Part B of the Energy Policy and Conservation Act of 1975
(EPCA or the Act), Public Law 94-163 (42 U.S.C. 6291-6309, as codified)
established the Energy Conservation Program for Consumer Products Other
Than Automobiles, a program covering most major household appliances
(collectively referred to as ``covered products''), which includes the
types of GSFLs and IRLs that are the subject of this rulemaking. (42
U.S.C. 6292(a)(14))
[[Page 4047]]
EPCA prescribed energy conservation standards for these products (42
U.S.C. 6295(i)(1)), and directed DOE to conduct further rulemakings to
determine whether to amend these standards. (42 U.S.C. 6295(i)(3)-(5))
On July 14, 2009, DOE published a final rule in the Federal Register,
which completed the first rulemaking cycle to amend energy conservation
standards for GSFLs and IRLs (hereafter the ``2009 Lamps Rule''). 74 FR
34080. That rule adopted standards for additional GSFLs, amended the
definition of ``colored fluorescent lamp'' and ``rated wattage,'' and
also adopted test procedures applicable to the newly covered GSFLs.
Information regarding the 2009 Lamps Rule can be found on
regulations.gov, docket number EERE-2006-STD-0131 at
www.regulations.gov/#!docketDetail;D=EERE-2006-STD-0131.
This rulemaking encompasses DOE's second cycle of review to
determine whether the standards in effect for GSFLs and IRLs should be
amended, including whether the standards should be applicable to
additional GSFLs. (DOE notes that under 42 U.S.C. 6295(m), the agency
must periodically review its already established energy conservation
standards for a covered product. Under this requirement, the next
review that DOE would need to conduct must occur no later than six
years from the issuance of a final rule establishing or amending a
standard for a covered product.)
Pursuant to EPCA, DOE's energy conservation program for covered
products consists essentially of four parts: (1) Testing; (2) labeling;
(3) the establishment of federal energy conservation standards; and (4)
certification and enforcement procedures. The Federal Trade Commission
(FTC) is primarily responsible for labeling, and DOE implements the
remainder of the program. Subject to certain criteria and conditions,
DOE is required to develop test procedures to measure the energy
efficiency, energy use, or estimated annual operating cost of each
covered product. (42 U.S.C. 6293) Manufacturers of covered products
must use the prescribed DOE test procedure as the basis for certifying
to DOE that their products comply with the applicable energy
conservation standards adopted under EPCA and when making
representations to the public regarding the energy use or efficiency of
those products. (42 U.S.C. 6293(c) and 6295(s)) Similarly, DOE must use
these test procedures to determine whether the products comply with
standards adopted pursuant to EPCA. Id. The DOE test procedures for
GSFLs and IRLs currently appear at title 10 of the Code of Federal
Regulations (CFR) part 430, subpart B, appendix R.
DOE must follow specific statutory criteria for prescribing amended
standards for covered products. As indicated above, any amended
standard for a covered product must be designed to achieve the maximum
improvement in energy efficiency that is technologically feasible and
economically justified. (42 U.S.C. 6295(o)(2)(A)) Furthermore, DOE may
not adopt any standard that would not result in the significant
conservation of energy. (42 U.S.C. 6295(o)(3)) Moreover, DOE may not
prescribe a standard: (1) For certain products, including GSFLs and
IRLs, if no test procedure has been established for the product, or (2)
if DOE determines by rule that the amended standard is not
technologically feasible or economically justified. (42 U.S.C.
6295(o)(3)(A)-(B)) In deciding whether an amended standard is
economically justified, DOE must determine whether the benefits of the
standard exceed its burdens. (42 U.S.C. 6295(o)(2)(B)(i)) DOE must make
this determination after receiving comments on the proposed standard,
and by considering, to the greatest extent practicable, the following
seven statutory factors:
1. The economic impact of the standard on manufacturers and
consumers of the products subject to the standard;
2. The savings in operating costs throughout the estimated average
life of the covered products in the type (or class) compared to any
increase in the price, initial charges, or maintenance expenses for the
covered products that are likely to result from the imposition of the
standard;
3. The total projected amount of energy, or as applicable, water,
savings likely to result directly from the imposition of the standard;
4. Any lessening of the utility or the performance of the covered
products likely to result from the imposition of the standard;
5. The impact of any lessening of competition, as determined in
writing by the Attorney General, that is likely to result from the
imposition of the standard;
6. The need for national energy and water conservation; and
7. Other factors the Secretary of Energy (Secretary) considers
relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)-(VII))
EPCA, as codified, also contains what is known as an ``anti-
backsliding'' provision, which prevents the Secretary from prescribing
any amended standard that either increases the maximum allowable energy
use or decreases the minimum required energy efficiency of a covered
product. (42 U.S.C. 6295(o)(1)) Also, the Secretary may not prescribe
an amended or new standard if interested persons have established by a
preponderance of the evidence that the standard is likely to result in
the unavailability in the United States of any covered product type (or
class) of performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as those generally available in the United States. (42 U.S.C.
6295(o)(4))
Further, EPCA, as codified, establishes a rebuttable presumption
that a standard is economically justified if the Secretary finds that
the additional cost to the consumer of purchasing a product complying
with an energy conservation standard level will be less than three
times the value of the energy savings during the first year that the
consumer will receive as a result of the standard, as calculated under
the applicable test procedure. See 42 U.S.C. 6295(o)(2)(B)(iii).
Additionally, 42 U.S.C. 6295(q)(1) specifies requirements when
promulgating a standard for a type or class of covered product that has
two or more subcategories. DOE must specify a different standard level
than that which applies generally to such type or class of products for
any group of covered products that have the same function or intended
use if DOE determines that products within such group (A) consume a
different kind of energy from that consumed by other covered products
within such type (or class); or (B) have a capacity or other
performance-related feature which other products within such type (or
class) do not have and such feature justifies a higher or lower
standard. (42 U.S.C. 6295(q)(1)) In determining whether a performance-
related feature justifies a different standard for a group of products,
DOE must consider such factors as the utility to the consumer of such a
feature and other factors DOE deems appropriate. Id. Any rule
prescribing such a standard must include an explanation of the basis on
which such higher or lower level was established. (42 U.S.C.
6295(q)(2))
Federal energy conservation requirements generally supersede state
laws or regulations concerning energy conservation testing, labeling,
and standards. (42 U.S.C. 6297(a)-(c)) DOE may, however, grant waivers
of federal preemption for particular state laws or regulations, in
accordance with the procedures and other provisions set forth under 42
U.S.C. 6297(d)).
Finally, pursuant to the amendments contained in section 310(3) of
the Energy Independence and Security Act
[[Page 4048]]
of 2007 (EISA 2007), any final rule for new or amended energy
conservation standards promulgated after July 1, 2010, are required to
address standby mode and off mode energy use. (42 U.S.C. 6295(gg)(3))
Specifically, when DOE adopts a standard for a covered product after
that date, it must, if justified by the criteria for adoption of
standards under EPCA (42 U.S.C. 6295(o)), incorporate standby mode and
off mode energy use into the standard, or, if that is not feasible,
adopt a separate standard for such energy use for that product. (42
U.S.C. 6295(gg)(3)(A)-(B)) DOE has determined that standby mode and off
mode do not apply to GSFLs and IRLs and that their energy use is
accounted for entirely in the active mode. Therefore, DOE is not
addressing standby and off modes, and will only address active mode in
this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
(E.O.) 13563, issued on January 18, 2011 (76 FR 3281, Jan. 21, 2011).
E.O. 13563 is supplemental to and explicitly reaffirms the principles,
structures, and definitions governing regulatory review established in
Executive Order 12866, ``Regulatory Planning and Review,'' 58 FR 51735
(Oct. 4, 1993). To the extent permitted by law, agencies are required
by Executive Order 13563 to: (1) Propose or adopt a regulation only
upon a reasoned determination that its benefits justify its costs
(recognizing that some benefits and costs are difficult to quantify);
(2) tailor regulations to impose the least burden on society,
consistent with obtaining regulatory objectives, taking into account,
among other things, and to the extent practicable, the costs of
cumulative regulations; (3) select, in choosing among alternative
regulatory approaches, those approaches that maximize net benefits
(including potential economic, environmental, public health and safety,
and other advantages; distributive impacts; and equity); (4) to the
extent feasible, specify performance objectives, rather than specifying
the behavior or manner of compliance that regulated entities must
adopt; and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or marketable permits, or providing
information upon which choices can be made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, the Office of Information and Regulatory Affairs (OIRA) has
emphasized that such techniques may include identifying changing future
compliance costs that might result from technological innovation or
anticipated behavioral changes. For the reasons stated in the preamble,
DOE believes that this rule is consistent with these principles,
including the requirement that, to the extent permitted by law,
benefits justify costs and that net benefits are maximized. Consistent
with E.O. 13563, and the range of impacts analyzed in this rulemaking,
the energy-efficiency standard adopted herein by DOE achieves maximum
net benefits. For further discussion of how this rulemaking achieves
maximum net benefits, see section VII.
B. Background
1. Current Standards
In the 2009 Lamps Rule, DOE prescribed the current energy
conservation standards for GSFLs and IRLs manufactured on or after July
14, 2012 (hereafter the ``July 2012 standards''). 74 FR 34080. The
current standards are set forth in Table II.1 and Table II.2.
Table II.1--July 2012 Standards for General Service Fluorescent Lamps
------------------------------------------------------------------------
Minimum
Lamp type Correlated color average lamp
temperature efficacy lm/W
------------------------------------------------------------------------
Four-Foot Medium Bipin......... <=4,500K............... 89
>4,500 K and <=7,000 K. 88
Two-Foot U-Shaped.............. <=4,500 K.............. 84
>4,500 K and <=7,000 K. 81
Eight-Foot Slimline............ <=4,500 K.............. 97
>4,500 K and <=7,000 K. 93
Eight-Foot High Output......... <=4,500 K.............. 92
>4,500 K and <=7,000 K. 88
Four-Foot Miniature Bipin <=4,500 K.............. 86
Standard Output. >4,500 K and <=7,000 K. 81
Four-Foot Miniature Bipin High <=4,500 K.............. 76
Output. >4,500 K and <=7,000 K. 72
------------------------------------------------------------------------
Table II.2--July 2012 Standards for Incandescent Reflector Lamps
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy lm/
inches W
----------------------------------------------------------------------------------------------------------------
40-205................... Standard Spectrum........... >2.5 >=125 V 6.8*P\0.27\
<125 V 5.9*P\0.27\
<=2.5 >=125 V 5.7*P\0.27\
<125 V 5.0*P\0.27\
----------------------------------------------------------------------------------------------------------------
40-205................... Modified Spectrum........... >2.5 \12\ >=125 V 5.8*P\0.27\
<125 V 5.0*P\0.27\
<=2.5 >=125 V 4.9*P\0.27\
<125 V 4.2*P\0.27\
----------------------------------------------------------------------------------------------------------------
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified
spectrum in 430.2.
[[Page 4049]]
2. Corrections to Codified Standards
In this final rule, DOE is correcting errors in the codified
standards for GSFLs and IRLs. In particular, DOE is correcting the
typographical errors in the sections of the CFR that lay out the GSFL
standards specified in EPCA and the IRL standards established by the
2009 Lamps Rule. Specifically, for the GSFL standards codified at 10
CFR 430.32(n)(1), the ``less than or equal to 35 W'' associated with
the 8-foot single pin (SP) slimline lamp type should instead be
associated with the 2-foot U-shaped lamp type. For 8-foot SP slimline
product class with a minimum color rendering index (CRI) of 45 and a
minimum average lamp efficacy of 80.0 lumens per watt (lm/W), the rated
wattage should be less than or equal to 65 W, not greater than 65 W.
The revised table will read as follows:
---------------------------------------------------------------------------
\12\ Shown correctly in this table; erroneously written as
``<=125V'' in the CFR.
Table II.3--GSFL Standards Prescribed by EPAct
----------------------------------------------------------------------------------------------------------------
Minimum
Lamp type Nominal lamp Minimum CRI average lamp Effective date
wattage efficacy lm/W
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin.................. >35 W 69 75.0 Nov. 1, 1995.
<=35 W 45 75.0 Nov. 1, 1995.
2-foot U-shaped...................... >35 W 69 68.0 Nov. 1, 1995.
<=35 W 45 64.0 Nov. 1, 1995.
8-foot slimline...................... >65 W 69 80.0 May 1, 1994.
<=65 W 45 80.0 May 1, 1994.
8-foot high output................... >100 W 69 80.0 May 1, 1994.
<=100 W 45 80.0 May 1, 1994.
----------------------------------------------------------------------------------------------------------------
For the IRL standards adopted by the 2009 Lamps Rule that are
codified in 10 CFR 430.32(n)(5), the minimum lamp efficacy of
5.8P\0.27\ is for lamps with a rated wattage of 40-205 W, modified
spectrum, diameter greater than 2.5 inches, and rated voltage of
``greater than or equal to 125 V'' rather than ``less than or equal to
125 V.'' The revised table will read as follows:
Table II.4--IRL Standards Adopted by the 2009 Lamps Rule
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy lm/
inches W
----------------------------------------------------------------------------------------------------------------
40-205......................... Standard Spectrum..... >2.5 >=125 V 6.8*P0.27
<125 V 5.9*P0.27
<=2.5 >=125 V 5.7*P0.27
<125 V 5.0*P0.27
----------------------------------------------------------------------------------------------------------------
40-205......................... Modified Spectrum..... >2.5 >=125 V 5.8*P0.27
<125 V 5.0*P0.27
<=2.5 >=125 V 4.9*P0.27
<125 V 4.2*P0.27
----------------------------------------------------------------------------------------------------------------
3. History of Standards Rulemaking for General Service Fluorescent
Lamps and Incandescent Reflector Lamps
As mentioned in the previous section, EPCA, as amended, established
energy conservation standards for certain classes of GSFLs and IRLs,
and required DOE to conduct two rulemaking cycles to determine whether
these standards should be amended. (42 U.S.C. 6295(i)(1) and (3)-(4))
EPCA also authorized DOE to adopt standards for additional GSFLs if
such standards were warranted. (42 U.S.C. 6295(i)(5))
DOE completed the first cycle of amendments by publishing a final
rule in the Federal Register in July 2009. 74 FR 34080 (July 14, 2009).
The 2009 Lamps Rule amended existing GSFL and IRL energy conservation
standards and adopted standards for additional GSFLs. That rule also
amended the definition of ``colored fluorescent lamp'' and ``rated
wattage,'' and adopted test procedures applicable to the newly covered
GSFLs.
The Energy Policy Act of 1992 (EPAct 1992, Pub. L. 102-486)
amendments to EPCA added as covered products IRLs with wattages of 40
watts (W) or higher. In defining the term ``incandescent reflector
lamp,'' EPAct 1992 excluded lamps with elliptical reflector (ER) and
bulged reflector (BR) bulb shapes, and with diameters of 2.75 inches or
less. Therefore, such IRLs were neither included as covered products
nor subject to EPCA's standards for IRLs.
Section 322(a)(1) of the EISA 2007 subsequently amended EPCA to
expand the Act's definition of ``incandescent reflector lamp'' to
include lamps with a diameter between 2.25 and 2.75 inches, as well as
lamps with ER, BR, bulged parabolic aluminized reflector (BPAR), or
similar bulb shapes. (42 U.S.C. 6291(30)(C)(ii) and (F)) Section 322(b)
of EISA 2007, in amending EPCA to set forth revised standards for IRLs
in new section 325(i)(1)(C), exempted from these standards the
following categories of IRLs: (1) Lamps rated 50 W or less that are
ER30, BR30, BR40, or ER40; (2) lamps rated 65 W that are BR30, BR40, or
ER40 lamps; and (3) R20 IRLs rated 45 W or less. (42 U.S.C. 6295(i)(C))
DOE refers to these three categories of lamps collectively as certain
R, ER, and BR IRLs.
DOE has concluded, for the reasons that follow, that it has the
authority under EPCA to adopt standards for these
[[Page 4050]]
R, ER, and BR IRLs, and that these lamps are covered by the directive
in 42 U.S.C. 6295(i)(3) to amend EPCA's standards for IRLs. First, by
amending the definition of ``incandescent reflector lamp'' (42 U.S.C.
6291(30)(C)(ii) and (F)), EISA 2007 effectively brought these R, ER,
and BR IRLs into the federal energy conservation standards program as
covered products, thereby subjecting them to DOE's regulatory
authority. Second, although 42 U.S.C 6295(i)(1)(C) exempts these R, ER,
and BR IRLs from the standards specified in 42 U.S.C. 6295(i)(1)(B),
EPCA directs that DOE amend the standards laid out in 42 U.S.C
6295(i)(1), which includes subparagraph (C). As a result, the statutory
text exempted these bulbs only from the standards specified in 42
U.S.C. 6295(i)(1), not from future regulation. Consequently, DOE began
considering energy conservation standards for these R, ER, and BR IRLs.
DOE initiated a new rulemaking for these products by completing a
framework document and publishing a notice announcing its availability.
75 FR 23191 (May 3, 2010). DOE held a public meeting on May 26, 2010 to
seek input from interested parties on its methodologies, assumptions,
and data sources.
To initiate the second rulemaking cycle to consider amended energy
conservation standards for GSFLs and IRLs (other than the certain R,
ER, and BR IRLs discussed in the preceding paragraphs), on September
14, 2011, DOE published a notice announcing the availability of the
framework document, ``Energy Conservation Standards Rulemaking
Framework Document for General Service Fluorescent Lamps and
Incandescent Reflector Lamps,'' and a public meeting to discuss the
proposed analytical framework for the rulemaking. 76 FR 56678. DOE also
posted the framework document on its Web site, in which DOE described
the procedural and analytical approaches DOE anticipated using to
evaluate the establishment of energy conservation standards for GSFLs
and IRLs.
DOE held the public meeting for the framework document on October
4, 2011 \13\ to present the framework document, describe the analyses
it planned to conduct during the rulemaking, seek comments from
stakeholders on these subjects, and inform stakeholders about and
facilitate their involvement in the rulemaking. At the public meeting,
and during the comment period, DOE received many comments that both
addressed issues raised in the framework document and identified
additional issues relevant to this rulemaking.
---------------------------------------------------------------------------
\13\ DOE published a notice announcing the availability of the
framework document, ``Energy Conservation Standards Rulemaking
Framework Document for General Service Fluorescent Lamps and
Incandescent Reflector Lamps,'' and a public meeting in the Federal
Register on September 14, 2011. 76 FR 56678. The framework document
and public meeting information are available at regulations.gov
under docket number EERE-2011-BT-STD-0006.
---------------------------------------------------------------------------
DOE issued the preliminary analysis for this rulemaking on February
20, 2013 and published it in the Federal Register on February 28, 2013.
78 FR 13563 (February 28, 2013). DOE posted the preliminary analysis,
as well as the complete preliminary technical support document (TSD),
on its Web site. The preliminary TSD included the results of the
following preliminary analyses: (1) Market and technology assessment;
(2) screening analysis; (3) engineering analysis; (4) energy-use
characterization; (5) product price determinations; (6) LCC and PBP
analyses; (7) shipments analysis; and (8) national impact analysis
(NIA). In the preliminary analysis, DOE described and sought comment on
the analytical framework, models, and tools (e.g., LCC and national
energy savings [NES] spreadsheets) DOE used to analyze the impacts of
energy conservation standards for GSFLs and IRLs. DOE held a public
meeting on April 9, 2013, to present the methodologies and results for
the preliminary analyses. Manufacturers, trade associations, and
environmental advocates attended the meeting. The participants
discussed multiple issues, including the methodology and results of the
market and technology assessment, screening analysis, engineering
analysis, product price determination, energy use, LCC analysis,
shipments analysis, and NIA.
In April 2014, DOE published a notice of proposed rulemaking (NOPR)
in the Federal Register proposing new and amended energy conservation
standards for GSFLs and IRLs. 79 FR 24068 (April 29, 2014). In
conjunction with the NOPR, DOE also published on its Web site the
complete TSD for the proposed rule.\14\ The NOPR TSD included updated
results of the analyses conducted in the preliminary analysis stage as
well as the following additional analyses: 1) LCC subgroup analysis, 2)
manufacturer impact analysis (MIA), 3) employment impact analysis, 4)
utility impact analysis, 5) emissions analysis, 6) monetization of
emission reduction benefits, and 7) regulatory impact analysis (RIA).
The NOPR TSD was accompanied by the LCC spreadsheet, the NIA
spreadsheet, and the MIA spreadsheet--all of which are available on
regulations.gov.\15\ In the NOPR DOE invited comment on these analyses
and related issues. DOE held a NOPR public meeting on May 1, 2014, to
hear oral comments on and solicit information relevant to the proposed
rule (hereafter the NOPR public meeting). DOE considered the comments
received in response to the NOPR after its publication and at the NOPR
public meeting when developing this final rule, and responds to these
comments in this rule.
---------------------------------------------------------------------------
\14\ The NOPR TSD is available at regulations.gov under docket
number EERE-2011-BT-STD-0006.
\15\ Supporting spreadsheets for the NOPR TSD are available at
regulations.gov under docket number EERE-2011-BT-STD-0006.
---------------------------------------------------------------------------
4. Test Procedure
EPCA sets forth generally applicable criteria and procedures for
DOE's adoption and amendment of test procedures. (42 U.S.C. 6293)
Manufacturers of covered products must use these test procedures to
certify to DOE that their product complies with EPCA energy
conservation standards and to quantify the efficiency of their product.
Similarly, DOE uses the test procedure to determine compliance with
energy conservation standards. DOE's test procedures for fluorescent
and incandescent reflector lamps are set forth in title 10 of the CFR,
part 430, subpart B, appendix R. These test procedures provide
instructions for measuring GSFL and IRL performance, largely by
incorporating industry standards. The test procedures were updated in a
final rule published in July 2009. 74 FR 31829 (July 6, 2009). The rule
updated citations to industry standards and made several other
modifications. DOE further amended the test procedures to update
references to industry standards for GSFLs in a final rule published in
January 2012. 77 FR 4203 (January 27, 2012).
a. Standby and Off Mode Energy Consumption
EPCA requires energy conservation standards adopted for a covered
product after July 1, 2010 to address standby mode and off mode energy
use. (42 U.S.C. 6295(gg)(3)) EPCA defines active mode as the condition
in which an energy-using piece of equipment is connected to a main
power source, has been activated, and provides one or more main
functions. (42 U.S.C. 6295)(gg)(1)(A)) Standby mode is defined as the
condition in which an energy-using piece of equipment is connected to a
main power source and offers one or more of the following user-oriented
or protective functions: Facilitating the activation or
[[Page 4051]]
deactivation of other functions (including active mode) by remote
switch (including remote control), internal sensor, or timer; or
providing continuous functions, including information or status
displays (including clocks) or sensor-based functions. Id. Off mode is
defined as the condition in which an energy-using piece of equipment is
connected to a main power source, and is not providing any standby or
active mode function. Id.
To satisfy the EPCA definitions of standby mode and off mode (42
U.S.C. 6295(gg)(1)), the lamp must not be providing any active mode
function (i.e., emitting light). However, to reach such a state, the
lamp must be entirely disconnected from the main power source (i.e.,
switched off), thereby not satisfying the requirements of operating in
off mode or standby mode. Further, neither GSFLs nor IRLs covered under
this rulemaking provide any secondary user-oriented or protection
functions or continuous standby mode functions. Thus, these lamps do
not satisfy the EPCA definition of standby mode. While EPCA allows DOE
to amend the mode definitions (42 U.S.C. 6295(gg)(1)(B)), DOE believes
that the energy use of GSFLs and IRLs is accounted for entirely in the
active mode. Therefore, DOE is not addressing lamp operation in the
standby and off modes in this rulemaking.
III. General Discussion
A. Product Classes and Scope of Coverage
When evaluating and establishing energy conservation standards, DOE
divides covered products into product classes by the type of energy
used or by capacity or other performance-related features that
justifies a different standard. In making a determination whether a
performance-related feature justifies a different standard, DOE must
consider such factors as the utility to the consumer of the feature and
other factors DOE determines are appropriate. (42 U.S.C. 6295(q)) For
further details on the scope of coverage for this rulemaking, see
section V. For further details on product classes, see section VI.C and
chapter 3 of the final rule TSD.
B. Technological Feasibility
1. General
In each energy conservation standards rulemaking, DOE conducts a
screening analysis based on information gathered on all current
technology options and prototype designs that could improve the
efficiency of the products or equipment that are the subject of the
rulemaking. As the first step in such an analysis, DOE develops a list
of technology options for consideration in consultation with
manufacturers, design engineers, and other interested parties. DOE then
determines which of those means for improving efficiency are
technologically feasible. DOE considers technologies incorporated in
commercially available products or in working prototypes to be
technologically feasible. 10 CFR part 430, subpart C, appendix A,
section 4(a)(4)(i).
After DOE has determined that particular technology options are
technologically feasible, it further evaluates each technology option
in light of the following additional screening criteria: (1)
Practicability to manufacture, install, and service; (2) adverse
impacts on product utility or availability; and (3) adverse impacts on
health or safety. 10 CFR part 430, subpart C, appendix A, section
4(a)(4)(ii)-(iv). Section VI.B of this notice discusses the results of
the screening analysis for GSFLs and IRLs, particularly the designs DOE
considered, those it screened out, and those that are the basis for the
trial standard levels (TSLs) in this rulemaking. For further details on
the screening analysis for this rulemaking, see chapter 4 of the final
rule TSD.
2. Maximum Technologically Feasible Levels
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max-tech'') improvements in energy efficacy for GSFLs and
IRLs, using the design parameters for the most efficient products
available on the market or in working prototypes. (See chapter 5 of the
final rule TSD.) The max-tech levels that DOE determined for this
rulemaking are described in section VI.D.2.f and VI.D.3.d, respectively
for GSFLs and IRLs, of this final rule.
C. Energy Savings
1. Determination of Savings
For each TSL, DOE projected energy savings from the products that
are the subject of this rulemaking purchased in the 30-year period that
begins in the year of compliance with amended standards (2018-
2047).\16\ The savings are measured over the entire lifetime of
products purchased in the 30-year analysis period.\17\ DOE quantified
the energy savings attributable to each TSL as the difference in energy
consumption between each standards case and the base case. The base
case represents a projection of energy consumption in the absence of
amended mandatory efficiency standards and the standards case
represents a projection of energy consumption if amended standards take
effect. As described in section VI.I of this notice, the projections
start from the current efficiency distribution on the market and
consider various market forces, in addition to amended standards, that
may affect future demand for more efficient products.
---------------------------------------------------------------------------
\16\ DOE also presents a sensitivity analysis that considers
impacts for products shipped in a 9-year period.
\17\ In the past DOE presented energy savings results for only
the 30-year period that begins in the year of compliance. In the
calculation of economic impacts, however, DOE considered operating
cost savings measured over the entire lifetime of products purchased
in the 30-year period. DOE has chosen to modify its presentation of
national energy savings to be consistent with the approach used for
its national economic analysis.
---------------------------------------------------------------------------
DOE used its NIA spreadsheet model to estimate energy savings from
amended standards for the products that are the subject of this
rulemaking. The NIA spreadsheet model (described in section VI.J of
this notice) calculates energy savings in site energy, which is the
energy directly consumed by products at the locations where they are
used. For electricity, DOE reports national energy savings in terms of
the savings in the energy that is used to generate and transmit the
site electricity. For electricity and natural gas and oil, DOE also
calculates full-fuel-cycle (FFC) energy savings. As discussed in DOE's
statement of policy and notice of policy amendment, the FFC metric
includes the energy consumed in extracting, processing, and
transporting primary fuels (i.e., coal, natural gas, petroleum fuels),
and thus presents a more complete picture of the impacts of energy-
efficiency standards. 76 FR 51281 (August 18, 2011), as amended at 77
FR 49701 (August 17, 2012).
To calculate this quantity, DOE derives annual conversion factors
from the model used to prepare the Energy Information Administration's
(EIA) most recent Annual Energy Outlook (AEO). For FFC energy savings,
DOE's approach is based on the calculation of an FFC multiplier for the
electricity used by covered products or equipment. For more
information, see section VI.L.
[[Page 4052]]
2. Significance of Savings
To adopt standards for a covered product, DOE must determine that
such action would result in ``significant'' energy savings. 42 U.S.C.
6295(o)(3)(B). Although the term ``significant'' is not defined in the
Act, the U.S. Court of Appeals, in Natural Resources Defense Council v.
Herrington, 768 F.2d 1355, 1373 (D.C. Cir. 1985), indicated that
Congress intended ``significant'' energy savings in the context of EPCA
to be savings that were not ``genuinely trivial.'' The energy savings
for these adopted standards of 2.5 quads over a 30-year product
purchase period (presented in section VII.B.3) are nontrivial, and,
therefore, DOE considers them ``significant'' within the meaning of
section 325 of EPCA.
D. Economic Justification
1. Specific Criteria
EPCA provides seven factors to be evaluated in determining whether
a potential energy conservation standard is economically justified. (42
U.S.C. 6295(o)(2)(B)(i)) The following sections discuss how DOE has
addressed each of those seven factors in this rulemaking.
a. Economic Impact on Manufacturers and Consumers
In determining the impacts of a potential amended standard on
manufacturers, DOE conducts a MIA, as discussed in section VI.K. DOE
first uses an annual cash-flow approach to determine the quantitative
impacts. This step includes both a short-term assessment--based on the
cost and capital requirements during the period between when a
regulation is issued and when entities must comply with the
regulation--and a long-term assessment over a 30-year period. The
industry-wide impacts analyzed include INPV, which values the industry
based on expected future cash flows; cash flows by year; changes in
revenue and income; and other measures of impact, as appropriate.
Second, DOE analyzes and reports the impacts on different types of
manufacturers, including impacts on small manufacturers. Third, DOE
considers the impact of standards on domestic manufacturer employment
and manufacturing capacity, as well as the potential for standards to
result in plant closures and loss of capital investment. Finally, DOE
takes into account cumulative impacts of various DOE regulations and
other regulatory requirements on manufacturers.
For individual consumers, measures of economic impact include the
changes in LCC and payback period (PBP) associated with new or amended
standards. These measures are discussed further in the following
section. For consumers in the aggregate, DOE also calculates the
national net present value of the economic impacts applicable to a
particular rulemaking. DOE also evaluates the LCC impacts of potential
standards on identifiable subgroups of consumers that may be affected
disproportionately by a national standard.
b. Savings in Operating Costs Compared to Increase in Price
EPCA requires DOE to consider the savings in operating costs
throughout the estimated average life of the covered product compared
to any increase in the price of the covered product that are likely to
result from the imposition of the standard. (42 U.S.C.
6295(o)(2)(B)(i)(II)) DOE conducts this comparison in its LCC and PBP
analysis.
The LCC is the sum of the purchase price of a product (including
its installation) and the operating expense (including energy,
maintenance, and repair expenditures) discounted over the lifetime of
the product. To account for uncertainty and variability in specific
inputs, such as product lifetime and discount rate, DOE uses a
distribution of values, with probabilities attached to each value. For
its analysis, DOE assumes that consumers will purchase the covered
products in the first year of compliance with amended standards.
The LCC savings and the PBP for the considered efficacy levels are
calculated relative to the baseline. DOE's LCC and PBP analysis is
discussed in further detail in section VI.G.
c. Energy Savings
Although significant conservation of energy is a separate statutory
requirement for adopting an energy conservation standard, EPCA requires
DOE, in determining the economic justification of a standard, to
consider the total projected energy savings that are expected to result
directly from the standard. (42 U.S.C. 6295(o)(2)(B)(i)(III)) As
discussed in section VI.J, DOE uses the NIA spreadsheet to project
national site energy savings.
d. Lessening of Utility or Performance of Products
In establishing classes of products, and in evaluating design
options and the impact of potential standard levels, DOE evaluates
standards that would not lessen the utility or performance of the
considered products. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) Based on data
available to DOE, the standards adopted in this rule would not reduce
the utility or performance of the products under consideration in this
rulemaking.
e. Impact of Any Lessening of Competition
EPCA directs DOE to consider the impact of any lessening of
competition, as determined in writing by the Attorney General, that is
likely to result from a proposed standard. (42 U.S.C.
6295(o)(2)(B)(i)(V) It also directs the Attorney General to determine
the impact, if any, of any lessening of competition likely to result
from a standard and to transmit such determination to the Secretary
within 60 days of the publication of a proposed rule, together with an
analysis of the nature and extent of the impact. (42 U.S.C.
6295(o)(2)(B)(ii)) DOE transmitted a copy of its proposed rule to the
Attorney General with a request that the Department of Justice (DOJ)
provide its determination on this issue. DOJ's response, that the
proposed energy conservation standards are unlikely to have a
significant adverse impact on competition, is reprinted at the end of
this notice.
f. Need for National Energy Conservation
In evaluating the need for national energy conservation, DOE
expects that the energy savings from amended standards are likely to
provide improvements to the security and reliability of the nation's
energy system. Reductions in the demand for electricity also may result
in reduced costs for maintaining the reliability of the nation's
electricity system. DOE conducts a utility impact analysis to estimate
how standards may affect the nation's needed power generation capacity.
The amended standards also are likely to result in environmental
benefits in the form of reduced emissions of air pollutants and
greenhouse gases primarily associated with fossil-fuel based energy
production. DOE reports the emissions impacts from these standards, and
from each TSL it considered, in section VII.B.6 of this notice. DOE
also reports estimates of the economic value of emissions reductions
resulting from the considered TSLs, as discussed in section VII.B.7.
g. Other Factors
EPCA allows the Secretary of Energy, in determining whether a
standard is economically justified, to consider any other factors that
the Secretary deems to be relevant. (42 U.S.C. 6295(o)(2)(B)(i)(VII))
[[Page 4053]]
2. Rebuttable Presumption
As set forth in 42 U.S.C. 6295(o)(2)(B)(iii), EPCA creates a
rebuttable presumption that an energy conservation standard is
economically justified if the additional cost to the consumer of a
product that meets the standard is less than three times the value of
the first year's energy savings resulting from the standard, as
calculated under the applicable DOE test procedure. DOE's LCC and PBP
analyses generate values used to calculate the effect potential amended
energy conservation standards would have on the payback period for
consumers. These analyses include, but are not limited to, the 3-year
payback period contemplated under the rebuttable-presumption test. In
addition, DOE routinely conducts an economic analysis that considers
the full range of impacts to consumers, manufacturers, the nation, and
the environment, as required under 42 U.S.C. 6295(o)(2)(B)(i). The
results of this analysis serve as the basis for DOE's evaluation of the
economic justification for a potential standard level (thereby
supporting or rebutting the results of any preliminary determination of
economic justification). The rebuttable-presumption payback calculation
is discussed in section VII.B.1.a of this final rule.
IV. Issues Affecting Rulemaking Schedule
DOE received several comments on the rulemaking schedule. Appliance
Standards Awareness Project (ASAP) and the Energy Efficiency
Organizations (EEOs) supported the rulemaking schedule as presented in
the NOPR. However, ASAP noted that DOE missed the legally required
legislative deadline and urged DOE not to push the rulemaking any later
than planned. (ASAP, Public Meeting Transcript, No. 49 at p. 29; \18\
EEOs, No. 55 at p. 2)
---------------------------------------------------------------------------
\18\ A notation in this form provides a reference for
information that is in the docket of DOE's rulemaking to develop
energy conservation standards for GSFLs and IRLs (Docket No. EERE-
2011-BT-STD-0006), which is maintained at www.regulations.gov. This
notation indicates that the statement preceding the reference is
document number 49 in the docket for the GSFL and IRL energy
conservation standards rulemaking, and appears at page 29 of that
document.
---------------------------------------------------------------------------
Sofie E. Miller commented that the 2009 Lamps Rule required
compliance on July 14, 2012 and for certain GSFL product classes, many
manufacturers were granted a stay of enforcement, which is still in
effect. Therefore, the full impact of the 2009 Lamps Rule on the
lighting market is unknown. Further, Miller noted that manufacturers
have expressed concern that the short period between the rulemakings
will have a severe and negative impact on manufacturers, who may not be
able to recover investments in new technologies or to develop products
meeting even higher standards than those in the 2009 Lamps Rule. While
DOE is statutorily required to make a determination about whether to
update these standards, it may make the most sense for DOE to delay
proposing new standards until the full effect of its previous standards
is known, and DOE should initiate that process by conducting a
retrospective review of the 2009 Lamps Rule. (Miller, No. 50 at p. 10)
DOE is conducting this rulemaking to satisfy the EPCA requirement
for a second review of the GSFL and IRL standards that were finalized
in the 2009 Lamps Rule and required compliance July 2012. DOE
understands that Office of Hearing and Appeals (OHA) has granted 16
manufacturers 2-year waivers from standards for their 700 series T8
products that expire in 2014. Because standards from this rulemaking
would become effective after these waivers granted to individual
manfacturers have expired and the products granted waivers would be
subject to standards, DOE has conducted its analysis assuming that the
waivers will not be in place. Further, at the time of the analysis of
the final rule, most of the waivers had expired and not been renewed.
Regarding this rulemaking assessing the full impact of the 2009
Lamps Rule, the analysis in this final rule was updated and finalized
almost two years after the July 2012 standards required compliance,
reflecting the most recent data available. DOE conducted a survey of
product offerings for this final rule and identified a few new covered
products since the NOPR analysis which were included in this final rule
analysis. Therefore, DOE finds that the analysis in this final rule
adequately assesses and captures the impacts of the July 2012 standards
for these products and sees no reason to delay in adopting the
appropriate standards resulting from it and requiring compliance three
years after the publication of the final rule.
V. Issues Affecting Scope
A. Clarifications of General Service Fluorescent Lamp Definition
The scope of this rulemaking for GSFLs is defined by the terms
``fluorescent lamp'' and ``general service fluorescent lamp.'' 10 CFR
430.2 The definition of general service fluorescent lamp includes
certain exemptions. DOE has received several questions on the
application of these exemptions. Therefore, DOE evaluated each
exemption and determined that the following exemption categories could
be further clarified: ``impact-resistant fluorescent lamps,''
``reflectorized or aperture lamps,'' ``fluorescent lamps designed for
use in reprographic equipment,'' and ``lamps primarily designed to
produce radiation in the ultraviolet region of the spectrum.'' For
these exemption categories, the terminology was either not defined
elsewhere or the application of the exemption could be further
clarified. Using product literature and industry reference sources, DOE
proposed clarifications of these exemptions in the NOPR. DOE did not
receive any comments on the proposed clarifications. However, the
National Electrical Manufacturers Association (NEMA) did state that
they support all existing exemptions for fluorescent products. (NEMA,
No. 54 at p. 11) DOE therefore is maintaining the clarifications to the
exemption definitions.
Additionally, DOE proposed clarifications of the terms ``designed''
and ``marketed'' as applied to definitions of lighting products covered
under DOE standards. These terms are generally used to ensure that
exemptions from applicable standards apply only to lamps used in
certain intended applications and/or functions. Therefore, DOE
considered the terms ``designed,'' ``designated,'' ``designation,''
``designated and marketed,'' and ``designed and marketed,'' for covered
lighting products to mean that manufacturers explicitly state the
intended application of the lamp in a publicly available document
(e.g., product literature, catalogs, packaging labels, and labels on
the product itself). In the NOPR DOE had specified the lamp types to
which the proposed definition should apply as follows: Fluorescent lamp
ballasts; fluorescent lamps; general service fluorescent lamps; general
service incandescent lamps; incandescent lamps; incandescent reflector
lamps; medium base compact fluorescent lamps; and specialty application
mercury vapor lamp ballasts. In this final rule, in addition to these
lamp types, the definition will also apply to ``general service lamps''
which are also a lamp type covered by DOE.
The term ``designed and marketed'' is also used in the general
service fluorescent lamp definition which specifies that all lamp types
exempted must be ``designed and marketed'' for the nongeneral
application they are
[[Page 4054]]
intended to serve. One of these exemptions is lamps with a CRI of 87 or
greater (hereafter ``high CRI lamps'').
The California Investor Owned Utilities (CA IOUs) commented that
the definition of ``designed and marketed'' should relate to the way
products are represented in the marketplace and might be utilized. (CA
IOUs, Public Meeting Transcript, No. 49 at p. 28) EEOs predicted that
DOE's method of adding a definition of ``designed and marketed,'' as
proposed in the NOPR, would do nothing to prevent or dissuade
manufacturers from continuing to sell high CRI lamps as inexpensive,
extremely inefficient alternatives to GSFLs subject to federal
standards. (EEOs, No. 55 at pp. 2-4) EEOs and the National Energy
Efficiency Partnership (NEEP) commented that the exemption for high CRI
GSFLs is a loophole that is undercutting the current federal standards
and, if not addressed, would undercut the standards ultimately adopted
by this rulemaking. EEOs, NEEP, and Earthjustice reported that they
have encountered numerous examples of high CRI lamps that are being
marketed as suitable general service lamps. NEEP noted that the market
responded to the 2009 Lamps Rule by increased offerings of high CRI T12
lamps. These products offer no energy savings and in the case of full-
wattage 40 W lamps, actually increase energy usage. EEOs found that
almost all of the 4ft T12 bipin GSFLs sold online were high CRI,
costing as little as $1.50 per lamp when sold in multi-packs and having
efficacy ratings as low as 54 lm/W. Compared to the 92.4 lm/W proposed
in the NOPR for lamps at or below a correlated color temperature (CCT)
of 4,500 K, EEOs calculated that a single high CRI 2600 lumen lamp,
with an average rated life of 36,000 hours, could use 720 kWh more than
a regulated lamp over the course of its life. (EEOs, No. 55 at pp. 2-4;
NEEP, No. 57 at pp. 2-3; Earthjustice, Public Meeting Transcript, No.
49 at p. 27; Earthjustice, No. 52 at pp. 1-3)
ASAP commented that DOE consider what modifications to the high CRI
definition could be made to address the use of high CRI lamps in
general service applications. (ASAP, Public Meeting Transcript, No. 49
at pp. 28-29) Earthjustice also noted that a high CRI lamp marketed for
general lighting applications but fails to meet federal minimum
efficacy levels would be violating energy conservation standards and
the marketing claims may constitute an unfair or deceptive act or
practice in violation of section 5(a)(1) of the Federal Trade
Commission Act, 15 U.S.C. 45(a)(1). Earthjustice stated that DOE should
work with the Federal Trade Commission to develop guidance on the
appropriate marketing of high CRI fluorescent lamps. Earthjustice
suggested that DOE should also investigate whether high CRI lamps meet
EPCA's thresholds for coverage and energy conservation standards.
(Earthjustice, No. 52 at pp. 3-4)
The definition of ``designed and marketed'' adopted in this rule
refers to how the lamp is represented in the market and should be
utilized by consumers. DOE believes that within the scope of this
rulemaking it is implementing the appropriate changes in the CFR to
clarify the exemption of high CRI products. It is not within the scope
of DOE's authority in this rulemaking to modify the thresholds set by
the current CRI exemptions for GSFLs.
Earthjustice commented the proposed definition of ``designed and
marketed'' states that the intended application must be specified in a
public document rather than all public documents. Earthjustice noted
this as a problem specifically for high CRI lamps as it would allow
manufacturers to explain the high CRI application in one document while
still marketing the product as for general lighting applications in
other documents. Earthjustice suggested, and EEOs concurred, that DOE
should revise the definition of ``designed and marketed'' to provide
that ``the intended application of the lamp is clearly and
conspicuously stated in all publicly available documents (e.g., product
literature, catalogs, packaging labels, and labels on the product
itself).'' (Earthjustice, No. 52 at pp. 3-4; EEOs, No. 55 at pp. 2-4)
DOE agrees that the definition proposed in the NOPR for ``designed
and marketed'' can be strengthened and therefore, in this final rule
will add the word ``clearly,'' and specify ``all publicly available
documents'' so it reads ``means that the intended application of the
lamp is clearly stated in all publicly available documents (e.g.,
product literature, catalogs, and packaging labels).'' DOE believes
that it is important that all public disclsures be consistent about the
intended use or application of the lamp. In addition, DOE notes that
the Federal Trade Commision prescribes certain energy-related labels
for lighting products, such as general service fluorescent lamps and
DOE will also consider those labels along with any other voluntary
marking the manufacturers currently put on their lamps when determining
whether a particular lamp is ``designed'' and ``marketed'' for a
specific application. DOE reiterates that it is not adopting any new
labeling requirements for lamps covered by this rulemaking.
B. General Service Fluorescent Lamp Scope of Coverage
1. Additional General Service Fluorescent Lamp Types
In this rulemaking, DOE evaluated energy-efficiency standards for
additional GSFLs beyond those for which standards have already been
established. (42 U.S.C. 6295(i)(5)) Any additional GSFLs considered for
coverage under standards must meet the definition of a fluorescent lamp
in 42 U.S.C. 6291(30)(A); satisfy the majority of fluorescent lighting
applications; not be within the exclusions specified in 42 U.S.C.
6291(30)(B); and not already be subject to energy conservation
standards. 73 FR 13620, 13629 (March 13, 2008). For each additional
GSFL that meets these criteria, DOE then assessed whether standards
could result in significant energy savings and are technologically
feasible and economically justified. Standards for any applicable
additional GSFLs are adopted based on the same criteria used to set new
or amended standards for products pursuant to 42 U.S.C. 6295(o).
Using these criteria, DOE evaluated whether the following GSFL
types warranted coverage under standards: 1) pin base compact
fluorescent lamps (CFLs); 2) non-linear fluorescent lamps (e.g.,
circline); and 3) fluorescent lamps with alternate lengths (e.g., 2-,
3-, and 5-foot lamps).
For pin base CFLs, DOE determined that these lamp types fall within
the definition of ``general service lamps,'' which excludes GSFLs. (42
U.S.C. 6291(30)(BB)) Therefore, these lamp types cannot be considered
under this rulemaking. DOE is evaluating these lamp types in the
rulemaking for general service lamps. Documents related to this
rulemaking can be found on regulations.gov, docket number EERE-2013-BT-
STD-0051.
For non-linear fluorescent lamps, DOE considered circline
fluorescent lamps, the primary shape not currently covered under
standards. Using the miscellaneous category of fluorescent lamps
reported by the 2010 U.S. Lighting Market Characterization \19\ (2010
LMC), DOE determined that the market share and energy consumption for
these lamps was not substantive. The 2010 LMC's miscellaneous category
composed 2.1 percent of lighting and
[[Page 4055]]
consumed 4 terrawatt-hours (TWh) of electricity in 2010. Circline lamps
are only a portion of the miscellaneous category, which also includes
all fluorescents other than T5 linear and T8 and T12 linear and U-
shaped lamps, as well as fluorescent lamps with unknown
characteristics. Interviews with manufacturers also confirmed the low
market share of these lamp types. Therefore, DOE concluded that
coverage should not be expanded to non-linear fluorescent lamps as
standards would not likely result in significant energy savings.
---------------------------------------------------------------------------
\19\ U.S. Department of Energy. 2010 U.S. Lighting Market
Characterization. January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
---------------------------------------------------------------------------
For linear lengths not already covered by standards, DOE focused on
linear medium bipin (MBP) fluorescent lamps ranging from 1 to 6 feet,
with the exception of the 4-foot MBP, which is already subject to
standards. DOE's analysis showed that 5- and 6-foot lengths comprise a
very low percentage of the linear MBP product offerings. For the T8 MBP
lamps with lengths less than 4 feet, according to the 2010 LMC, these
lamps comprised about 0.7 percent of the linear fluorescent lamp market
and 0.2 percent of all installed lighting and consumed 1 TWh of
electricity in 2010. Feedback from manufacturers also indicated a low
market share for these lamp types.
NEMA supported DOE's decision not to include additional lamp types,
such as 2-foot linear lamps, in the scope of the regulation agreeing
that such lamps have low sales volume and low energy use. (NEMA, No. 54
at p. 11) ASAP stated it understood DOE's reasoning for not covering 2-
foot linear fluorescent lamps based on the 2010 LMC. However, ASAP
noted and CA IOUs concurred that 2-foot lamps is a growing market and
that DOE should address this in the final rule. (ASAP, Public Meeting
Transcript, No. 49 at pp. 19-20; CA IOUs, Public Meeting Transcript,
No. 49 at p. 20)
EEOs and CA IOUs commented that DOE should include and set efficacy
standards for 2-foot linear lamps as part of the rulemaking, finding
DOE's assertion that linear fluorescent lamps shorter than 4 feet do
not comprise a sufficiently large share of annual lamp sales and energy
use to warrant coverage unconvincing. EEOs argued that DOE used
outdated shipment data from the 2010 LMC, which was not specific to 2-
foot linear GSFLs, to estimate sales and energy savings potential. EEOs
and CA IOUS stated as this data was gathered prior to the effective
date of the last round of GSFL standards it does not include the market
impact from these standards. Further, EEOs and CA IOUs voiced concern
over DOE's continued use of the 2010 LMC data instead of the newer
shipment data from Vermont and California. CA IOUs noted that in
Vermont study (2011 Vermont Market Characterization and Assessment
Study \20\), 2-foot lamps were by far the most common lamp length
behind 4-foot lamps, and more common than many of the other product
classes currently being covered by standards. While EEOs recognized
that this data only represents a small portion of the overall lighting
market, EEOs stated that using the field survey is better than relying
on unreliable and outdated information from the 2010 LMC. (EEOs, No. 55
at pp. 5-6; CA IOUs, No. 56 at p. 4)
---------------------------------------------------------------------------
\20\ Navigant Consulting, Inc. 2011 Vermont Market
Characterization and Assessment Study. October 2012. Available at
http://publicservice.vermont.gov/sites/psd/files/Topics/Energy_Efficiency/EVT_Performance_Eval/VT%20CI%20Existing%20Buildings%20Market%20Assessment%20and%20Characterization_2012-10-6_FINAL.pdf.
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DOE found using the 2010 LMC data to determine whether the 2-foot
linear fluorescent lamps have a substantial market share and could
result in significant energy savings is more accurate than relying on
data from the Vermont study. The Vermont study is specific to a region
and states that it was intended to develop the baseline data that
characterizes the existing building and equipment stock in the Vermont
business sector and covers the period of July 2011 to July 2012.\21\
The study uses on-site surveys of 120 existing buildings for its
primary data.\22\ The 2010 LMC study captures all lighting installed in
the U.S. in stationary applications during 2010.\23\ The 2010 LMC
groups linear fluorescent lamps by shape and length, and DOE used the
T8 lamps with lengths less than 4 feet category to assess the 2-foot
linear fluorescent market. Therefore, because this category includes
more than just the 2-feet lengths, DOE's market estimates for the 2-
foot linear fluorescent lamps are likely conservative. Further, the
2009 Lamps Rule became effective September 14, 2009 and required
compliance July 14, 2012. Therefore, the Vermont study that was
executed before compliance was required does not offer any added
benefit.
---------------------------------------------------------------------------
\21\ 2011 Vermont Study, 1.
\22\ 2011 Vermont Study, 3.
\23\ 2010 LMC Study, 2.
---------------------------------------------------------------------------
CA IOUs noted that when using the 2010 LMC data, DOE excluded 2-
foot T12 lamps from its total on the premise that the market will
likely shift away from T12s due to strengthened ballast standards. CA
IOUs agreed that the market will shift away from T12s, however, they
predicted that all of these lamp sales would likely become 2-foot T8
sales. DOE therefore should have counted 2-foot T12 shipments towards
the total 2-foot lamp estimates. (CA IOUs, No. 56 at p. 4)
DOE excluded T12 lamps from this analysis to reflect future market
trends. The 2011 final rule amending energy conservation standards for
fluorescent lamp ballasts (hereafter the ``2011 Ballast Rule''), which
will require compliance on November 14, 2014, set standards difficult
for T12 ballasts to meet.\24\ 76 FR 70548 (Nov. 14, 2011). Due to these
standards and because historical shipments of most T12 lamps have been
decreasing steadily, a trend confirmed in manufacturer feedback from
interviews, DOE determined the market will likely shift away from T12
lamps. However, even if there were a shift from 2-foot linear T12 to 2-
foot linear T8 lamps it would not be significant, as the T12 lamps with
lengths less than 4 feet comprise only 0.6 percent of the linear
fluorescent market and 0.2 percent of all installed lighting.
---------------------------------------------------------------------------
\24\ The full text and all related documents of the 2011 Ballast
Rule can be found on regulations.gov, docket number EERE-2007-BT-
STD-0016 at www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-
0016.
---------------------------------------------------------------------------
EEOs reflected further on DOE's argument that 2-foot linear GSFLs
are uncommon and not a large percentage of the lighting market. While
EEOs agreed it is undoubtedly true that 2-foot linear GSFLs sell in
much smaller volumes than 4-foot GSFLs, EEOs contended and CA IOUs
agreed that regulating 2-foot linear GSFLs sales that are a small
fraction of the volume of the 4-foot GSFLs lamps could still yield
significant energy savings, especially as the baseline 2-foot linear
lamps are extremely inefficient. Specifically, for 2-foot linear
fluorescent lamps, EEOs found efficacies of 58 lm/W for T12 lamps, 77
lm/W for standard T8 lamps, and 88 lm/W for more efficient T8 lamps. By
comparison, 2-foot U-shaped GSFLs which are subject to current
standards have efficacies that range from 85 to 94 lm/W. (EEOs, No. 55
at pp. 5-6; CA IOUs, No. 56 at p. 4) EEOs noted that in interviews,
manufacturers told DOE that 2-foot linear GSFLs are used in kitchens,
bathrooms, vanity lighting, hospitality applications, cabinets, and to
round out edges of ceilings in commercial spaces, and the Edison
Electric Institute had noted that these lamps are used in task
lighting. EEOs and CA IOUs additionally argued that many 2x2 fixtures
are retrofitted to 2-foot linear lamps, replacing existing U-bend
lamps. EEOs also cautioned that following the exemption of certain ER
and BR IRLs from standards, the sales of
[[Page 4056]]
ER, BR lamps increased. EEOs suggested that DOE may be making the same
mistake by not covering 2-foot linear GSFLs. (EEOs, No. 55 at pp. 5-6)
In order to extend the scope to an additional lamp type, DOE must
consider the potential energy savings that would result from regulating
the lamp type under consideration. (42 U.S.C. 6295(o)) Based on its
assessment of market share, trends, and product offerings, DOE does not
find that significant energy savings will result from a standard for 2-
foot linear fluorescent lamps.
DOE's review of 2-foot fluorescent lamp product offerings indicated
that the majority of T8 products are offered in 17 W with minimal
reduced wattage options and the T12 products are offered in 20 W.
Therefore, any likely savings from standards would come from more
efficacious T8 systems replacing T12 systems. However, as noted
previously, the 2011 Ballast Rule enacts standards that will be
difficult for T12 ballasts to meet and likely result in a shift away
from T12 products.
As mentioned, using the relevant data in the 2010 LMC and observing
the limited product offerings, DOE determined that the market share for
2-foot linear fluorescents is very low. Additionally, DOE compared the
market share reported for the less than 4 feet T8 lamps in 2000 LMC
compared to the 2010 LMC. From 2000 to 2010 the market of less than 4
feet T8 lamps declined from 1.5 to 0.7 percent of the linear
fluorescent market and 0.5 to 0.2 percent of the entire lighting
market. Further, the inventory of less than 4 feet T8 lamps declined by
about 52 percent from 2000 to 2010 based on the LMC reports for those
years. Therefore, DOE finds that the 2-foot linear lamps not only
currently comprise a low market share but will likely not experience
growth and therefore, will not result in significant energy savings.
Regarding a potential shift to the 2-foot linear lamps, while
manufacturer feedback noted the applications in which 2-foot linear
lamps can be utilized, it also indicated that the market share of the
2-foot linear fluorescent lamps was not likely to increase. Further,
the noted applications such as cabinets or hospitality lighting
indicate that this lamp type is used in specific spaces and therefore
would likely have limited growth in market share.
Therefore, DOE maintains its conclusion not to include the 2-foot
linear fluorescent lamp type in the scope of this rulemaking.
2. Additional General Service Fluorescent Lamp Wattages
DOE specifies a certain minimum wattage for lamp types included in
the definition of ``fluorescent lamp.'' In this rulemaking, DOE also
evaluates whether coverage should be extended to additional wattages of
these lamp types. (42 U.S.C. 6295(i)(5)) As part of this assessment,
DOE reviewed product offerings for covered lamp types to determine if
any new, lower wattage products had been introduced since publication
of the 2009 Lamps Rule. In the NOPR, DOE proposed extending coverage to
the following reduced wattage lamps: 49 W, 50 W, 51 W 8-foot SP
slimline, 25 W 4-foot T5 MiniBP standard output (SO), and 44 W, 47 W 4-
foot T5 MiniBP HO lamps. 79 FR at 24085 (April 29, 2014) DOE currently
covers 8-foot SP slimline lamps with wattages of 52 W or more; 4-foot
T5 MiniBP SO lamps with wattages of 26 W or more; and 4-foot T5 MiniBP
HO lamps with wattages of 49 W or more. These reduced wattage lamps are
generally more efficacious than their full-wattage counterparts are and
offer the potential for increased energy savings. DOE did not receive
any comments regarding the proposed additional wattages for inclusion
in GSFL scope in response to the NOPR.
Therefore, DOE is extending coverage to the following GSFLs in the
final rule:
8-foot SP slimline lamps with wattages >= 49 W and < 52 W;
4-foot T5 MiniBP SO lamps with wattages >= 25 W and < 26
W; and
4-foot T5 MiniBP HO lamps with wattages >= 44 W and < 49
W.
C. Incandescent Reflector Lamp Scope of Coverage
1. Incandescent Reflector Lamp Types
In this rulemaking, DOE does not consider the following IRL types:
(1) lamps rated 50 W or less that are ER30, BR30, BR40, or ER40; (2)
lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20 IRLs
rated 45 W or less. (42 U.S.C. 6295(i)(C)) These IRLs referred to
collectively as certain R, ER, and BR IRLs are the subject of a
separate rulemaking on which further information can be found on
regulations.gov under docket ID EERE-2010-BT-STD-0005 at
www.regulations.gov/#!docketDetail;D=EERE-2010-BT-STD-0005. DOE has
suspended activity on this rulemaking as a result of section 322 of
Public Law (Pub. L.) 113-76 (January 17, 2014) (hereafter,
``Consolidated Appropriations Act, 2014''), which prohibits DOE from
using appropriated funds to implement or enforce standards for ER, BR,
and BPAR IRLs. DOE received several comments on the exclusion of the
certain R, ER, BR lamps from this rulemaking and DOE's interpretation
of the Consolidated Appropriations Act, 2014.
NEMA stated its support for all existing exemptions for IRL
products and agreed with DOE's approach to address exempted BR lamps in
a separate rulemaking when funding is available. (NEMA, No. 54 at p.
10-11) Earthjustice, however, commented DOE is obligated to include the
certain R, ER, and BR IRLs in this rulemaking. Earthjustice remarked
that DOE's determination that these IRLs are covered by the directive
in 42 U.S.C. 6295(i)(3) to amend EPCA's standards should extend to 42
U.S.C. 6295(i)(4) under which this rulemaking is being concluded.
Therefore, the exempt lamps should be a part of this rulemaking.
(Earthjustice, No. 52 at p. 4) Earthjustice further commented that
because the Consolidated Appropriations Act, 2014 is clearly
inapplicable to R20 IRLs rated 45 W or less, DOE should adopt standards
for those lamps. (Earthjustice, No. 52 at p. 5)
DOE is not including the certain R, ER, and BR IRLs in this
rulemaking as it has commenced another rulemaking to address standards
for these lamps. At the time DOE determined that it has the authority
under EPCA to adopt standards for these R, ER, and BR IRLs, as they are
covered by the directive in 42 U.S.C. 6295(i)(3), the first cycle of
rulemaking to amend standards for IRLs per 42 U.S.C. 6295(i)(3) was
already underway. Therefore, DOE initiated a separate rulemaking for
the R, ER, and BR IRLs which included publishing a framework document
and holding a public meeting, prior to the initiation of this
rulemaking. Additionally, the Consolidated Appropriations Act, 2014
precludes DOE from engaging in a rulemaking involving certain ER, and
BR IRLs. While DOE agrees that implementation or enforcement of
standards for R IRLs are not prohibited by the Consolidated
Appropriations Act, 2014, the R20 IRLs rated 45 W or less are already
the subject of a separate rulemaking. Due to the progress of that
rulemaking, DOE did not find it appropriate to remove the R20 IRLs
rated 45 W or less from the scope of that rulemaking.
CA IOUs, NEEP, Earthjustice and EEOs noted that they do not agree
with DOE's interpretation of the Consolidated Appropriations Act, 2014
and urged DOE to include all covered IRLs in this rulemaking, including
the ER, BR, and BPAR lamps noted in the Act. (CA IOUs, No. 56 at p. 5;
NEEP, No. 57 at
[[Page 4057]]
p. 1; EEOs, No. 55 at p.7; Earthjustice, No. 52 at p. 5) Earthjustice
commented that nothing in the text of the Act prevents DOE from using
appropriated funds to adopt standards that are different from those
shown in the tables in section 325(i)(1)(B). Earthjustice stated that
even if DOE believes that adopting standards stronger than those in the
tables would implicitly also apply standard levels blocked by the Act
(in that DOE would be applying standards to remove from the market
lamps that Congress allegedly sought to protect), DOE could certainly
adopt standards weaker than those applied in EPAct 1992. Such standards
would still represent a significant improvement in efficacy, and under
the current funding constraints, may represent the maximum improvement
in energy efficiency that is feasible. (Earthjustice, No. 52 at p. 5)
EEOs stated that the Consolidated Appropriations Act, 2014 only
prevents DOE from using funds to implement or enforce standards
contained in the tables in section 325(i)(1)(B) and not from
implementing or enforcing standards developed in response to a separate
congressionally required rulemaking. (EEOs, No. 55 at p. 7) CA IOUs
stated that EISA 2007 requires DOE to consider revising standards for
these products. (CA IOUs, No. 56 at p. 5)
CA IOUs also noted that by omitting these products, the total
savings potential from IRL standards is greatly minimized as standards
for covered IRLs may result in more expensive, higher performing
covered products and low cost, low efficacy unregulated products. CA
IOUs and NEEP commented that these unregulated lamps would result in
major loopholes as consumers could be incented to utilize less
efficient IRLs, ultimately sacrificing significant energy savings to
the country. (CA IOUs, No. 56 at p. 5; NEEP, No. 57 at p. 1) ASAP
stated and was supported by CA IOUs that consumers currently have a
choice between a very efficient light-emitting diode (LED), a very
efficient incandescent covered lamp or a very inefficient 65 W BR or
equivalent lamp. Therefore, addressing this loophole could lead to
annual savings of half a billion dollars. (ASAP, Public Meeting
Transcript, No. 49 at pp. 16-17)
The Consolidated Appropriations Act, 2014 prohibits expenditure of
funds appropriated by that law to implement or enforce standards for
BPAR, BR, and ER IRLs. Thus, DOE is not considering these specific
lamps in this rulemaking.
2. Incandescent Reflector Wattages
In this rulemaking, DOE also did not consider IRLs with wattages
lower than 40. EPCA defines an incandescent reflector lamp as a lamp
that ``has a rated wattage that is 40 watts or higher.'' (42 U.S.C.
6291(30)(C), (C)(ii), and (F)) Additionally, while the definition of
IRLs does not provide an upper wattage limit, DOE did not assess
covered IRLs higher than 205 W in the NOPR. DOE research indicated that
wattages greater than 205 W comprise a very small portion of the market
and are typically designed for specialty uses, and therefore, do not
represent significant energy savings. DOE did not receive any comments
on this assessment in response to the NOPR and therefore, analyzes the
same wattage range for IRLs in this final rule.
D. Summary of Scope of Coverage
In conclusion, in this rulemaking DOE is extending the scope of
coverage for GSFLs to certain wattages including 8-foot SP slimline
lamps with wattages >=49 W and <52 W, 4-foot T5 MiniBP SO lamps with
wattages >=25 W and <26 W, and 4-foot T5 MiniBP HO lamps with wattages
>=44 W and <49 W but not to additional GSFL types. Further, DOE is
clarifying certain exemptions noted under the definition of ``general
service fluorescent lamp.'' DOE is not considering IRLs less than 40 W
or greater than 205 W and is also not considering the following IRL
types: (1) Lamps rated 50 W or less that are ER30, BR30, BR40, or ER40;
(2) lamps rated 65 W that are BR30, BR40, or ER40 lamps; and (3) R20
IRLs rated 45 W or less. DOE is also adopting a definition for
``designed and marketed'' as it applies to all covered lighting
products.
VI. Methodology and Discussion
In the NOPR phase of this rulemaking, DOE conducted the following
analyses: a market and technology assessment, screening analysis,
engineering analysis, product price determination, energy-use
characterization, LCC and PBP analyses, an LCC subgroup analysis,
shipments analysis and NIA, a complete MIA, a utility impact
assessment, an employment impact assessment, an emissions analysis, a
determination of monetization of reduced emissions from proposed
standard levels, and an RIA. These analyses were then updated and
revised as appropriate based on feedback received for this final rule.
DOE used four spreadsheet tools to estimate the impact of standards
analyzed in the NOPR. The first tool (``Life-Cycle Cost [LCC]
Analytical Tool'') calculates LCCs and payback periods of potential new
energy conservation standards. The second tool (``National Impact
Analysis [NIA] Analytical Tool'') is a spreadsheet that provides
shipments forecasts and a framework that calculates national energy
savings and net present value resulting from potential amended energy
conservation standards. DOE assessed manufacturer impacts, largely
through use of the ``Government Regulatory Impact Model (GRIM)'', the
third tool. Additionally, DOE used output from the latest version of
EIA's National Energy Modeling System (NEMS) for the emissions and
utility impact analyses. NEMS is a public domain, multi-sector, partial
equilibrium model of the U.S. energy sector. EIA uses NEMS to prepare
its Annual Energy Outlook (AEO), a widely known energy forecast for the
United States.
NEMA voiced concerns about the number of assumptions that DOE uses
in the NOPR that are not being tested by retrospectively evaluating
predictions made in the 2009 Lamps Rule in order to improve DOE's
predictive analysis and to tune DOE's models. (NEMA, No. 54 at p. 17)
As needed, DOE makes assumptions based on the current relevant data
and research available, feedback from manufacturer interviews, and
stakeholder comments, information that is informed by the impacts of
the 2009 Lamps Rule. Further, in the NOPR analysis and in this final
rule analysis DOE has taken appropriate steps to ensure that its models
provide the most accurate assessment of standards and their impacts. In
the following sections, DOE discusses its methodology and responds to
comments specific to each analysis. DOE further provides details
regarding its analysis including assumptions in the final rule TSD.
A. Market and Technology Assessment
In the energy conservation standards rulemaking process, DOE
conducts a market and technology assessment to provide an overall
picture of the market for products concerned. Based primarily on
publicly available information, the analysis provides both qualitative
and quantitative information. The market and technology assessment
includes the major manufacturers, product classes, retail market
trends, shipments of covered products, regulatory and non-regulatory
programs, and technologies that could be used to improve the efficacy
of GSFLs and IRLs. DOE identified several technology options after
conducting this assessment for the NOPR analysis. 79 FR at 24087-24090
(April 29, 2014). For further details on
[[Page 4058]]
the technology options and the screening process, see, respectively,
chapters 3 and 4 of the NOPR TSD.
Osram Sylvania (OSI) commented that many of the GSFL and IRL
technology options are already being used by manufacturers, so they
should not be considered technology options. (OSI, Public Meeting
Transcript, No. 49 at pp. 46-47) Based on DOE research, the technology
options put forth in this rulemaking for GSFLs and IRLs all remain
tools manufacturers can use to increase the efficacy of the lamp.
Because lamps are present on the market at different efficacy levels,
it is evident that not all the technology options are being used by all
manufacturers and/or are not being used to their optimal performance.
Therefore, with the exception of the IRL technology options of
efficient filament orientation and efficient filament coiling, which
are discussed in greater detail in section VI.A.2, DOE continues to
consider the technology options put forth in the NOPR as means to
improve the efficacy of GSFLs and IRLs.
1. General Service Fluorescent Lamp Technology Options
DOE received comments specific to the GSFL technology options put
forth in the NOPR analysis. Specifically, DOE received a comment on
highly emissive coatings, fill gas compositions, and higher efficiency
phosphors.
a. Highly Emissive Coatings
DOE identified highly emissive coatings as a technology option to
increase GSFL efficacy in the NOPR. When electrons are more easily
emitted from the fluorescent lamp electrodes, a lower voltage is needed
to maintain the arc. Therefore, any improvement in electrode coating
that would allow electrons to be more easily removed from the
electrodes would reduce the lamp power and increase the overall
efficacy of the lamp. See chapter 3 of the final rule TSD for further
details.
General Electric (GE) commented that highly emissive coatings are
already being used to meet the current requirements of the 2009 Lamps
Rule, so it is not logical to cite this as a technology options again.
(GE, Public Meeting Transcript, No. 49 at pp. 48-49)
DOE found that there are various coatings and combinations that can
be used to increase lamp efficacy. Conventional coatings include barium
oxide (BrO), calcium oxide (CaO), and strontium oxide (SrO), sometimes
paired with the addition of zirconium oxide (ZrO) which is used to
extend lamp lifetime, and silicon carbide (SiC) which removes more
electrons from the electrode. Because lamps are present on the market
at more than one level of efficacy, and highly emissive electrode
coating technology can be optimized in different variations, it
provides a mechanism to improve the efficacy of less efficacious
products (see chapter 3 of the final rule TSD for more information).
Therefore, DOE retained highly emissive electrode coating as a
technology option for this final rule.
b. Higher Efficiency Lamp Fill Gas Composition
DOE also identified higher efficiency lamp fill gas composition as
a technology option to increase GSFL efficacy in the NOPR. Lamp fill
gases in fluorescent lamps increase mobility of mercury ions and
electrons, facilitating recombination and resulting in increased
ultraviolet (UV) output and higher lamp efficacy. See chapter 3 of the
final rule TSD for further details.
GE commented that higher efficiency gas fill composition is already
being used to meet the current requirements of the 2009 Lamps Rule, so
it is not logical to cite this as a technology option again. (GE,
Public Meeting Transcript, No. 49 at pp. 48-49)
Based on feedback from manufacturers in interviews, there are
different types and ratios of fill gases that can be used to improve
lamp efficacy. Because lamps are present on the market at more than one
level of efficacy, and fill gas compositions can be optimized in
different combinations, they provide a mechanism to improve the
efficacy of less efficacious products. Therefore, DOE retained higher
efficiency fill gas composition as a technology option for this final
rule.
c. Higher Efficiency Phosphors
DOE also identified higher efficiency phosphors as a technology
option to increase GSFL efficacy in the NOPR. 79 FR at 24088 (April 29,
2014). Triband phosphors which contain rare earth elements are more
efficient phosphors that allow a lamp to emit light at the wavelengths
to which human eyes are most sensitive which increases lamp efficacy.
This effect is impacted by the relationship between the efficiency
losses in the phosphor's conversion of light, wavelengths sensitive to
the human eye, and measurement of lamp efficacy. Generally, as
thickness of the phosphor layer (also called phosphor weight)
increases, lamp light output increases until it slightly decreases or
stays flat. (See chapter 3 of the final rule TSD for further details).
NEMA stated that options to increase phosphor weight are
essentially exhausted at the proposed efficacy level because it is near
the peak of the coating weight/light output curve shown in figure 3.4.5
of chapter 3 of the NOPR TSD. (NEMA, No. 54 at pp. 22-23)
As noted, phosphor weight utilized in a lamp impacts the efficacy
achieved. Because lamps are present on the market at more than one
level of efficacy, varying weights of higher efficiency phosphor
coatings is an option that can be utilized to improve the efficacy of
less efficacious products. Therefore, DOE maintained higher efficiency
phosphors as a technology option for this final rule.
d. Summary of GSFL Technology Options
In summary, in this final rule analysis, DOE identified technology
options for GSFLs listed in Table VI.1.
Table VI.1--GSFL Technology Options in the Final Rule Analysis
------------------------------------------------------------------------
Name of technology option Description
------------------------------------------------------------------------
Highly Emissive Electrode Coatings Improved electrode coatings allow
electrons to be more easily removed
from electrodes, reducing lamp
power and increasing overall
efficacy.
Higher Efficiency Lamp Fill Gas Fill gas compositions improve
Composition. cathode thermionic emission or
increase mobility of ions and
electrons in the lamp plasma.
Higher Efficiency Phosphors....... Phosphors increase the conversion of
ultraviolet light into visible
light.
Glass Coatings.................... Coatings on inside of bulb enable
the phosphors to absorb more UV
energy, so that they emit more
visible light.
Higher Efficiency Lamp Diameter... Optimal lamp diameters improve lamp
efficacy.
Multi-Photon Phosphors............ Phosphors emit more than one visible
photon for each incident UV photon.
------------------------------------------------------------------------
[[Page 4059]]
2. Incandescent Reflector Lamp Technology Options
DOE received comments specific to the IRL technology options put
forth by DOE in the NOPR. Id. at 24088-24090. Specifically, DOE
received comments on thinner filaments, efficient filament coiling,
efficient filament orientation, higher efficiency inert fill gases,
higher pressure tungsten-halogen lamps, infrared glass coatings,
efficient filament placement, and integrally ballasted low voltage
lamps.
a. Thinner Filaments
In the NOPR analysis, DOE proposed thinner filaments as a
technology option for increasing IRL efficacy. Id. at 24089. A thinner
filament has an increased resistance and therefore an increased
operating temperature, which increases the lamp efficacy. (See chapter
3 of the final rule TSD for further details.) NEMA commented that
thinner filaments mean longer filaments, which reduce efficacy by
defocusing the light source inside the reflector. (NEMA, No. 54 at p.
20)
DOE's research did not find any information indicating that the
loss in efficacy due to the potentially defocused light with a longer
filament outweighs the gain obtained by running a thinner filament at a
higher temperature. Additionally, a longer filament would increase
lumen output. DOE acknowledges that when utilizing a thinner filament
as a technology option, other factors must be considered, such as the
length of the filament required to implement the technology in its most
optimal form. However, this does not preclude it as a technology option
as use of it in the appropriate manner can increase IRL efficacy.
Therefore, DOE maintained the use of thinner filaments as a technology
option that can be manipulated to increase lamp efficacy for this final
rule.
b. Efficient Filament Coiling
DOE proposed efficient filament coiling in the NOPR analysis as a
technology option to increase lamp efficacy. Id. at 24089. Coiling of
the incandescent lamp filament can increase luminous efficacy. The
light output of an incandescent lamp is directly proportional to the
light-emitting surface area of the light source. By coiling the
filament, a longer filament can be used, increasing luminous output and
therefore lamp efficacy. (See chapter 3 of the final rule TSD for
further details.) NEMA stated that efficient filament coiling, which is
necessary for efficient optics and beam patterns, is already common
practice in the majority of halogen IRLs. Thus, no further efficacy
increase is possible with this technology option. (NEMA, No. 54 at p.
20)
DOE research indicates that specifications of commercially
available IRLs covered in this rulemaking state that the optimal
coiling configuration, the CC (coiled coil) is being used. Therefore,
DOE removed efficient filament coiling as a technology option that can
be used to improve the efficacy of lamps on the market for this final
rule.
c. Efficient Filament Orientation
DOE proposed efficient filament orientation in the NOPR analysis as
a technology option to increase lamp efficacy. Id. Tungsten filaments
in incandescent lamps can be positioned horizontally or vertically with
respect to the base of the bulb. By positioning the filament in
vertical alignment, only a small portion of the light is emitted
towards the base, allowing more light to escape the bulb and be used
for illumination, thereby increasing lamp efficacy. (See chapter 3 of
the final rule TSD for further details.) NEMA commented that efficient
filament orientation, which is necessary for efficient optics and beam
patterns, is already common practice in the majority of halogen IRLs,
noting that manufacturers already strive to accomplish this and thus,
no further efficacy increase is possible with this technology option.
(NEMA, No. 54 at p. 20)
DOE recognizes that filaments are placed in the vertical position
which is optimal for commercially available IRLs covered in this
rulemaking. Therefore, DOE removed efficient filament orientation as a
technology option that can be used to improve the efficacy of lamps on
the market for this final rule.
d. Higher Efficiency Inert Fill Gas
DOE proposed high-efficiency inert fill gas as another technology
option to increase IRL efficacy in the NOPR analysis. Id. Fill gases
such as krypton and xenon have low thermal conductivity that decreases
the convective cooling of the filament, allowing for higher temperature
operation and therefore higher efficacy. These gas molecules are larger
relative to other gases, and can more effectively slow down the
evaporation of tungsten and thereby extend the life of the lamp. Xenon,
having even lower heat conductivity and larger mass than krypton, can
more drastically change efficacy and life, but has a higher cost. Most
lamps compliant with the July 2012 standards use xenon as a fill gas.
(See chapter 3 of the final rule TSD for further details.) NEMA
commented that higher efficiency inert fill gas is already common
practice in the majority of halogen IRLs and therefore, no further
efficacy increase is possible with this technology option. (NEMA, No.
54 at p. 20)
Based on feedback from manufacturer interviews, DOE confirmed that
the majority of covered standards-compliant IRLs are utilizing xenon.
However, DOE also learned that the amount of xenon used in a lamp can
vary based on several factors. Because lamps are present on the market
at more than one level of efficacy, higher efficiency inert fill gas is
one option that can be utilized to improve the efficacy of less
efficacious products. Therefore, DOE maintained high-efficiency inert
fill gas as a technology option for this final rule.
e. Higher Pressure Tungsten-Halogen Lamps
DOE proposed the use of higher pressure tungsten-halogen as a
technology option in the NOPR analysis. Id. Increasing the pressure of
the halogen burner by increasing the density of halogen elements can
indirectly raise the efficacy of the tungsten-halogen lamp. The
increased density of halogen elements raises the probability that an
evaporated tungsten element combines with a halogen element in a
gaseous compound. Adding more of this gaseous compound in the burner
effectively increases the amount of tungsten re-deposited on the
tungsten filament. The lamp efficacy can be increased by using higher
pressure to maintain the evaporation rate while increasing the filament
temperature. (See chapter 3 of the final rule TSD for further details.)
NEMA stated that the higher pressures in higher pressure tungsten-
halogen lamps increase life but reduce efficacy due to the faster
convective cooling of the filament. (NEMA, No. 54 at p. 21)
DOE understands that maintaining the filament temperature and
increasing the pressure, thereby decreasing the evaporation rate of
tungsten result in a gain in lifetime. However, a combination of higher
pressure and increased temperature can be used to achieve both an
increase in efficacy and lifetime. Therefore, DOE maintains high-
efficiency inert fill gas as a technology option in this final rule.
f. Infrared Glass Coatings
DOE proposed infrared glass coatings as a technology option in the
NOPR analysis. Id. at 24090. Infrared coatings on incandescent lamps
are used to
[[Page 4060]]
reflect some of the radiant energy emitted back onto the filament. This
infrared radiation then supplies heat to the filament and the operating
temperature increases. An increase in operating temperature results in
higher light output and therefore an increase in efficacy. (See chapter
3 of the final rule TSD for further details.) NEMA commented that
infrared glass coatings on burners and reflectors have been in use
since the mid-1980s and have been developed to the maximum
technologically feasible level. More efficient coatings with 80 or more
layers have been tested, but these coatings fail due to cracking under
repeated thermal expansion and contraction. Therefore, no further
efficacy increase is possible with this technology option. (NEMA, No.
54 at p. 21)
Based on feedback from manufacturer interviews, DOE determined that
different IR coating formulas are used on different halogen burners.
Because lamps are present on the market at more than one level of
efficacy, and infrared glass coating technology can be optimized in
different variations, it provides a mechanism to improve the efficacy
of less efficacious products. Therefore, DOE maintained infrared glass
coatings as a technology option for the final rule.
g. Efficient Filament Placement
Efficient filament placement was one of the technology options
presented in the preliminary analysis (see chapter 3 of the preliminary
analysis TSD), but DOE did not propose it in the NOPR phase. An
optimally placed filament allows a portion of the spectrum emitted by
the filament to focus back onto it. The additional heat provided to the
filament increases the operating temperature and thereby increases lamp
efficacy. In the NOPR phase, NEMA commented that manufacturers already
use efficient filament placement and that no further efficacy gains due
to this technology option are possible. (NEMA, No. 54 at p. 20)
DOE had received similar comments regarding efficient filament
placement in the preliminary analysis. Based on these comments and
further research as well as manufacturer interviews, DOE determined
that the optimal filament placement design is theoretically well
understood and is being applied in commercially available IRLs covered
under the scope of this rulemaking. Therefore, DOE did not propose
efficient filament placement as a technology option in the NOPR
analysis and maintained this decision for the final rule.
h. Integrally Ballasted Low Voltage Lamps
DOE also presented integrally ballasted low voltage lamps as a
technology option in the preliminary analysis but did not propose it in
the NOPR phase. 79 FR at 24089 (April 29, 2014) The use of an integral
ballast in an incandescent lamp allows an increase in the efficacy
because it converts the line voltage to lower lamp operating voltages,
thereby reducing the lamp wattage. In the NOPR phase, NEMA commented
that integrally ballasted low voltage lamps use electronics that are
thermally limited to 30 W or less due to American National Standards
Institute/International Electrotechnical Commission (ANSI/IEC) form
constraints. Further, most IRLs are burned base-up. Therefore, this is
not viable for higher power PAR lamps. (NEMA, No. 54 at p. 21)
DOE received similar comments in the preliminary analysis and
reviewed feedback from manufacturer interviews and conducted further
research regarding issues with this technology option. In interviews,
manufacturers stated that the use of an integral ballast to lower
voltage is not a feasible technology in higher wattage lamps due to
issues with dissipating heat generated by the electronic components.
Manufacturers indicated that heat dissipation becomes a problem at
wattages ranging from 20 to 35 W. DOE research also indicated that in
converting to a lower voltage, current is increased and greater heat is
generated from the filament. In higher wattage IRLs, the resulting
increased temperature can be damaging to the voltage conversion
circuitry. Further, based on manufacturer interviews there are no
covered IRLs that currently utilize this technology option. Because the
lower limit of IRL wattages covered under standards is 40 W, DOE did
not propose integrally ballasted low voltage lamps as a technology
option in the NOPR analysis and maintained this decision for the final
rule.
i. Summary of IRL Technology Options
In summary, in this final rule analysis, DOE identified technology
options for IRLs listed in Table VI.2.
Table VI.2--IRL Technology Options in the Final Rule Analysis
------------------------------------------------------------------------
Name of technology option Description
------------------------------------------------------------------------
Higher Temperature Operation. Operating the filament at higher
temperatures, the spectral output shifts
to lower wavelengths, increasing its
overlap with the eye sensitivity curve.
Microcavity Filaments........ Texturing, surface perforations,
microcavity holes with material
fillings, increasing surface area and
thereby light output.
Novel Filament Materials..... More efficient filament alloys that have
a high melting point, low vapor
pressure, high strength, high ductility,
or good radiating characteristics.
Thinner Filaments............ Thinner filaments to increase operating
temperature. This measure may shorten
the operating life of the lamp.
Crystallite Filament Coatings Layers of micron or submicron
crystallites deposited on the filament
surface that increases emissivity of the
filament.
Higher Efficiency Inert Fill Filling lamps with alternative gases,
Gas. such as Krypton, to reduce heat
conduction.
Higher Pressure Tungsten- Increased halogen bulb burner
Halogen Lamps. pressurization, allowing higher
temperature operation.
Non-Tungsten-Halogen Novel filament materials that regenerate.
Regenerative Cycles.
Infrared Glass Coatings...... When used with a halogen burner, this is
referred to as an HIR lamp. Infrared
coatings on the inside of the bulb to
reflect some of the radiant energy back
onto the filament.
IR Phosphor Glass Coatings... Phosphor coatings that can absorb IR
radiation and re-emit it at shorter
wavelengths (visible region of light),
increasing the lumen output.
UV Phosphor Glass Coatings... Phosphor coatings that convert UV
radiation into longer wavelengths
(visible region of light), increasing
the lumen output.
Electron Stimulated A low voltage cathodoluminescent phosphor
Luminescence. that emits green light (visible region
of light) upon impingement by thermally
ejected electrons, increasing the lumen
output.
Higher Efficiency Reflector Alternative reflector coatings such as
Coatings. silver, with higher reflectivity
increase the amount of directed light.
[[Page 4061]]
Corner Reflectors............ Individual corner reflectors in the cover
glass that reflect light directly back
in the direction from which it came.
High Reflectance Filament Filament supports that include a
Supports. reflective face that reflects light to
another filament, the reflective face of
another filament support, or radially
outward.
Permanent Infrared Reflector Permanent shroud with an IR reflector
Coating Shroud. coating and a removable and replaceable
lamp can increase efficiency while
reducing manufacturing costs by allowing
IR reflector coatings to be reused.
Higher Efficiency Burners.... A double-ended burner that features a
lead wire outside of the burner, where
it does not interfere with the
reflectance of energy from the burner
wall back to the burner filament in HIR
lamps.
------------------------------------------------------------------------
B. Screening Analysis
After DOE identifies the technologies that improve the efficacy of
GSFLs and IRLs, DOE conducts the screening analysis. The purpose of the
screening analysis is to determine which options to consider further
and which options to screen out. DOE consults with industry, technical
experts, and other interested parties in developing a list of
technology options. DOE then applies the following set of screening
criteria to determine which options are unsuitable for further
consideration in the rulemaking (10 CFR part 430, subpart C, appendix A
at 4(a)(4) and 5(b)):
Technological Feasibility: DOE will consider technologies
incorporated in commercially available products or in working
prototypes to be technologically feasible.
Practicability to Manufacture, Install, and Service: If
mass production of a technology and reliable installation and servicing
of the technology could be achieved on the scale necessary to serve the
relevant market at the time the standard comes into effect, then DOE
will consider that technology practicable to manufacture, install, and
service.
Adverse Impacts on Product Utility or Product
Availability: If DOE determines a technology to have significant
adverse impact on the utility of the product to significant subgroups
of consumers, or to result in the unavailability of any covered product
type with performance characteristics (including reliability),
features, sizes, capacities, and volumes that are substantially the
same as products generally available in the United States at the time,
it will not further consider this technology.
Adverse Impacts on Health or Safety: If DOE determines
that a technology will have significant adverse impacts on health or
safety, it will not further consider this technology.
Those technology options not screened out by the above four
criteria are called ``design options'' and are considered as possible
methods of improving efficacy in the engineering analysis. DOE received
several comments on technology options not screened out and retained as
design options in the NOPR analysis for GSFLs and IRLs.
1. General Service Fluorescent Lamp Design Options
DOE received a general comment on the screening methodology as it
relates to GSFLs. Philips commented that the screening analysis is not
comprehensive enough because it is only looking at efficacy and does
not consider other market requirements such as lifetime, dimmability,
and CRI. (Philips, Public Meeting Transcript, No. 49 at p. 49)
One of the screening criteria is determining if a technology option
would result in adverse impacts on the utility or availability of the
product. DOE determined that of the design options considered for
GSFLs, none would have a negative impact on the utility of the lamp
(since lumen output is improved or maintained) nor would they eliminate
the common lifetimes and CRI currently being offered. DOE acknowledges
that krypton, a high-efficiency fill gas, seems to affect dimmability
of reduced wattage lamps (i.e., energy saver lamp model). Because of
the issues related to dimming associated with reduced wattage lamps,
DOE's analysis requires that full-wattage lamps, which do not
experience these problems, meet any proposed level. Therefore, because
the use of high-efficiency fill gas would only impact the dimmability
of certain product options available at a standard level (i.e., reduced
wattage lamps), this design option is retained.
In summary, in this final rule analysis DOE identified as design
options the following GSFL technologies that have met the screening
criteria:
Highly Emissive Electrode Coatings
Higher Efficiency Lamp Fill Gas Composition
Higher Efficiency Phosphors
Glass Coatings
Higher Efficiency Lamp Diameter
See chapter 4 of the final rule TSD for further details on the GSFL
screening analysis.
2. Incandescent Reflector Lamp Design Options
DOE received feedback on several IRL design options put forth in
the NOPR analysis, including higher temperature operation, thinner
filaments, and higher efficiency reflector coatings.
a. Higher Temperature Operation
In the NOPR, DOE proposed higher temperature operation as a design
option. 79 FR at 24091 (April 29, 2014). By operating the filament at
higher temperatures, the spectral output shifts to shorter wavelengths,
increasing its overlap with the photopic spectral eye sensitivity.
This, in effect, increases the luminous output for a given power input
and consequently increases the lamp efficacy. NEMA stated that higher
temperature operation leads to a drastic and disproportionate loss in
lifetime (e.g., 6-7 percent efficacy gain results in about 50 percent
reduction in lifetime). (NEMA, No. 54 at p. 20)
DOE understands that there may be a tradeoff between operation at
higher temperature and a decrease in lifetime. However, DOE believes
the use of higher temperature operation can be tuned to achieve a gain
in efficacy while maintaining a reasonable lifetime. Therefore, DOE
maintained higher temperature operation as a design option for this
final rule.
b. Thinner Filaments
DOE proposed thinner filaments as a design option in the NOPR
analysis. A thinner filament has an increased resistance and therefore
an increased operating temperature, which increases the lamp efficacy.
NEMA commented that thinner filaments lead to a drastic loss in
lifetime. (NEMA, No. 54 at p. 20)
DOE is aware that an incandescent lamp with a thinner filament
cannot withstand as much tungsten evaporation as a thicker filament
before failing,
[[Page 4062]]
resulting in a shorter lifetime. However, a thinner filament design can
be implemented to achieve a gain in efficacy while preserving a
reasonable lifetime. Therefore, DOE maintained the use of thinner
filaments as a design option for this final rule.
c. Higher Efficiency Reflector Coatings
DOE proposed higher efficiency reflector coatings with the
exception of gold reflector coatings, as a design option in the NOPR
analysis. 79 FR at 24091 (April 29, 2014). IRLs are incandescent lamps
with a reflective coating, most commonly composed of aluminum or silver
applied directly to the reflector surface. The reflector coating allows
these lamps to place the same illuminance on a specific area with
reduced watts, thereby increasing efficacy. (Note: In the NOPR and in
this final rule, DOE screened out gold reflector coating due to impact
on product utility as gold reflectivity diminishes at and below blue-
green wavelengths, which may decrease the color quality of light. See
chapter 4 of the final rule TSD for further details.)
NEMA stated that silver, the best higher efficiency reflector
coating, is already in use and cannot be used in glue-sealed lamps
(such as PAR20, PAR30, PAR30LN) due to extreme oxidation issues. (NEMA,
No. 54 at p. 21)
DOE research indicates that it is possible to use silver reflector
coatings with an epoxy (glue-based) seal. For example, DOE identified a
patent that uses aluminum as an inner reflective coating extending from
the rim to the base of the lamp and then a second coating consisting of
silver spaced from the rim. The silver layer is heat-treated in an oven
with a controlled environment prior to fusing the lens to the reflector
body, which allows a seal to form without further diminishing the
reflective characteristic of the silver.\25\ Because there are methods
to apply higher efficiency reflector coatings to all products covered
by this rulemaking, DOE maintained the use of higher efficiency
reflector coatings as a design option for this final rule.
---------------------------------------------------------------------------
\25\ Woodward, David R. and Walter A. Boyce, Jack R. Sheppard.
High efficiency sealed beam reflector lamp with reflective surface
of heat treated silver. U.S. Patent No. 5789847A, filed October 24,
1995, and issued August 4, 1998.
---------------------------------------------------------------------------
d. Higher Pressure Tungsten-Halogen Lamps
DOE proposed the use of high pressure tungsten-halogen as a
technology option in the NOPR analysis. 79 FR at 24091 (April 29,
2014). Increasing the pressure of the halogen burner by increasing the
density of halogen elements can indirectly raise the efficacy of the
tungsten-halogen lamp. NEMA stated that there are practical
manufacturing process limitations and key consumer safety concerns with
higher pressure tungsten-halogen lamps. (NEMA, No. 54 at p. 21)
DOE notes that this design option is being used in commercially
available lamps. Further, DOE did not find information indicating any
manufacturing or safety concerns with the use of higher pressure
tungsten-halogen lamps. Therefore, DOE maintained the use of higher
pressure tungsten-halogen lamps as a design option for this final rule.
In summary, in this final rule analysis DOE identified as design
options the following IRL technologies that have met the screening
criteria:
Higher Temperature Operation
Thinner Filaments
Higher Efficiency Inert Fill Gas
Higher Pressure Tungsten-Halogen Lamps
Infrared Glass Coatings
Higher Efficiency Reflector Coatings (with the exception
of gold reflector coatings)
Higher Efficiency Burners
See chapter 4 of the final rule TSD for further details on the IRL
screening analysis.
C. Product Classes
DOE divides covered products into classes by: (a) the type of
energy used; (b) the capacity of the product; or (c) other performance-
related features that justify different standard levels, considering
the consumer utility of the feature and other relevant factors. (42
U.S.C. 6295(q)) DOE received several comments regarding product classes
proposed for GSFLs and IRLs in the NOPR analysis.
1. General Service Fluorescent Lamp Product Classes
In the NOPR analysis DOE considered product classes for GSFLs based
on the following three factors: (1) Correlated color temperature; (2)
physical constraints of lamps (i.e., lamp shape and length); and (3)
lumen package. 79 FR at 24091 (April 29, 2014). DOE received comments
regarding establishing additional product classes based on the
different spacing of 2-foot U-shaped lamps and lamp lifetime.
a. Two-Foot U-Shaped Lamps
DOE received several comments that separate product classes based
on the spacing of the 2-foot U-shaped lamps may be needed. Spacing
refers to the length between the two legs of the U-shaped lamp. The 2-
foot U-shaped GSFLs come in 1\5/8\-inch spacing and 6-inch spacing. OSI
commented that the 2-foot U-shaped lamps with 1\5/8\-inch spacing and
6-inch spacing should be in different product classes based on DOE's
analysis in the NOPR. (OSI, Public Meeting Transcript, No. 49 at pp.
33-34) OSI stated that the reduced wattage 2-foot U-shaped lamps with
1\5/8\-inch spacing are typically used in retail applications and would
be eliminated by the rulemaking, resulting in an increase in energy
use. OSI added that full-wattage 6-inch lamps would be eliminated by
the rulemaking, removing dimming utility. (OSI, Public Meeting
Transcript, No. 49 at pp. 60-61) GE noted that this issue could
partially be due to the scaling of the 2-foot U-shaped product class
from the 4-foot MBP product class and could be an issue specific to the
scaling factor or the 4-foot MBP product class efficacy levels. (GE,
Public Meeting Transcript, No. 49 at p. 61) NEMA explained that
consumers have switched to reduced wattage 1\5/8\-inch 2-foot U-shaped
lamps, which serve retail applications and full-wattage 6-inch 2-foot
U-shaped lamps are mainly used in offices for dimming purposes. (NEMA,
No. 54 at p. 15)
EEOs recommended that DOE only create separate product classes for
6-inch and 1\5/8\-inch spacing of 2-foot U-shaped if a technical
barrier impacting efficacy potential is identified. (EEOs, No. 55 at p.
6) CA IOUs commented that DOE should not create separate product
classes for U-shaped lamps with different spacing. CA IOUs supported
this statement by identifying commercially available full and reduced
wattage U-shaped lamps with 6-inch spacing that would meet the proposed
standard in the NOPR for these products. CA IOUs also noted that of the
2-foot U-shaped offerings with 1\5/8\-inch spacing, the majority of
products were 31 W lamps, many of which met the standard level proposed
in the NOPR analysis. Further, CA IOUs stated that there has to be a
clear technical reason for design limitations for U-bend lamps of
specific spacing to create separate product classes. They also noted
that the 2-foot U-shaped lamps comprise a low market share that is
shrinking as 2x2 fixtures are being converted to straight linear 2-foot
lamps and therefore, manufacturers may not have developed an array of
lamp offerings of varying efficacies. (CA IOU, No. 56 at p. 3)
DOE determines efficacy levels for 2-foot U-shaped lamps by
reducing the efficacy levels of comparable 4-foot MBP lamps by an
appropriate scaling
[[Page 4063]]
factor. DOE updated this scaling factor for the final rule analysis,
see section VI.D.2.h for addition detail. In response to stakeholder
comments, DOE reviewed the ability of 2-foot U-shaped lamps to comply
with the highest efficacy level analyzed in this final rule, paying
particular attention to the ability of both lamp spacings to comply.
DOE determined that full wattage and reduced wattage versions of both
lamp spacings are able to meet the highest efficacy level analyzed in
the 2-foot U-shaped product class. Therefore, in this final rule, DOE
did not establish separate product classes for the 1\5/8\-inch 2-foot
U-shaped and 6-inch 2-foot U-shaped lamps.
b. Long-Life Lamps
DOE received comments that a separate product class for GSFLs with
longer lifetimes than the standard lifetime may be needed. The longer
life products are new on the market and mainly prevalent among the 4-
foot MBP lamp types. NEMA commented that DOE should ensure that long-
life lamps could meet the proposed standards or create a new product
class for long-life lamps and report the associated analysis. (NEMA,
No. 54 at p. 18) NEMA emphasized that the issue is that consumers are
willing to pay a premium for long life (e.g., 80,000 hour) fluorescent
lamps to avoid frequent lamp replacement. NEMA added that for many
consumers long-life LEDs might not be an option due to first cost.
(NEMA, Public Meeting Transcript, No. 49 at pp. 72-73) NEMA stated that
long-life products offer utility for areas that are difficult to
relamp, such as areas over assembly lines, or bridges and tunnels.
Further, NEMA contended that design changes that permit much longer
lifetimes have a net reduction in lumens/watt. When lumens per watt are
increased lifetime is reduced and that increases the frequency of
replacement, which in turn increases labor costs for replacement,
increases the use of rare earth oxides in manufacturing, and increases
mercury release. (NEMA, No. 54 at pp. 13-14)
GE noted that more lamps would be required to support lifetimes
that may be half as long as common lifetimes for fluorescent lamps and
this would also increase waste and costs to the manufacturer. GE also
noted that elimination of long-life GSFLs would not result in energy
savings as fluorescent lamps consume a steady amount of power from
initial to mean to end life. (GE, Public Meeting Transcript, No. 49 at
pp. 68-69, 73-74) Regarding a question on the market share of long-life
GSFLs, OSI responded that because these products have only been
recently introduced in the market it is difficult to determine and NEMA
noted that it would try to obtain this data for DOE. (OSI, Public
Meeting Transcript, No. 49 at p. 74; NEMA, Public Meeting Transcript,
No. 49 at pp. 75-76)
EEOs remarked that although industry members proposed a separate
product class for extra-long-life GSFLs with lifetimes of around 80,000
hours, these products are new on the market and it is unclear if a
technical barrier exists preventing these lamps from meeting proposed
standards. EEOs added that CA IOUs provided examples of reduced wattage
extra-long-life 4-foot MBP lamps that would meet proposed levels.
Further, EEOs agreed that extra-long-life lamps are cost effective,
however, the negative impacts of a proposed level on life could be
captured in DOE's economic analysis. (EEOs, No. 55 at pp. 6-7) The
Northwest Energy Efficiency Alliance (NEEA) stated that it had not
observed consumer concern for lifetime, noting more sales of less
efficacious, long-life products. NEEA also noted that it was not
possible to have both an efficacious and a good long lifetime product
and expected this rulemaking to address the lifetime in the life-cycle
cost analysis of the product. (NEEA, Public Meeting Transcript, No. 49
at pp. 77-79)
CA IOUs commented that a separate product class might be warranted
for extra-long-life GSFLs if DOE finds a technical justification for
reduced efficacy among these products. CA IOUs identified a variety of
commercially available reduced wattage extra-long-life products with
catalog efficacies that would pass DOE's proposed standard for 4-foot
MBP lamps. Noting that these were reduced wattage lamps, CA IOUs added
that if DOE is not able to identify full-wattage extra-long-life lamps
that meet the proposed standards, and stakeholders present a technical
justification with respect to design limitations preventing such
products from being developed, a separate product class might be
appropriate for this product type. However, CA IOUs noted that a
standard for such a product class should be sufficiently stringent to
avoid becoming a loophole. (CA IOU, No. 56 at pp. 3-4)
In response to stakeholder comments, DOE reviewed information about
long life GSFLs from manufacturer interviews, product catalogs, and
DOE's certification database. Manufacturer interviews indicated that it
may be possible to increase the lifetime of fluorescent lamps by
increasing the gas pressure, but that this may also decrease efficacy.
DOE reviewed manufacturer catalog offerings and found that several
manufacturers offered lamps that were marketed as ``standard life'' and
also offered lamps that were marketed as ``long life.'' Catalog
information generally indicated that the marketed long life lamps were
less efficacious than comparable standard life lamps. Where available,
certification data supported this trend. However, DOE notes that there
is inconsistency in the industry regarding what actually constitutes a
``long life'' lamp. When comparing lamps offered by different
manufacturers, one manufacturer's ``long life'' product may be offered
with a lifetime very similar to that of another manufacturer's
``standard life'' product. Further, while DOE is aware that lifetime is
a feature valued by consumers, DOE's analysis ensures that the
lifetimes typically available at the baseline level are also available
at higher efficacy levels (see section VI.D.2.g for more details). In
this way, DOE's higher efficacy levels do not impact consumer utility
and DOE accounts for any differences in lifetime as economic impacts in
the LCC and NIA. Therefore, DOE did not establish separate product
classes for long life GSFLs in this final rule analysis.
c. Summary of GSFL Product Classes
In this final rule analysis, DOE established product classes for
GSFLs as summarized in Table VI.3. See chapter 3 of the final rule TSD
for further details on each GSFL product class.
Table VI.3--GSFL Product Classes in Final Rule Analysis
------------------------------------------------------------------------
Lamp type CCT
------------------------------------------------------------------------
4-foot medium bipin........................................ <=4,500 K
>4,500 K
2-foot U-shaped............................................ <=4,500 K
>4,500 K
8-foot single pin slimline................................. <=4,500 K
>4,500 K
8-foot recessed double contact high output................. <=4,500 K
>4,500 K
4-foot T5, miniature bipin standard output................. <=4,500 K
>4,500 K
4-foot T5, miniature bipin high output..................... <=4,500 K
>4,500 K
------------------------------------------------------------------------
2. Incandescent Reflector Lamp Product Classes
In the NOPR analysis, DOE proposed product classes for IRLs based
on the following three factors: (1) Rated voltage, separating lamps
less than 125 V from lamps greater than or equal to 125 V; (2) lamp
spectrum, separating lamps with a standard spectrum from lamps with a
modified spectrum; and
[[Page 4064]]
(3) lamp diameter, separating lamps with a diameter greater than 2.5
inches from lamps with a diameter less than or equal to 2.5 inches. 79
FR at 24092 (April 29, 2014). DOE received comments on the rated
voltage and modified spectrum product class setting factors. DOE did
not receive feedback on the other product class divisions proposed for
IRLs in the NOPR analysis.
a. Rated Voltage
In the NOPR analysis, DOE proposed rated voltage as a class setting
factor, establishing a product class for IRLs with voltages less than
125 V and a product class for IRLs with voltages greater than or equal
to 125 V. NEMA stated that DOE's reasoning for a separate 130 V product
class was out of concern that consumers would shift to 130 V options
that are less efficient than 120 V lamps resulting in increased energy
consumption. However, NEMA noted that when operated at 120 V, a 60 W
130 V PAR38 uses less energy, approximately 54-55 W. Further, NEMA
stated that since this decreases light output, consumers would not
choose 130 V IRLs to `cheat' on energy conservation standards. (NEMA,
No. 54 at p. 30)
DOE agrees that the 130 V lamp described by NEMA would use less
energy when operated at 120 V. However, in the NOPR analysis and in
this final rule DOE concludes that the corresponding decrease in light
output would result in consumers purchasing additional lamps to
maintain sufficient light. 79 FR at 24093 (April 29, 2014). Therefore,
setting higher standards for IRLs without accounting for voltage
differences could result in increased energy consumption.
Westinghouse remarked that the absence of 130 V IRLs on the market
has resulted in a loss in utility as 130 V IRLs were used to maintain
product lifetimes in areas with transients, voltage spikes, and other
power issues, and that consumers in those markets will have to buy more
light bulbs due to voltage issues. Citing the 130 V lamps as an
example, Westinghouse noted that in this rulemaking DOE has to be
careful when setting new IRL standards that such unintended
consequences do not happen as they cannot be fixed in the future due to
the backsliding provision. (Westinghouse, Public Meeting Transcript,
No. 49 at pp. 43-44)
DOE is aware that the 130 V lamps can provide a certain utility by
lasting longer than 120 V lamps in certain areas that are susceptible
to voltage spikes. However, based on its assessment that most consumers
operate 130 V IRLs at 120 V and differences in efficacy when they are
operated at 120 V versus tested at 130 V, DOE determined that there
would be a potential migration to 130 V IRLs if they were subject to
the same standards as 120 V IRLs and further that there would be
additional purchases of 130 V IRLs by the consumer. Hence, in order to
preserve energy savings, DOE maintained the rated voltage class
division that separates covered IRLs less than 125 V from those that
are greater than or equal to 125 V in this rulemaking. (See chapter 3
of the final rule TSD for further information.)
b. Modified Spectrum
Modified spectrum IRLs provide unique utility to consumers by
providing a different type of light than standard spectrum lamps, much
like fluorescent lamps with different CCT values. However, the same
technologies (i.e., coatings) that modify the spectral emission of a
lamp also decrease lamp efficacy. Therefore, in the NOPR DOE proposed a
product class division separating standard spectrum IRLs from modified
spectrum IRLs. 79 FR at 24093 (April 29, 2014).
EEOs added that a separate product class for modified spectrum
lamps may not be needed as more efficient technologies, such as CFLs
and LEDs, are able to achieve the same utility and also due to the lack
of commercially available modified spectrum lamps covered by the
rulemaking. (EEOs, No. 55 at pp. 7-8) CA IOUs agreed that due to the
limited number of modified spectrum IRLs on the market, the category
should be eliminated. (CA IOUs, Public Meeting Transcript, No. 49 at p.
20) ASAP and CA IOUs concluded that there is no need to make an
exemption or have a less efficacious standard for modified spectrum
lamps. (ASAP, Public Meeting Transcript, No. 49 at pp. 17-18; CA IOUs,
Public Meeting Transcript, No. 49 at p. 20) NEMA commented that
modified spectrum lamps, like 130 V lamps, cannot remain both cost
effective and compliant and referred DOE to manufacturer interviews for
additional details. (NEMA, No. 54 at p. 31)
As in the NOPR, DOE continues to believe that modified spectrum
lamps offer unique utility by providing a different spectrum of light.
79 FR at 24093 (April 29, 2014). Although more efficient technologies,
such as CFLs and LEDs, may offer similar spectrums, DOE must maintain
consumer utility for the products that are within the scope of this
rulemaking. Modified spectrum IRLs modify the spectral emission of a
lamp in such a way that lamp efficacy decreases. DOE acknowledges that
there are currently no modified spectrum products on the market.
However, DOE maintains that there are no technological barriers to
creating these products. DOE does not consider cost when establishing
product classes. Because modified spectrum lamps offer unique utility
but at lower efficacy compared to standard spectrum products, DOE
maintained the class division for lamp spectrum in this final rule.
c. Summary of IRL Product Classes
In this final rule analysis, DOE established product classes for
IRLs as summarized in Table VI.4. See chapter 3 of the final rule TSD
for further details on each IRL product class.
Table VI.4--IRL Product Classes in Final Rule Analysis
------------------------------------------------------------------------
Diameter (in
Lamp type inches) Voltage
------------------------------------------------------------------------
Standard Spectrum....................... >2.5 >=125 V
.............. <125 V
<=2.5 >=125 V
.............. <125 V
Modified Spectrum....................... >2.5 >=125 V
.............. <125 V
<=2.5 >=125 V
.............. <125 V
------------------------------------------------------------------------
[[Page 4065]]
D. Engineering Analysis
1. General Approach
The engineering analysis is generally based on commercially
available lamps that incorporate the design options identified in the
technology assessment and screening analysis. (See chapters 3 and 4 of
the final rule TSD for further information on technology and design
options.) The methodology consists of the following steps: (1)
Selecting representative product classes, (2) selecting baseline lamps,
(3) identifying more efficacious substitutes, and (4) developing
efficacy levels by directly analyzing representative product classes
and then scaling those efficacy levels to non-representative product
classes. The details of the engineering analysis are discussed in
chapter 5 of the final rule TSD. The following discussion summarizes
the general steps of the engineering analysis:
Representative product classes: DOE first reviews covered lamps and
the associated product classes. When a product has multiple product
classes, DOE selects certain classes as ``representative'' and
concentrates its analytical effort on these classes. DOE selects
representative product classes primarily because of their high market
volumes.
Baseline lamps: For each representative product class, DOE selects
a baseline lamp as a reference point against which to measure changes
resulting from energy conservation standards. Typically, a baseline
model is the most common, least efficacious lamp sold in a given
product class. DOE also considers other lamp characteristics in
choosing the most appropriate baseline for each product class such as
wattage, lumen output, and lifetime.
More efficacious substitutes: DOE selects higher efficacy lamps as
replacements for each of the baseline models considered. When selecting
higher efficacy lamps, DOE considers only design options that meet the
criteria outlined in the screening analysis (see section VI.B or
chapter 4 of the final rule TSD). For GSFLs, DOE pairs each lamp with
an appropriate ballast because fluorescent lamps are a component of a
system, and their performance is related to the ballast on which they
operate.
Efficacy levels: After identifying the more efficacious substitutes
for each baseline lamp, DOE develops ELs. DOE bases its analysis on
three factors: (1) The design options associated with the specific
lamps studied; (2) the ability of lamps across wattages to comply with
the standard level of a given product class; \26\ and (3) the max tech
EL. DOE then scales the ELs of representative product classes to those
classes not directly analyzed.
---------------------------------------------------------------------------
\26\ ELs span multiple lamps of different wattages. In selecting
ELs, DOE considered whether these multiple lamps can meet the
standard levels.
---------------------------------------------------------------------------
DOE received a comment regarding the general methodology of the IRL
engineering. GE recommended that DOE conduct two separate analyses for
the commercial sector and residential sector. GE noted that lamps in
the residential sector have shorter lifetimes, such as 1,500 hours, as
they are used less frequently and therefore need to be replaced less
often, especially if the lamps are on a dimmer. GE continued that the
commercial sector requires longer lifetimes of 3,000 to 4,000 hours
because lamps in commercial applications can be used up to 16 hours a
day. GE stated that the analyses would be skewed between the two
markets and that it would have a negative effect on the residential
market as residential consumers with their shorter hours of operation
are less likely to see the cost savings and payback that commercial
consumers would be able to accrue. GE proposed the idea that the
commercial and residential lamps could be differentiated by the typical
applications, wattages, and technical aspects for each sector. For
example, the PAR30 lamps could be treated as residential and PAR38
lamps as commercial. GE further commented that they understood that
separating the lamps by sector could be difficult, but that the
separation is necessary, as the proposed max tech levels applied across
sectors would have the unintended consequences of removing certain
utility and entire products from the market. (GE, Public Meeting
Transcript, No. 49 at pp. 105-106, 116-117) NEEA agreed that separate
analyses could be done for the commercial sector and for the
residential sector. Alternatively, NEEA also suggested segregating the
large commercial sector from the residential and small commercial
sectors, such as independent, family-owned businesses and other
consumers that purchase lighting similarly to homeowners. (NEEA, Public
Meeting Transcript, No. 49 at p. 131)
DOE acknowledges that lamps have varying levels of penetration in
different market sectors. However, there is nothing that would limit
the use of a covered IRL in a specific sector. Therefore, DOE does not
conduct sector-based assessments in the engineering analysis. Rather,
the LCC analysis and NIA consider lamp use in different market sectors.
The LCC analysis provides results for each analyzed lamp in each
relevant sector. See section VII.B.1 for results of the IRL LCC
analysis. The shipments analysis accounts for the number of shipments
by sector and the popularity of analyzed lamps in each sector. The
results are subsequently used in the NIA. See section VII.B.3 for
results of the NIA. Further, as part of the engineering analysis, when
selecting more efficacious substitutes and establishing efficacy
levels, DOE ensures that products at higher efficacy levels meet
baseline consumer needs. DOE's analysis of IRLs addresses the concerns
regarding lifetime and product availability. See section VI.D.3 for
further details. Therefore, DOE did not conduct separate engineering
analyses by sector for IRLs.
Stakeholders had several comments specific to the GSFL and IRL
engineering analyses presented in the NOPR. The following sections
discuss and address feedback received from stakeholders for each
product.
2. General Service Fluorescent Lamp Engineering
For GSFLs, DOE received several comments on the engineering
analysis presented in the NOPR. The following sections summarize the
comments and responses received on these topics, and present the GSFL
engineering methodology for this final rule analysis.
a. Data Approach
Usability of Certification Data and Catalog Data
Because not all commercially available products had associated
certification data, DOE was unable to rely solely on certification data
in the preliminary analysis. At the time of the NOPR analysis, DOE's
Compliance Certification Management System (CCMS) database \27\ only
contained data for 68 percent of the covered commercially available
lamps. Therefore, in the NOPR analysis, DOE continued to utilize
catalog data to identify baseline products and develop initial efficacy
levels. DOE then used available certification data to adjust the
initial efficacy levels so that the proposed levels could be met with
efficacies submitted for certification.
---------------------------------------------------------------------------
\27\ The publicly available compliance information for GSFLs can
be found in DOE's compliance Certification Database available here:
www.regulations.doe.gov/certification-data/.
---------------------------------------------------------------------------
NEMA commented that while catalog data is reviewed on a regular
basis, due to publication delays it may not reflect all products being
manufactured and, therefore, certification data would
[[Page 4066]]
provide a more realistic representation of products than catalogs. For
example, NEMA commented on DOE's assessment that only 68 percent of the
commercially available fluorescent lamps in the scope of this
rulemaking have certification data. NEMA stated that this percentage
suggests that products identified by DOE in catalogs are not really
made or sold as all manufacturers are required to submit certification
data to DOE on their products on an annual basis. (NEMA, No. 54 at p.
19)
DOE understands that catalog data is subject to publication delays
and may not be updated on a continuous basis. DOE frequently reviews
both the available catalog data and certification data. At the time of
the final rule analysis, DOE's certification database contained data
for 79 percent of the covered commercially available lamps. While this
percentage was an increase from the NOPR analysis, it still did not
represent a comprehensive dataset on which to base an engineering
analysis. Therefore, in this final rule analysis, DOE again utilized
both catalog data and certification data in order to assess all
available data. Specifically, DOE utilized catalog data to identify
baseline products and develop initial efficacy levels. This approach
ensured consideration of all available products. DOE then used
available certification data to adjust the initial efficacy levels, if
necessary, thereby ensuring that the adopted levels can be met based on
the certification values submitted by manufacturers to demonstrate
compliance with standards.
Regarding the certification data, NEMA stated that they had
determined that erroneous conclusions could be drawn from the data in
DOE's certification database. NEMA commented on an exchange with DOE
regarding the application of cathode heat during testing for T8 lamps
in the 4-foot MBP and 2-foot U-shaped product classes. NEMA stated that
the application of cathode heat for full wattage lamps and U-shaped
lamps is clear as they do not have high frequency specifications.
However, NEMA asserted that while ANSI C78.81-2010 specifies that the
reduced wattage (30 W, 28 W and 25 W) 4-foot MBP T8 lamps have
normative high frequency (HF) reference ballast circuits, DOE requires
they be tested at low frequency and permits exclusion of cathode heat,
which makes them appear more efficacious than full wattage lamps. NEMA
asserted that DOE certification database has erroneous values for
reduced wattage lamps for the following reasons: (1) There was a lack
of awareness of the exchange between DOE and NEMA on the subject of
cathode heat and high frequency circuits for reduced wattage lamps; (2)
the current DOE test procedure incorporates ANSI C78.81-2010, which
made high frequency reference photometry normative for reduced wattage
T8 lamps but requires that these lamps be tested at low frequency and
permits the removal of cathode heat, which makes them seem more
efficacious; and (3) DOE certification data is not required to be
resubmitted if there are no changes affecting efficacy of the basic
model. (NEMA, No. 54 at pp. 23-24)
DOE acknowledges that there may be confusion in the industry
regarding how to test certain lamp types. Per the DOE test procedure,
GSFLs are to be tested at low frequency unless only high frequency
reference ballast specifications are available. (See section 4.1.1 in
10 CFR 430, subpart B, appendix R.) Because low frequency settings
exist, 4-foot MBP lamps and 2-foot U-shaped lamps must be tested at low
frequency. For lamps tested at high frequency, the industry standard
referenced by the DOE test procedure, LM-9-09,\28\ specifies that
cathode heat is not utilized for high frequency circuits. Manufacturers
are encouraged to contact [email protected]
with questions regarding DOE's test procedure.
---------------------------------------------------------------------------
\28\ ``IES Approved Method for the Electrical and Photometric
Measurement of Fluorescent Lamps'' (approved Jan. 31, 2009).
---------------------------------------------------------------------------
Calculation of Efficacy
DOE calculated efficacy as the initial lumen output published in
manufacturer catalogs divided by the ANSI rated wattage. For lamp types
that do not have a defined ANSI rated wattage, DOE utilized the lamp's
nominal wattage to calculate catalog efficacy. For example, because
reduced wattage 4-foot T5 MiniBP HO lamps do not have a defined ANSI
rated wattage, DOE used their nominal wattages, either 49 W or 47 W, to
calculate efficacy.
NEMA commented on DOE's use of catalog lumens and ANSI wattage to
determine catalog efficacy, stating that lamp wattage may vary when
measuring catalog lumens for rating purposes. Further, NEMA noted that
the ANSI-typical electrical characteristics are given for informational
use only and that any determination of lamp power or efficacy from
these values would be considered as rough estimates. (NEMA, No. 54 at
p. 23)
ANSI rated wattage is the result of standardized ANSI testing and
represents an industry agreed upon wattage. As noted by NEMA in
response to the preliminary analysis, the rated wattage is based on the
average of a very large number of samples and manufacturers produce
lamps to fall on and around that point. Therefore, the individual lamp
tested wattage will differ from this rated value of that lamp. NEMA
stated that it would defer to its members, but in general it supported
using the ANSI rated wattage rather than the measured wattage. 79 FR at
24095 (April 29, 2014). Lamp wattage is also reported by manufacturers
in the CCMS database. However, DOE identified inconsistencies with the
reported wattage. For example, some manufacturers appeared to report
nominal wattage rather than measured wattage. DOE notes that using the
ANSI rated wattage provides a conservative rating for the efficacy for
several lamp types, specifically those lamp types tested at low
frequency (i.e., 4-foot MBP, 2-foot U-shaped, and 8-foot SP slimline).
Therefore, DOE continued to use the ANSI defined rated wattage in this
final rule.
For lamp types that do not have a defined ANSI rated wattage, DOE
utilized the lamp's nominal wattage to calculate catalog efficacy. NEMA
commented that the assumption that the rated wattage and nominal
wattage of reduced wattage 4-foot T5 MiniBP HO lamps are the same is
not valid. NEMA noted that until an industry standard is completed,
these values are speculative in nature. (NEMA, No. 54 at p. 26)
DOE acknowledges that reduced wattage 4-foot T5 MiniBP HO lamps do
not have a defined rated wattage. However, DOE believes that the
nominal wattage is a reasonable approximation of rated wattage for
these lamps, based on the guidelines for defining nominal wattage in
ANSI C78.81. After developing initial levels based on efficacies
calculated using catalog data and ANSI wattages, DOE reviewed
certification data. The reported values for efficacy are based on
measured lumen output and measured wattage as specified in DOE's test
procedures for GSFLs set forth at 10 CFR part 430, subpart B, appendix
R. Utilizing ANSI rated wattage to calculate catalog efficacy and
reported efficacy for developing final efficacy levels eliminates the
uncertainty associated with the wattages reported for compliance.
Rounding
NEMA disagreed with DOE's current GSFL test procedure that requires
efficacies be reported to the nearest tenth. 10 CFR 430.23(r)(2) NEMA
stated that due to the uncertainty of
[[Page 4067]]
measurement, reporting lumen values to the nearest tenth was
statistically incorrect and could result in enforcement issues; and
further recommended that DOE require efficacies to be rounded to the
nearest lumen per watt. Specifically, NEMA quoted that the National
Institute of Standards and Technology (NIST) TL standards measurement
of expanded uncertainty is 1.6 percent (coverage factor k=2). NEMA
provided the example that a highly stable 3,000-lumen F32T8 fluorescent
lamp based on NIST standards would result in an uncertainty for the
reported mean of +/- 33 lumens for 21 samples. Further, NEMA stated
that in addition to being contrary to the NIST ``Guidelines for
Evaluating and Expressing the Uncertainty of NIST Measurement Results''
(GUM) rounding to the nearest tenth also did not align with
International Laboratory Accreditation Cooperation (ILAC) Policy for
Uncertainty in Calibration (ILAC-P14:01/2013). The policy states that
the expanded uncertainty should be at most two significant figures and
the final result rounded to the least significant figure in the value
of the expanded uncertainty assigned to the measurement result. NEMA
noted that an accredited laboratory with measurements traceable to SI
units through a National Metrology Institute cannot have a measurement
uncertainty less than the artifact samples utilized to calibrate their
systems and random lamp production samples would add further
uncertainty. (NEMA, No. 54 at pp. 15-16)
As specified in DOE's test procedures for GSFLs set forth at 10 CFR
part 430, subpart B, appendix R, lamp efficacy is the ratio of measured
lumen output in lumens to the measured lamp electrical power input in
watts rounded to the nearest tenth in units of lumens per watt. In the
2009 final rule for the GSFL and IRL test procedure, DOE amended the
test procedure to require reported efficacy measurements for GSFLs to
be rounded to the nearest tenth of a lumen per watt allowing for future
energy conservation standards to be rounded to the nearest tenth of a
lumen per watt. 74 FR 31829, 31836 (July 6, 2009). DOE concluded this
amendment to the test procedure was feasible because manufacturers
routinely generate test results that would allow reporting to at least
the tenth of a lumen per watt level. 74 FR at 31836 (July 6, 2009).
Therefore, DOE analyzed efficacy levels in this rulemaking rounded
to the nearest tenth of a lumen per watt as DOE maintains that this is
an achievable level of accuracy.
b. Representative Product Classes
When a covered product has multiple product classes, DOE identifies
and selects certain product classes as representative and analyzes
those product classes directly. DOE chooses these representative
product classes primarily due to their high market volumes. In the
NOPR, DOE identified all GSFLs with CCTs less than or equal to 4,500 K
with the exception of the 2-foot U-shaped lamps as representative
product classes. 79 FR at 24096 (April 29, 2014). DOE received no
comments on this subject and therefore maintained the same
representative product classes for the final rule.
c. Baseline Lamps
Once DOE identifies representative product classes for analysis, it
selects baseline lamps to analyze in each class. Typically, a baseline
lamp is the most common, least efficacious lamp that just meets
existing energy conservation standards. In the NOPR, DOE proposed
baselines at the existing standard levels for all product classes. Id.
at 24097-98. For the 4-foot MBP and 8-foot slimline product classes,
DOE determined the baseline to be the least efficient product on the
market at the existing standard level. For representative product
classes in which there were no commercially available lamps at the
existing standard level, DOE modeled baseline lamps. Feedback from
stakeholders and manufacturer interviews indicated that manufacturers
will likely produce lamps at the existing standard level even if no
products are currently available. Further, after the 2009 Lamps Rule,
DOE observed the introduction of products that were not previously
available at the newly adopted standard levels for some product
classes. Thus, DOE believed this trend could continue and additional
lamps may be offered that just meet the existing standard level for the
remaining product classes. In the NOPR, DOE modeled baseline lamps for
the 8-foot RDC HO, T5 MiniBP SO, and T5 MiniBP HO product classes. Id.
NEMA agreed with the baselines selected for GSFLs based on the data
in DOE's certification database, but noted its concern that product
performance may be overstated due to data entry errors in the
certification database or the use of catalog data that shows higher
than actual performance of products. (NEMA, No. 54 at p. 17)
Because DOE received no comments to the contrary, DOE analyzed the
same baselines in the final rule analysis as analyzed in the NOPR. DOE
selected commercially available lamps as baselines for the 4-foot MBP
and 8-foot slimline product classes and modeled baseline lamps for the
8-foot RDC HO, T5 MiniBP SO, and T5 MiniBP HO product classes.
Regarding overstated product performance, DOE addresses discrepancies
within the available data sets in section VI.D.2.a and discusses its
methodology for developing efficacy levels in section VI.D.2.g.
d. More Efficacious Substitutes
DOE selects more efficacious replacements for the baseline lamps
considered within each representative product class. DOE considers only
design options identified in the screening analysis. In the NOPR, these
selections were made such that potential substitutions maintained light
output within 10 percent of the baseline lamp's light output with
similar performance characteristics, when possible. 79 FR at 24098
(April 29, 2014). DOE also sought to keep other characteristics of
substitute lamps as similar as possible to the baseline lamps, such as
rated life, CRI, and CCT. In identifying the more efficacious
substitutes, DOE utilized a database of commercially available lamps.
DOE received several comments regarding its choices for more
efficacious substitutes in the NOPR.
Four-Foot MBP Lamps
In the NOPR analysis, DOE analyzed two levels for 4-foot MBP lamps
above the baseline, with the highest level represented by a more
efficacious full wattage 4-foot MBP lamp and two reduced wattage lamps
(28 W and 25 W) that are commercially available.
CA IOUs questioned why DOE did not consider 30 W lamps in its
analysis, which would be another opportunity to save energy and stay
within 10 percent of lumen output. (CA IOUs, Public Meeting Transcript,
No. 49 at pp. 94-95)
DOE analyzed a database of commercially available lamps to identify
the most common characteristics of lamps in each product class
including wattage. DOE found the 30 W 4-foot MBP lamp to be
significantly less common than the 28 W and 25 W wattages. Manufacturer
feedback confirmed the most popular reduced wattage lamps in the 4-foot
MBP product class to be 28 W and 25 W. Further, for consumers who
choose to purchase a reduced wattage product, DOE believes the 28 W and
25 W products capture both options available: one that saves energy
while maintaining lumen output within 10 percent of the lumen output of
typical 32 W products and one that saves more energy but offers
slightly lower lumen output. Because 28 W lamps are more
[[Page 4068]]
efficacious than 30 W lamps and save more energy, DOE believes that
consumers opting to purchase reduced wattage lamps will choose 28 W
lamps rather than 30 W lamps. Therefore, DOE continued to analyze only
28 W and 25 W reduced wattage 4-foot MBP lamps in the final rule.
T5 MiniBP HO Lamps
In the NOPR analysis, DOE modeled a baseline lamp for the T5 HO
product class because a commercially available lamp was not offered at
the existing standard level. DOE analyzed one level above the baseline,
represented by a more efficacious full wattage T5 HO lamp and two
reduced wattage T5HO lamps that are commercially available.
NEMA noted that DOE should not use modeled lamps to determine more
efficacious substitutes for T5 MiniBP HO lamps. (NEMA, No. 54 at p. 18)
NEMA stated that if a more efficacious design was possible it would
already be commercially available. Because of the high bulb wall
temperatures in T5 MiniBP HO lamps, there are many characteristics to
consider such as phosphor loading, cold spot control, cathode design,
gas fill for reduced wattage products, and overall design for optimal
performance at 35 [deg]C. Further, NEMA was skeptical that DOE could
produce measured data that demonstrates manufacturability of the more
efficacious modeled T5 MiniBP HO lamp. (NEMA, No. 54 at p. 26)
As noted in section VI.D.3.b in response to stakeholder comments
DOE modeled a baseline lamp for the NOPR analysis because the T5 HO
product class does not have a commercially available lamp that just
meets the existing standard. Because there are full wattage products
that have demonstrated efficacy higher than the existing standard, DOE
believes the modeled baseline lamp is feasible. Based on this new
baseline, in the NOPR analysis DOE was able to identify a more
efficacious full wattage T5 HO substitute that is commercially
available. For the final rule, DOE continues to analyze the same
baseline and higher efficacy replacements, including the commercially
available full wattage T5 HO lamp.
e. General Service Fluorescent Lamp Systems
Because fluorescent lamps operate on ballasts in practice, DOE
analyzed lamp-and-ballast systems, thereby more accurately capturing
real-world energy use and light output. In the DOE test procedure for
GSFLs, and therefore in this rulemaking, lamp efficacy is based on the
initial lumen output. However, because light output decreases over
time, DOE analyzed more efficacious systems that maintain mean lumen
output \29\ within 10 percent of the baseline system, when possible.
Further, DOE selected replacement systems that do not have higher
energy consumption than the baseline system.
---------------------------------------------------------------------------
\29\ Mean lumen output is a measure of light output midway
through the rated life of a lamp.
---------------------------------------------------------------------------
DOE considered two different scenarios: (1) A lamp replacement
scenario in which the consumer selects a reduced wattage replacement
lamp that can operate on the installed ballast and (2) a lamp-and-
ballast replacement scenario in which the consumer selects a lamp that
has the same or lower wattage compared to the baseline lamp and also
selects a new ballast with potentially different performance
characteristics, such as ballast factor \30\ (BF) or ballast luminous
efficiency \31\ (BLE). In the second scenario DOE attempted to select a
ballast that would result in energy savings and still maintain the mean
lumen output within 10 percent of the baseline. DOE identified a new
lamp-and-ballast system by pairing a more efficacious lamp with a
commercially available ballast that had the lowest BF possible that
still maintained system mean lumen output within 10 percent of the
baseline system. When multiple ballast options with the same BF
existed, DOE selected the most efficient ballast based on the BLE
metric, as this was considered to be the most likely ballast substitute
in a lamp-and-ballast replacement scenario designed to achieve energy
savings. If it was not possible to identify a lamp-and-ballast
replacement that maintained the 10 percent mean lumen output criterion,
DOE prioritized energy savings and analyzed a lamp-and-ballast system
that reduced light output by more than 10 percent \32\ but saved energy
relative to the baseline system.
---------------------------------------------------------------------------
\30\ BF is defined as the output of a ballast delivered to a
reference lamp in terms of power or light divided by the output of
the relevant reference ballast delivered to the same lamp (ANSI
C82.13-2002). Because BF affects the light output of the system,
manufacturers design ballasts with a range of ballast factors to
allow consumers to vary the light output, and thus power consumed,
of a fluorescent system. See the 2011 Ballast Rule final rule TSD
Chapter 3. The Ballast Rule materials are available at
www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016.
\31\ BLE is the ratio of the total lamp arc power to ballast
input power multiplied by the appropriate frequency adjustment
factor.
\32\ Light output was reduced up to 18 percent in some
replacement scenarios. The percent reduction in light output was
based on the ballast factor of the commercially available ballasts
analyzed. For more information, see chapter 5 of the NOPR TSD.
---------------------------------------------------------------------------
NEMA disputed the energy savings demonstrated by the lamp-and-
ballast systems. NEMA commented that re-ballasting is not common and
thus spaces will more likely be overlit and consume the same amount of
system energy. NEMA asserted that a 32 W fluorescent lamp, even if it's
more efficacious, will consume the same amount of energy.\33\ If
ballasts were replaced, NEMA disagreed with DOE's assessment that, in
new construction and retrofit scenarios, lamps will be paired with low
ballast factor ballasts to result in lower system energy use. Further,
NEMA noted that DOE's analysis shows a 2-3 percent change in system
lumen output which does not align with the existing 10 percent steps in
ballast factors. (NEMA, No. 54 at p. 18)
---------------------------------------------------------------------------
\33\ If paired with a dimming ballast, energy savings may be
possible if the system is adjusted to maintain the same light output
of the replaced system.
---------------------------------------------------------------------------
DOE agrees that a ballast is not always replaced when a lamp fails.
DOE analyzes a lamp replacement scenario in which the existing ballast
is not replaced and a consumer saves energy by choosing a reduced
wattage lamp. For the instances in which the consumer replaces both a
lamp and ballast, DOE analyzes a lamp-and-ballast replacement scenario
in which a consumer can achieve energy savings by pairing a new lamp
with an improved ballast. DOE selected commercially available ballasts
to pair with representative lamps and found ballasts with ballast
factors available in increments smaller than 10 percent.
DOE received several comments regarding the light level that must
be maintained when analyzing replacement lamp-and-ballast systems. CA
IOUs stated that they were aware that lumens depreciate over time,
decreasing to about 30 percent of initial lumen output. Further, they
added that in a lighting retrofit the replacement of a new lamp-and-
ballast system can result in up to a 15-17 percent increase in light
output, and consumers actually respond negatively to this increase.
Therefore, CA IOUs suggested that when examining different scenarios of
sacrificing increased light over energy savings or vice versa, DOE
prioritize energy savings and maintaining reasonable light levels. (CA
IOUs, Public Meeting Transcript, No. 49 at pp. 93-94) NEMA disagreed
with the comment made by the CA IOU's during the NOPR public meeting
that consumers would not like increased light levels and a decrease of
up to 10 percent of lumens would still be too much light for consumers.
NEMA stated that recent studies show that the aging population
[[Page 4069]]
requires higher light levels and regardless, does not agree that
decreasing light by 10 percent in place of energy savings for all
applications is acceptable due to lumen depreciation resulting in light
that does not meet the required needs, creates safety issue, or
violates building codes. (NEMA, No. 54 at pp. 18-19)
DOE notes that, while it may be possible to decrease light output
by more than 10 percent in certain situations to maximize energy
savings, it is likely not acceptable in all applications. DOE tried to
select lamp-and-ballast systems that maintained mean lumen output
within 10 percent of the baseline system, when possible. For the lamp-
and-ballast replacement scenario, DOE attempted to select a ballast
that would result in energy savings and still maintain the mean lumen
output within 10 percent of the baseline. In cases where energy savings
were not possible without going beyond the 10 percent threshold of the
baseline mean lumen output, DOE gave priority to energy savings.
DOE also received comments regarding the pairing of GSFLs with
dimming ballasts. CA IOUs noted that California's new building codes
will potentially require almost all lighting to use dimming ballasts
and therefore the ballasts may become common in other states as well.
CA IOUs noted that this presents another opportunity for saving energy
without increasing light. (CA IOUs, Public Meeting Transcript, No. 49
at pp. 94-96) CA IOUs requested clarification on compatibility issues
when dimming fluorescent lamps because of the expected increase in the
use of dimming products in California. (CA IOUs, Public Meeting
Transcript, No. 49 at p. 63) ASAP noted that there are reduced wattage
lamps that are able to be dimmed and because it is an improving
situation, the analysis should not be so rigid as to require that there
always be full wattage lamps available. (ASAP, Public Meeting
Transcript, No. 49 at p. 65) GE responded that while reduced wattage
lamps can be dimmed, their use of krypton makes them more susceptible
to striations which are unacceptable to the consumer. GE added that
because of this issue, major companies recommend using full wattage
lamps with dimming systems as actual energy savings are obtained from
the wattage at which the lamps are being operated rather than their
efficacy. (GE, Public Meeting Transcript, No. 49 at pp. 66-67)
DOE agrees with the CA IOUs that the market share of dimmable
systems may increase in the future and therefore continued to analyze
dimmable systems in the final rule. While certain dimming ballasts are
listed as compatible for operation with both full and reduced wattage
lamps, DOE continues to receive feedback that there can be issues with
dimming reduced wattage lamps. Specifically DOE received feedback from
manufacturer interviews that problems that can be encountered when
dimming linear fluorescent lamps, including difficulties in lamp
starting, striations, and dropout, are exacerbated by the use of
krypton in reduced wattage lamps. Because of these issues, DOE has
continued to ensure that full wattage lamps can meet the efficacy
levels analyzed.
In the final rule, DOE continued to analyze GSFLs operating on
fluorescent lamp ballasts. In situations where a consumer selects a new
ballast in addition to a new lamp, DOE allows the consumer to select a
new ballast with potentially different performance characteristics,
such as BF \34\ or BLE.\35\ DOE maintained the same methodology
described previously in this section to select ballasts in the final
rule. However, due to certain products being discontinued and new
products introduced, certain ballast selections in the final rule for
the 4-foot MBP, 8-foot SP slimline, and 8-foot RDC HO product classes
were updated. See chapter 5 of the final rule TSD for additional
detail.
---------------------------------------------------------------------------
\34\ BF is defined as the output of a ballast delivered to a
reference lamp in terms of power or light divided by the output of
the relevant reference ballast delivered to the same lamp (ANSI
C82.13-2002). Because BF affects the light output of the system,
manufacturers design ballasts with a range of ballast factors to
allow consumers to vary the light output, and thus power consumed,
of a fluorescent system. See the 2011 Ballast Rule final rule TSD
Chapter 3. The Ballast Rule materials are available at
www.regulations.gov/#!docketDetail;D=EERE-2007-BT-STD-0016.
\35\ BLE is the ratio of the total lamp arc power to ballast
input power multiplied by the appropriate frequency adjustment
factor.
---------------------------------------------------------------------------
f. Max Tech
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max tech'') improvements in efficacy for GSFLs using the
design parameters for the most efficient products available on the
market or in working prototypes.
NEMA advised DOE to be wary of claims of ultra-performance lamps in
the certification database, particularly since there have been no
technology breakthroughs since the 2009 Lamps Rule and therefore, the
max tech established in that rulemaking should not change. (NEMA, No.
54 at p. 25, 29)
In reviewing available certification data, DOE considered the
possibility of exorbitant claims or incorrect data. DOE identified
several efficacy values that it did not consider feasible for
fluorescent lamp technology and therefore did not consider in this
analysis. In general, these outliers were identified based on the
reported wattage, which indicated that these lamps may not have been
tested correctly. However, DOE still identified several commercially
available lamps performing at efficacy levels higher than the max tech
levels established in the 2009 Lamps Rule based on catalog data and
certification data. Thus, manufacturers appear to be utilizing more
advanced technologies or to be more efficiently utilizing existing
technologies.
g. Efficacy Levels
After identifying more efficacious substitutes for each of the
baseline lamps, in the NOPR DOE developed ELs based on the
consideration of several factors, including: (1) The design options
associated with the specific lamps being studied (e.g., grades of
phosphor for GSFLs); (2) the ability of lamps across wattages to comply
with the standard level of a given product class; and (3) the max tech
level. When evaluating ELs in the NOPR, DOE considered only ELs at
which a full wattage version of the lamp type was available because
reduced wattage lamps have limited utility. 79 FR at 24103 (April 29,
2014). DOE received several comments on the ELs considered in the NOPR.
Clarification of Standard Levels
ASAP commented that the rulemaking for GSFLs is a performance
standard and not a design standard, thus ensuring that full wattage
lamps are available should not be a constraint for DOE. (ASAP, Public
Meeting Transcript, No. 49 at pp. 50-51)
DOE agrees with ASAP that the efficacy levels analyzed in this rule
are performance standards rather than design standards. Thus, DOE does
not dictate how manufacturers must comply with a standard (i.e.,
requiring that they produce full wattage lamps). However, DOE must
evaluate standards that do not lessen utility or performance of a
product. (42 U.S.C. 6295(o)(2)(B)(i)(IV)) As described in section
VI.D.2.e, DOE has determined that reduced wattage lamps cannot be used
in all of the same dimming systems as full wattage lamps due to the
addition of krypton gas. Therefore, DOE has established a
[[Page 4070]]
performance standard such that manufacturers can continue to produce
full wattage lamps if required by consumers.
Methodology To Develop Efficacy Levels
EEOs agreed with DOE's approach using catalog lumens and ANSI
wattages for GSFLs to establish initial efficacy levels and then
adjusting the levels based on certification data to ensure that
certified values could meet proposed standards. EEOs did note that DOE
had not provided specifics of the adjustments based on certification
data. Based on its observations of the certified efficacy levels for a
significant number of lamps, from several manufacturers, EEOs
determined that the proposed standard levels for the 4-foot and 8-foot
T8/T12 products were reasonable. (EEOs, No. 55 at pp. 4-5)
However, manufacturers offered several comments regarding the
methodology for determining efficacy levels and how it might affect
manufacturers' ability to comply with an adopted standard level. NEMA
stated that manufacturers design products around the midpoint of a bell
distribution curve, and therefore when the required standard is below
the max-tech level, manufacturers have room to make adjustments (e.g.,
reducing lifetime, adding costly material) to ensure that all their
products can meet the standard level. However, NEMA stated that because
DOE's proposed standards for GSFLs are approaching max-tech, the design
mid-point is above this max-tech level which does not allow
manufacturers to build in production tolerances that would ensure
compliance. (NEMA, No. 54 at p. 12) GE stated that if DOE sets the
level at the upper tail of the distribution of data, it will be
requiring efficacies above max tech which is at the center of that
distribution. GE encouraged DOE to use the information in NEMA Lighting
System Division (LSD)-63 Measurement Methods and Performance Variation
for Verification Testing of General Purpose Lamps and Systems paper to
analyze data in the DOE certification database and assess the variation
between test measurements and in production. (GE, Public Meeting
Transcript, No. 49 at pp. 86-88) Further, NEMA noted that while there
is no statutory definition for the term ``standard,'' NEMA quoted
specification of the term put forth by the International Standards
Organization and the Office of Management and Budget. NEMA stressed
that a standard must be capable of being met consistently and
repeatedly by manufacturers and one that cannot be is not within DOE's
authority to promulgate. (NEMA, No. 54 at p. 13)
To demonstrate compliance with standards, DOE requires
manufacturers to test a minimum of 21 lamps according to the procedures
described in 10 CFR 430, subpart B, Appendix R and report a value that
does not exceed the lower of the sample mean or the 95 percent lower
confidence limit (LCL) of the true mean divided by 0.97. The greater
the variation in the tested sample, the more likely that manufacturers
will report the second value (i.e., LCL). DOE notes that the statistics
included in the compliance procedures are intended to ensure that
manufacturers are reporting a value that approximates the population
mean. Each tested lamp is not individually required to meet or exceed
the standard level. Designing products such that their population mean
or the performance of each individual lamp unit within the population
exceeds DOE's standard level is not required and is done so at the
discretion of individual manufacturers.
DOE believes the efficacy levels analyzed in this rulemaking
represent expected population means rather than outlier data in the
high end of a bell distribution curve. DOE received feedback from
manufacturers during interviews that catalog data represents the long
term average performance of products. DOE uses catalog data to
establish initial efficacy levels. DOE then compares the efficacy
levels to available certification data and adjusts the levels downward
if necessary. DOE does not believe that the certification values
represent outlier data in the high end of a bell distribution curve.
Manufacturers must select a minimum of three lamps from each month of
production for a minimum of 7 months out of a 12-month period.\36\ It
is unlikely that selecting lamps from multiple months of production
over the course of a year will result in a value that is consistently
in the high end of a bell distribution curve. Furthermore, if
manufacturers believe their test results are artificially high, they
have the opportunity to report a more conservative value as DOE allows
manufacturers to rate the product within the range of the existing
standard up to the lower of the LCL divided by 0.97 or the mean. See 10
CFR part 430, subpart B, Appendix R.
---------------------------------------------------------------------------
\36\ In the instance where production occurs during fewer than 7
of such 12 months, the manufacturer shall randomly select 3 or more
lamps from each month of production, where the number of lamps
selected for each month shall be distributed as evenly as
practicable among the months of production to attain a minimum
sample of 21 lamps.
---------------------------------------------------------------------------
Using this methodology, DOE accounts for variation in tested
samples and ensures efficacy levels are based on values determined by
DOE's test procedures and reported by manufacturers themselves. In this
final rule, DOE has maintained the same methodology to develop efficacy
levels.
Long-Life Lamps
NEMA stated that GSFL manufacturers have recently introduced
reduced wattage 4-foot T8 MPB lamps with 84,000-90,000 hour life and
full wattage (dimmable) lamps with 67,000-70,000 hour life. NEMA noted
that these products offer more than twice the life and better lumen
maintenance than standard product with the same initial lumens,
attributes that provide consumer utility. However, NEMA asserted that
the proposed efficacy standard levels will eliminate the 4-foot 32 W
dimmable long life and 28W long life lamps leaving only the 25W long
life lamps and also eliminate a patchwork of full and reduced wattage
standard lamps between 42,000 and 52,000 hours. Additionally, NEMA
stated the T5 MiniBP HO long-life product would also not be able to
meet the proposed standard. NEMA also warned that industry would not
produce new products in response to the proposed standards but instead
reduce existing product offerings and re-purpose existing products,
resulting in decreased consumer satisfaction. Citing T5s specifically,
NEMA stated that in order to offer choices to consumers, manufacturers
may have to add more rare earth phosphors increasing production costs
and then also have to decrease life to lower cost to the consumer.
(NEMA, No. 54 at pp. 17-18, 47-48)
DOE reviewed catalog data to identify the long life products cited
by NEMA. DOE found that while some manufacturers did offer long life
products, the lifetimes of these products were inconsistent across the
industry. For example, some manufacturers' long life products are
similar in lifetime to other manufacturers' standard life products.
While catalog data indicates that some designated long life products
would meet analyzed efficacy levels, certification data is noticeably
lower, suggesting that these products may not meet the highest level
analyzed. DOE believes that lifetime is a feature valued by consumers.
However, DOE considers lifetime to be an economic issue unless a
standard requires the shortening of lamp lifetime beyond that which is
typically available. Because the highest
[[Page 4071]]
standard level analyzed will still maintain the availability of 4-foot
MBP GSFLs with lifetimes ranging from 30,000 to 50,000 hours,\37\ DOE
did not adjust the efficacy levels in this final rule due to lifetime.
---------------------------------------------------------------------------
\37\ Based on 3-hour programmed start operation.
---------------------------------------------------------------------------
Four-Foot MBP Lamps
In the NOPR, DOE analyzed a standard 800 series full wattage T8
lamp at the baseline. (See chapter 5 of the NOPR TSD.) DOE identified
two levels of efficacy above the baseline. Based on catalog data, DOE
determined EL 1 (90.0 lm/W) represented an improved 800 series full
wattage T8 lamp and EL 2 (93.0 lm/W) represented an 800 series high
lumen output full wattage T8 lamp and the 25 W and 28 W reduced wattage
lamps. DOE analyzed available certification information and found that
EL 1 did not need to be adjusted from 90.0 lm/W. DOE adjusted EL 2 from
93.0 lm/W to 92.4 lm/W based on certification data. DOE received
several comments on the levels analyzed for 4-foot MBP lamps.
NEMA commended DOE on taking an analytical approach rather than
relying only on catalog data or DOE certification data to determine
efficacy levels for the 4-foot MBP product class. However, NEMA stated
that the limitations of both the catalog and DOE certification data
need to be considered to understand the efficacy distribution and max
tech of 4-foot MBP lamps with CCT <= 4,500 K. (NEMA, No. 54 at p. 22)
NEMA commented on figure 5.3.2 of chapter 5 of the NOPR TSD, which
shows the certification data for the 4-foot MBP lamps with a CCT less
than 4,500 K. NEMA noted that the reported reduced wattage T8 lamp data
spreads up to 10-11 percent over the max tech, plausibly indicating a
mixture of properly measured 60 Hz photometry without cathode heat and
erroneously reported measurements made using the normative ANSI HF
ballast reference circuit. (NEMA, No. 54 at p. 24)
As mentioned in section VI.D.2.f, DOE agrees that there may be
outliers in certification data due to manufacturers' confusion
regarding how to test certain lamp types. DOE developed initial levels
based on catalog data and then adjusted the levels based on available
certification data. DOE did not adjust levels upward but rather
adjusted levels downward if certification data was noticeably lower
than catalog data. Thus the erroneously reported measurements cited by
NEMA would not have resulted in an increased standard level.
NEMA conducted a detailed review of how the efficacy levels
analyzed in the NOPR compared to the available certification data. NEMA
noted that the 8 percent tolerance for a 21 sample size and 99 percent
confidence limit specified in NEMA's LSD 63-2012 guidance aligns with
the spread of certification data for full wattage lamps. Further, NEMA
noted that the high lumen full wattage lamps falling at the upper
levels of 96 lm/W represents max tech measured with favorable lab
measurement bias per LSD 63-2012. (NEMA, No. 54 at p. 24)
NEMA stated that the average maximum technically feasible 4-foot
MBP T8 lamp efficacy measured at 60 Hz with cathode heat is close to 92
lm/W. NEMA noted that setting a standard close to the max tech level of
92 lm/W could result in sample measurement variation below the
requirement approaching 50 percent and unintended consequences such as
statistical production disruption of compliant designs. NEMA concluded
that DOE should maintain the current standard at 89 lm/W for 4-foot MBP
T8 lamps to allow for the manufacturability of consistently compliant
products. (NEMA, No. 54 at p. 24)
GE offered a slightly different opinion on the average maximum
technologically feasible efficacy for 4-foot MBP lamps. GE expressed
concern that for the 4-foot MBP product class, EL 1 represented the
central tendency of a distribution and EL 2 at 92.4 lm/W was based on a
data point from DOE's certification database that happened to come out
at the higher tail of a distribution. GE noted this as normal
statistical variation when taking small samples of large quantities of
lamps. (GE, Public Meeting Transcript, No. 49 at pp. 86-87)
NEMA noted its concern that the rulemaking is not following well-
established rules for the treatment of statistical variation as applied
to the production of compliant lamps. NEMA stated that for the 4-foot
MBP product class, the proposed efficacy level of 92.4 lm/W is
considered the midpoint of the normal distribution performance curve of
compliant lamps. However, because the Certification, Compliance, and
Enforcement (CCE) rule (76 FR 12422 (March 7, 2011)) requires almost
all lamps to meet the proposed efficacy level, manufacturers would have
to design their products above the midpoint which would result in
eliminating most of the current best performing argon-based product
lines. NEMA also noted that the response that lamps listed in the CCMS
database meet the level is not adequate because it ignores differences
due to the understanding of reporting requirements and optimistic
manufacturer claims. NEMA concluded that DOE is proposing manufacturers
consistently and repeatedly produce products above the max tech. (NEMA,
No. 54 at p. 22)
As described previously in this section, the statistics included in
the compliance procedures are intended to ensure that manufacturers are
reporting a value that approximates the population mean. Each tested
lamp is not individually required to meet or exceed the standard level.
Designing products such that their population mean or the performance
of each individual lamp unit within the population exceeds DOE's
standard level is not required and is done so at the discretion of
individual manufacturers.
DOE believes the efficacy levels analyzed in this rulemaking
represent expected population means rather than outlier data in the
high end of a bell distribution curve. DOE received feedback from
manufacturers during interviews that catalog data represents the long
term average performance of products. DOE uses catalog data to
establish initial efficacy levels. DOE then compares the efficacy
levels to available certification data and adjusts the levels downward
if necessary. DOE does not believe that the certification values
represent outlier data in the high end of a bell distribution curve.
Manufacturers must select a minimum of three lamps from each month of
production for a minimum of 7 months out of a 12-month period.\38\ It
is unlikely that selecting lamps from multiple months of production
over the course of a year will result in a value that is consistently
in the high end of a bell distribution curve. Furthermore, if
manufacturers believe their test results are artificially high, they
have the opportunity to report a more conservative value as DOE allows
manufacturers to rate the product within the range of the existing
standard up to the lower of the LCL divided by 0.97 or the mean as
determined per 10 CFR 429.27(a)(2)(i).
---------------------------------------------------------------------------
\38\ In the instance where production occurs during fewer than 7
of such 12 months, the manufacturer shall randomly select 3 or more
lamps from each month of production, where the number of lamps
selected for each month shall be distributed as evenly as
practicable among the months of production to attain a minimum
sample of 21 lamps.
---------------------------------------------------------------------------
Using this methodology, DOE accounts for variation in tested
samples and ensures efficacy levels are based on values determined by
DOE's test procedures and reported by manufacturers themselves. In this
final
[[Page 4072]]
rule, DOE has maintained the same methodology to develop efficacy
levels.
NEMA stated that very high efficacy levels proposed and the
impossibility of reliably meeting them indicates that consumers will
lose the full-wattage (argon-based) lamps in some product categories.
NEMA asserted that this would push consumers to reduced wattage
(krypton-based) lamps which DOE has acknowledged are not suitable for
dimming applications. Further, NEMA stated that control systems are
expected to deliver more national energy savings than the 2 percent
efficacy difference between the proposed EL 1 and EL 2 levels. NEMA
asserted that the proposed EL 2 limits the dimmability and energy
saving potential if argon-based lamps cannot meet the level as they can
dim far more than 2 percent lower than krypton-based lamps. NEMA also
noted that end users may not be aware of potential issues that can
occur if reduced wattage lamps are used in the wrong application.
(NEMA, No. 54 at p. 27, 48)
NEMA stated that in order to ensure that dimmable argon-based lamps
are available to take advantage of energy saving controls, the proposed
efficacy level must be properly adjusted downward to make the low end
of the bell distribution curve the midpoint and allow industry to be
compliant. Specifically, the level must be maintained at 89 lm/W to
assure that the very long life high performing argon lamps survive in
the marketplace. (NEMA, No. 54 at pp. 22-23)
NEEP commented that high efficacy lamps do not impede control
capabilities. NEEP added that the proposed TSL 5 efficacy level allows
for 4-foot MBP full-wattage ``high-lumen'' T8 lamps that have the same
control and dimming performance as lower efficacy lamps eliminated by
the standard. (NEEP, No. 57 at p. 2)
As stated previously in this section, DOE disagrees that the
analyzed levels cannot be reliably met by available products. Because
manufacturers demonstrate compliance with energy conservation standards
by reporting values to DOE that are intended to represent the
population mean, DOE develops its efficacy levels based on these
values. Thus, DOE is not adjusting efficacy levels downward to reflect
the low end of a bell distribution curve. Regarding lighting controls,
DOE agrees with NEMA that dimmable systems can offer significant energy
savings and therefore ensures that the analyzed levels maintain the
availability of full wattage (argon-based) products.
NEMA stated that the proposed level for the 4-foot MBP product
class will eliminate over 80 percent of the current full wattage
product offering, including the long-life products, and nearly half of
the reduced wattage lamps. NEMA noted that this would result in one
lamp offering for each of the three common color lamps (830, 835 and
841) per manufacturer. NEMA concluded that this proved DOE's approach
to modeling does not work. (NEMA, No. 54 at p. 25)
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such a product. (42 U.S.C. 6295(p)(1)) After determining
this level, DOE conducts subsequent analysis to determine the impact of
potential standards on individuals, manufacturers, and the nation as a
whole. DOE then considers these results to determine whether the
benefits of potential standard levels outweigh the burdens. See section
VII.C.1 for this discussion.
For the final rule, DOE updated catalog and certification data for
all products. DOE continued to identify two levels of efficacy above
the baseline. Based on catalog data, DOE determined EL 1 (90.0 lm/W)
represented an improved 800 series full wattage T8 lamp and EL 2 (93.0
lm/W) represented an 800 series high lumen output full wattage T8 lamp.
Reduced wattage lamps also meet EL 2. Based on available certification
information, DOE confirmed that no adjustment to EL 1 was necessary. As
stated, DOE adjusted EL 2 to 92.4 lm/W in the NOPR analysis. DOE
analyzed available certification information and found that, given
additional certification data reported, no additional downward
adjustments to EL 2 were necessary. Therefore, DOE analyzed EL 1 at
90.0 lm/W and EL 2 at 92.4 lm/W in the final rule.
Eight-Foot Slimline Lamps
In the NOPR, DOE selected a baseline lamp that just complies with
the existing standard level of 97 lm/W. 79 FR at 24097, 24098 (April
29, 2014). The baseline level represents a less efficient 800 series
full wattage T8 lamp. DOE then identified two levels of efficacy above
this baseline that commercially available lamps are able to achieve.
Manufacturer-provided information in catalogs indicates that there are
two distinct product lines available with efficacies higher than the
baseline product. EL 1 represents a standard 800 series full wattage T8
lamp. EL 2 represents an improved 800 series full wattage T8 lamp in
which the phosphor mix and/or coating is enhanced to increase efficacy.
Reduced wattage lamps also meet EL 2. DOE found no adjustments were
necessary based on certification data and established EL 1 at 98.2 lm/W
and EL 2 at 99.0 lm/W in the NOPR.
NEMA stated that there is potential for erroneous high frequency
reference ballast photometry testing for full wattage (59 W) and
reduced wattage (54 W) 8-foot SP slimline lamps, although less likely
for 59 W lamps because ANSI C78.81-2005 and C78.81-2010 versions
standardized measurement on low frequency circuits for these lamps.
NEMA noted that measurements with 54 W lamps tested on high frequency
circuits were more likely to appear in DOE's certification database
because this lamp type will be standardized for high frequency testing
in the version of ANSI C 78.81 expected to be published in 2014. (NEMA,
No. 54 at p. 25) NEMA commented on figure 5.3.4 of chapter 5 of the
NOPR TSD, which shows all certification data reported for the 8-foot SP
slimline lamps. Specifically, examining the data from 97 lm/W (current
standard) to 102.4 lm/W, NEMA stated that the spread was approximately
6 percent which is in agreement with industry expectations as specified
in LSD 63-2012 and does not indicate the use of high frequency
photometry testing. (NEMA, No. 54 at p. 25)
For the 8-foot SP slimline product class, NEMA recommended that DOE
should maintain the current standard of 97 lm/W in order to allow the
manufacturability of consistently compliant products. NEMA added that
if DOE intended to propose the max tech level of 99 lm/W, it should
allow for efficacy compliance tolerances of approximately 8 percent and
require reporting only the sample mean value. (NEMA, No. 54 at p. 25)
For the final rule, DOE updated catalog and certification data for
all products. DOE continued to identify two distinct levels above the
baseline. EL 1 at 98.2 lm/W represents a standard 800 series full
wattage T8 lamp and EL 2 at 99.0 lm/W represents an improved 800 series
full wattage T8 lamp in which the phosphor mix and/or coating is
enhanced to increase efficacy. Reduced wattage lamps also meet EL 2.
DOE found no adjustments were necessary based on certification data. As
described previously in this section, DOE believes that catalog and
certification data approximate the population mean and therefore does
not believe that an efficacy level has to be lowered further in order
for products reporting those values to comply.
[[Page 4073]]
Eight-Foot RDC HO Product Class
In the NOPR, DOE modeled a baseline that just met the existing
standard level of 92 lm/W, as described in section VI.D.2.c. DOE then
identified two levels of efficacy above the baseline level. EL 1
represents a 700 series full wattage T8 lamp with basic coating, gas
composition, and phosphor mix. EL 2 represents a shift to an 800 series
full wattage T8 lamp. DOE analyzed publicly available certification
data and determined that EL 1 should be adjusted from 95.2 lm/W to 94.0
lm/W for 700 series full wattage T8 lamps based on available
certification data. EL 2 was not adjusted based on available
certification data and remained 97.6 lm/W. 79 FR at 24103 (April 29,
2014).
NEMA stated that the DOE certification data for the 8-foot RDC HO
GSFL lamps with CCT <=4,500 K lamps was too sparse for analysis and
recommended retaining the current standard of 92 lm/W. (NEMA, No. 54 at
p. 25) Although commenting that the data was sparse, NEMA claimed that
the proposed efficacy levels would eliminate T8 HO lamps and force
consumers to change to another fixture or retrofit with another
technology. (NEMA, No. 54 at p. 25)
For the final rule, DOE updated catalog and certification data for
all products. DOE continued to model a baseline lamp that just meets
the existing standard level of 92 lm/W, because feedback from
stakeholders and manufacturer interviews indicated that manufacturers
will likely produce lamps at the existing standard level even if no
products are currently available. DOE again identified two levels of
efficacy above the baseline. DOE analyzed publicly available
certification data and determined that adjustment to EL 1 in the NOPR
analysis was still appropriate and maintained the adjustment from 95.2
lm/W to 94.0 lm/W for 700 series full wattage T8 lamps based on
available certification data. EL 2 was not adjusted based on available
certification data and remained 97.6 lm/W. While there are fewer
product offerings for 8-foot RDC HO lamps than for other covered lamp
types, DOE does not believe the data is too sparse for analysis. For
the final rule, certification data was available for 71 percent of 8-
foot RDC HO lamps. DOE confirmed through its assessment of catalog and
certification data that 8-foot RDC HO products meet the analyzed ELs.
Because manufacturer-reported data demonstrates that products can meet
the analyzed levels, DOE does not believe the efficacy levels would
eliminate 8-foot RDC HO lamps and force consumers to switch to another
technology.
Four-Foot T5 MiniBP SO Product Class
In the NOPR, DOE modeled a baseline that just met the existing
standard level of 86 lm/W, as described in section VI.D.2.c. The
baseline level represents a lower efficacy full wattage (28 W) lamp. 79
FR at 24097, 24098 (April 29, 2014). Based on a review of commercially
available products, DOE then identified two levels of efficacy above
the baseline level at which lamps were consistently performing.
Manufacturer-provided information in catalogs indicates that there are
two distinct product lines available with efficacies higher than the
baseline product. EL 1 represents an 800 series full wattage T5 lamp
with basic coating, gas composition, and phosphor mix. EL 2 represents
an improved 800 series full wattage T5 lamp in which the phosphor mix
and/or coating is enhanced to increase efficacy. Reduced wattage lamps
also meet this level. DOE found that no adjustments were necessary for
EL 1 and therefore established EL 1 at 93.5 lm/W. For EL 2 representing
improved 800 series full wattage T8 lamps, DOE adjusted EL 2 from 98.2
lm/W to 97.1 lm/W based on certification data.
NEMA stated that since the 2010-2011 rare earth crisis, some
efficacious phosphors are no longer available and thus many of the high
performance T5 lamps currently found in product catalogs that meet the
proposed standard level will be removed from the catalogs.
Additionally, compliant T5 lamps may also be removed because they do
not sell due to high prices. (NEMA, No. 54 at p. 19)
DOE reviewed updated catalogs and certification submissions and
confirmed that the 4-foot T5 MiniBP SO and HO lamps analyzed for the
final rule were still commercially available. DOE found no indication
in manufacturer literature that any T5 lamps were discontinued. When
considering available products, DOE relied on information provided by
each manufacturer and did not speculate on the future discontinuation
of products.
NEMA provided several comments on how the certification data
compared to the efficacy levels DOE considered in the NOPR. NEMA
acknowledged that the current standard for 4-foot T5 MiniBP SO lamps of
86 lm/W is easily achievable by max tech designs. However, NEMA
disagrees with eliminating the manufacturability and marketing of
consistently compliant products by setting the minimum efficacy level
any higher than 89 lm/W, which is only about 4 percent below the
proposed max tech level. (NEMA, No. 54 at p. 26) NEMA stated that the
certification data for the 28 W 4-foot MiniBP T5 SO lamps shown in
figure 5.3.8 of chapter 5 of the NOPR TSD reflects about a 7 percent
spread from 93 lm/W to 100 lm/W and is in agreement with their
assessment. (NEMA, No. 54 at p. 26)
For the final rule, DOE updated catalog and certification data for
all products. DOE continued to model a baseline lamp that just meets
the existing standard level of 86 lm/W, because feedback from
stakeholders and manufacturer interviews indicated that manufacturers
will likely produce lamps at the existing standard level even if no
products are currently available. DOE again identified two levels of
efficacy above the baseline. EL 1 represents an 800 series full wattage
T5 lamp with basic coating, gas composition, and phosphor mix. EL 2
represents an improved 800 series full wattage T8 lamp in which the
phosphor mix and/or coating is enhanced to increase efficacy. Reduced
wattage lamps also meet this level. DOE reviewed available
certification data and found that no adjustments were necessary for EL
1 and therefore established EL 1 at 93.5 lm/W. For EL 2 representing
improved 800 series full wattage T8 lamps, DOE found that a further
downward adjustment was necessary and adjusted EL 2 from 98.2 lm/W to
95.0 lm/W. Additional and/or revised certification data reported since
the publication of the NOPR indicated that T5 SO lamps had lower
efficacies than originally indicated. As described previously in this
section, DOE does not believe that catalog or certification data
inherently represent values at the high end of a distribution curve and
that an efficacy level has to be lowered further in order for products
reporting those values to comply.
Four-Foot T5 MiniBP HO
For the NOPR, DOE analyzed one level of efficacy above the baseline
level. DOE modeled a baseline that just met the existing standard level
of 76 lm/W, as described in section VI.D.2.c. The baseline level
represents a lower efficacy full wattage (54 W) lamp. Manufacturer-
provided information in catalogs indicates that there is one distinct
product line available with an efficacy higher than the baseline
product. EL 1 represents an 800 series full wattage T5 lamp with basic
coating, gas composition, and phosphor mix. Reduced wattage lamps also
meet this level. DOE did not adjust this level based on certification
data and is therefore evaluated EL 1 at 82.7 lm/W
[[Page 4074]]
in the NOPR. 79 FR at 24104 (April 29, 2014).
NEMA stated that efficacy levels for T5 lamps should not be based
on catalog rated efficacy at 35 [deg]C because the industry standard
IEC 60081 and the DOE test procedure require measurement at 25 [deg]C.
NEMA further noted that there is no ambiguity in the measurement
circuit as all T5 lamps are measured on high frequency circuits at 25
[deg]C. (NEMA, No. 54 at pp. 25-26)
DOE agrees that T5 lamps must be tested at 25 [deg]C per DOE's test
procedure. However, not all manufacturers provide lumen output data at
25 [deg]C for T5 lamps in their catalogs, whereas all manufacturers
provide data at 35 [deg]C. Thus, to consider the entire market DOE
developed initial efficacy levels based on 35 [deg]C catalog data for
T5 lamps and then adjusted the initial efficacy levels to reflect
operation at 25 [deg]C. DOE compared the 25 [deg]C levels to
certification data which reflects tested values at the same
temperature.
NEMA provided several comments on how the certification data
compared to the efficacy level DOE considered in the NOPR. NEMA noted
that the spread of certification data from 81 lm/W to 96 lm/W for 54 W
4-foot T5 MiniBP HO lamps indicates variability of 17 percent, which
could be explained by the steeper slope of lumen output with ambient
temperature at 25 [deg]C for T5 compared to T8 lamps. NEMA stated that
the certification data shown in figure 5.3.10 of chapter 5 of the NOPR
TSD agreed with its assessment of DOE's certification database. NEMA
noted that for the reduced wattage 4-foot T5 MiniBP HO lamps, the
certification data was shown mostly to be between 85 and 87 lm/W and
with a couple of values well above 90 lm/W. Stating that it is
difficult to determine the max tech for this product class, NEMA
recommended that DOE set the minimum efficacy level no higher than 80
lm/W. NEMA stated that 80 lm/W would require centering the practical
compliant designs near 87 lm/W to avoid statistical non-compliant
results. (NEMA, No. 54 at p. 26)
For the final rule, DOE updated catalog and certification data for
all products. DOE continued to model a baseline lamp that just meets
the existing standard level of 76 lm/W because feedback from
stakeholders and manufacturer interviews indicated that manufacturers
will likely produce lamps at the existing standard level even if no
products are currently available. DOE again identified one level of
efficacy above the baseline representing an 800 series full wattage T5
lamp with basic coating, gas composition, and phosphor mix. Reduced
wattage lamps also meet this level. Based on catalog data, DOE
determined EL 1 to be 82.7 lm/W. DOE reviewed available certification
data and found that the reported values did not indicate that any
adjustment to the level was necessary. The certification data, as noted
by NEMA, is generally higher than the catalog data on which EL 1 is
based. As described previously in this section, DOE does not believe
that catalog or certification data inherently represent values at the
high end of a distribution curve and that an efficacy level has to be
lowered further in order for products reporting those values to comply.
h. Scaling to Other Product Classes
As noted previously, DOE analyzes the representative product
classes directly. DOE then scales the levels developed for the
representative product classes to determine levels for product classes
not analyzed directly. For GSFLs, the representative product classes
analyzed were all lamp types with CCTs <=4,500 K, with the exception of
2-foot U-shaped lamps. For the 2-foot U shaped product class DOE scaled
the efficacy levels developed for the 4-foot MBP product class.
CCT Scaling
Finding substantial variation in the percent reduction in efficacy
associated with increased CCT among product classes, in the NOPR DOE
proposed a separate scaling factor for each product class. 79 FR at
24105 (April 29, 2014). Based on its assessment, DOE proposed a 2
percent scaling factor for the 4-foot MBP product class, 3 percent
scaling factor for the 2-foot U-shaped product class, 5 percent for the
8-foot SP slimline product class, 2 percent for the 8-foot RDC HO
product class, 6 percent for the T5 MiniBP SO product class, and 5
percent for the T5 MiniBP HO product class. DOE verified the scaling
factors developed against certification data. Further, DOE confirmed
that lamps with CCT greater than 4,500 K will meet the scaled levels.
NEMA stated it is well established in industry that there is a
decrease in efficacy of 4-6 percent to go from the common 4,100 K 4-
foot MBP lamps to the 5,000 K tri-phosphor lamps and a decrease in
efficacy of 6-8 percent to go to the 6,500 K tri-phosphor lamps. NEMA
noted that the reduction in efficacy at CCTs greater than 4,500 K
becomes more significant when targeting higher efficacy levels. NEMA
also contended that the 2009 Lamps Rule was erroneous in allowing only
a 1 percent reduction in efficacy for 4-foot MBP lamps with a CCT
greater than 4,500 K. NEMA recommended that the scaling factor for high
CCT lamps allow a decrease of at least 7 percent to accommodate the
average performance of higher CCT lamps and at minimum be reduced by
greater than 4 percent unless limited by current regulations. NEMA also
noted that European regulations allow for a decrease of 10 percent for
high CCT lamps, and CEE specifications allow for a decrease of 4.3
percent for high CCT 4-foot T8 MBP lamps. (NEMA, No. 54 at p. 28)
DOE revised its scaling analysis for CCT in the final rule to use
the most recent values submitted to DOE for compliance purposes rather
than catalog data. DOE compared certification data for each lamp type
to determine the efficacy differences between low and high CCT lamps.
The data still demonstrated that the difference in efficacy between low
and high CCT lamps varied by lamp type. Therefore, DOE maintained a
separate scaling factor for each product class. However, the additional
and revised certification data indicated slightly different scaling
factors were necessary. Based on its assessment, DOE calculated a 4
percent scaling factor for the 4-foot MBP product class, 2 percent
scaling factor for the 2-foot U-shaped product class, 3 percent for the
8-foot SP slimline product class, 4 percent for the 8-foot RDC HO
product class, 6 percent for the T5 MiniBP SO product class, and 7
percent for the T5 MiniBP HO product class. DOE applied these scaling
factors to the low CCT levels to determine the appropriate levels for
high CCT lamps. If applying the scaling factor resulted in an efficacy
that was lower than that of the existing standard, DOE maintained the
existing standard level to avoid backsliding. (See 42 U.S.C.
6295(o)(1)) DOE compared the scaled efficacy levels to available
certification data and confirmed that high CCT lamps can meet the
analyzed efficacy levels.
Two-Foot U-Shaped Scaling
By comparing certification data for 2-foot U-shaped lamps with
equivalent 4-foot MBP lamps, in the NOPR, DOE determined an average
efficacy reduction of 6 percent for the 2-foot U-shaped lamps from the
4-foot MBP lamps was appropriate. 79 FR at 24106 (April 29, 2014). DOE
confirmed that the technology impacts of the scaled ELs for the 2-foot
U-shaped lamps were consistent with those of the proposed ELs for the
4-foot MBP product class.
NEMA stated that only the full wattage 2-foot U-shaped 1\5/8\-inch
lamps and reduced wattage 2-foot U-shaped 6'' lamps can meet the
proposed efficacy
[[Page 4075]]
levels. NEMA explained that consumers have switched to reduced wattage
2-foot U-shaped 1\5/8\-inch lamps which serve retail applications and
full wattage 2-foot U-shaped 6'' lamps are mainly used in offices for
dimming purposes. Therefore, NEMA concluded that the energy savings for
the 2-foot U-shaped 1\5/8\-inch lamps would be negative and increase
the energy consumption by 2 W due to the elimination of the reduced
wattage versions forcing consumers back to the full wattage version.
NEMA stated that DOE should update its energy savings estimates
accordingly or adopt the efficacy level at TSL 3, which would allow for
both full and reduced wattage 2-foot U-shaped lamps to meet. (NEMA, No.
54 at p. 15, 27) GE also noted that the efficacies of the 2-foot U-
shaped class were scaled from the 4-foot MBP class which could indicate
an issue with the scaling or the proposed efficacy levels of the 4-foot
MBP. (GE, Public Meeting Transcript, No. 49 at p. 61)
DOE revised its scaling analysis for 2-foot U-shaped lamps in the
final rule to use the most recent values submitted to DOE for
compliance purposes. DOE compared certification data for 2-foot U-
shaped lamps of both spacings (i.e., 6-inch and 1\5/8\-inch leg
spacing) with equivalent 4-foot MBP lamps and determined an average
efficacy reduction of 8 percent for the 2-foot U-shaped lamps from the
4-foot MBP lamps was appropriate. Thus, DOE applied this scaling factor
to the 4-foot MBP levels to determine the appropriate levels for 2-foot
U-shaped lamps. If applying the scaling factor resulted in an efficacy
that was lower than that of the existing standard, DOE maintained the
existing standard level to avoid backsliding. (See 42 U.S.C.
6295(o)(1)) DOE compared the scaled efficacy levels to available
certification data and confirmed that both types of 2-foot U-shaped
lamps can meet with the analyzed efficacy levels.
i. Rare Earth Phosphors
DOE understands a constrained supply of rare earth phosphors may
have impacts on the production of higher efficacy fluorescent lamps.
DOE also acknowledges that supply and demand of rare earth phosphors
should be considered when evaluating amended standards for GSFLs. Thus,
in the NOPR analysis, DOE considered a scenario of increased rare earth
phosphor prices in the LCC and NIA.
NEMA commented that manufacturers are at risk of not being able to
make compliant lamps consistently due to the availability of high
efficiency phosphors for GSFLs. If manufacturers cannot consistently
produce a product, they will stop making it as with the 130 V IRLs.
(NEMA, No. 54 at pp. 13-14)
NEMA noted that the proposed lm/W requirements would increase the
use of rare earth oxides (REOs) per lamp. (NEMA, No. 54 at p. 34)
Further, NEMA commented that even though it is possible to increase
GSFL efficacy with a more efficient mix of REOs, the high material cost
of the REOs needed for the small increase in efficacy is still
relevant. NEMA commented that DOE should analyze price elasticity and
consumer behavior during previous REO shortages, as the ELs DOE
proposed in the NOPR would effectively cause another shortage of REOs.
(NEMA, No. 54 at p. 34)
Noting that that China appealed World Trade Organization's (WTO's)
ruling demanding greater availability of REOs, NEMA stressed that DOE
should expect China to raise prices on REOs through various methods;
specifically quoting an article from Bloomberg News.\39\ NEMA explained
that during the last REO shortage, prices increased 400 to 700 percent,
and stated that this is cause for DOE to revise their price estimates
to raise the upper bounds of potential spiking during periods of
criticality to 700 percent of current prices. NEMA further noted that
while they cannot make the same supply warnings they provided for the
2009 Lamps Rule, REO availability continues to be an issue and there
are significant uncertainties regarding future supplies. (NEMA, No. 54
at pp. 34-35)
---------------------------------------------------------------------------
\39\ Bloomberg News, ``China Maintains Quotas for Heavy Rare
Earths, Tungsten,'' June 19, 2014. <http://www.bloomberg.com/news/2014-06-19/china-maintains-quotas-for-heavy-rare-earths-tungsten.html.
---------------------------------------------------------------------------
NEEP noted that REO prices and availability had improved in the
last few years and, according to DOE, would continue to fluctuate. NEEP
commented that DOE appropriately weighed the variability of REO prices
in the analysis. (NEEP, No. 57 at p. 3)
In April of 2012, several manufacturers were granted exception
relief exempting their 700 series T8 lamps from the July 2012 standards
for a period of two years. The waiver was granted due to the global
supply restrictions on rare earth phosphors, the rising world demand of
these phosphors, and the resulting impacts on producing higher efficacy
GSFLs. DOE notes that manufacturers, in their applications for
exception relief, stated that they expected an improvement in the rare
earth market, specifically noting that supplies of key rare earth
phosphors used in fluorescent lamps will become more equal to estimated
demand beginning in 2014. Manufacturers also stated that the two-year
relief would provide time for potential development of additional
supplies outside of China, for progress in technology advancements and
development of alternative technologies that use lesser amounts of rare
earth material, and for the expansion of recycling and reclamation
initiatives.\40\ Because this waiver expired in 2014, and manufacturers
did not reapply for exception relief, DOE does not believe that the
availability of high efficiency phosphors will affect manufacturers'
ability to consistently produce a product. However, DOE acknowledges
that the market for rare earth phosphors is uncertain and therefore
continues to analyze in this final rule a scenario of increased rare
earth phosphor prices in the LCC and NIA.
---------------------------------------------------------------------------
\40\ Philips Lighting Company, et al. OHA Case Nos. EXC-12-0001,
EXC-12-0002, EXC-12-0003 (2012). Accessible here: http://energy.gov/sites/prod/files/oha/EE/EXC-12-0001thru03.pdf.
---------------------------------------------------------------------------
3. Incandescent Reflector Lamp Engineering
For IRLs, DOE received several comments on the engineering analysis
presented in the NOPR. 79 FR at 24106 (April 29, 2014). Stakeholders
provided feedback on DOE's baseline lamps, selection of more
efficacious substitutes, max tech level, ELs, scaling, and xenon. The
following sections summarize the comments and responses received on
these topics, and present the IRL engineering methodology for this
final rule analysis.
a. Representative Product Classes
When a product has multiple product classes, DOE identifies and
selects certain product classes as representative and analyzes those
product classes directly. DOE chooses these representative product
classes primarily due to their high market volumes. For IRLs, in the
NOPR analysis DOE identified standard spectrum lamps, with diameters
greater than 2.5 inches, and input voltage less than 125 V as the
representative product class, shown in gray in Table VI.5. 79 FR at
24107 (April 29, 2014). NEMA commented that the only IRLs that still
have any meaningful product sales are in the standard spectrum, less
than 2.5 inches in diameter, less than 125 V product class. (NEMA, No.
54 at p. 21) Receiving no
[[Page 4076]]
other comments, DOE maintained the same IRL representative product
classes for the final rule.
Table VI.5--IRL Representative Product Classes
----------------------------------------------------------------------------------------------------------------
Lamp type Diameter Voltage
----------------------------------------------------------------------------------------------------------------
Standard spectrum..................... >2.5 inches.............. >=125
<125 (representative)
<=2.5 inches............. >=125
<125
Modified spectrum..................... >2.5 inches.............. >=125
<125
<=2.5 inches............. >=125
<125
----------------------------------------------------------------------------------------------------------------
b. Baseline Lamps
Once DOE identifies representative product classes for analysis, it
selects baseline lamps to analyze in each representative product class.
Typically, a baseline lamp is the most common, least efficacious lamp
that meets existing energy conservation standards. DOE reviewed product
offerings in catalogs, shipment trends, and information obtained during
manufacturer interviews to identify the common characteristics of lamps
that meet standards. In the NOPR, DOE identified a PAR38 lamp as the
most prevalent lamp shape and diameter in the representative product
class. Id. at 24109. From all PAR38 lamps with the most common
characteristics, DOE selected a lamp that just met existing standards
as the baseline: A 60 W halogen lamp with a lifetime of 1,500 hours
that utilized a higher efficiency inert fill gas and a higher
efficiency reflector coating, and had an efficacy right at the existing
standard, 5.9P\0.27\. DOE received several comments on its selection of
the baseline for IRLs.
GE stated that they agreed that the baseline lamp is representative
of its product class. (GE, Public Meeting Transcript, No. 49 at p. 104)
However, NEMA commented that a 60 W IRL with a lifetime of 1,000 hours
should be the baseline as it is the lowest performing most common
product. (NEMA, No. 54 at p. 29) As noted, the baseline is usually
representative of the most common, least efficacious lamp that meets
existing energy conservation standards. Based on DOE's review of
product offerings in catalogs, 1,500 hours is the most common lifetime.
Among the covered IRLs product offerings, 1,500-hour lamps comprise 27
percent of offerings while 1,000-hour lamps comprise 12 percent. The
1,500-hour product selected as the baseline lamp in the NOPR performs
at the minimum efficacy required by existing standards. Therefore, DOE
is maintaining the 1,500-hour lamp as the baseline in the final rule
analysis. Table VI.6 summarizes the performance characteristics of the
IRL baseline lamp. For further information, see chapter 5 of the final
rule TSD.
Table VI.6--IRL Baseline Lamp
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline lamp
---------------------------------------------------------------------------------------------------------------
Wattage Efficacy Initial Lifetime
Representative product class ---------------------------- light output -------------
Lamp type Descriptor --------------
W lm/W lm hr
--------------------------------------------------------------------------------------------------------------------------------------------------------
Standard Spectrum, Voltage <125 V, PAR38..................... Improved Halogen.......... 60 17.8 1,070 1,500
Diameter >2.5 Inches.
--------------------------------------------------------------------------------------------------------------------------------------------------------
c. More Efficacious Substitutes
DOE selects more efficacious replacements for the baseline lamps
considered within each representative product class. DOE considers only
design options identified in the screening analysis. In the NOPR, DOE
considered substitute lamps that saved energy and, where possible, had
a light output within 10 percent of the baseline lamp's light output.
Id. at 24109. In identifying the more efficacious substitutes, DOE
utilized a database of commercially available lamps. DOE identified two
higher efficacy, reduced wattage lamps, referred to in this analysis as
an HIR lamp with a lifetime of 2,500 hours and an improved HIR lamp
with a lifetime of 4,200 hours, as more efficacious substitutes for the
baseline lamp. DOE received several comments regarding its choice for
the more efficacious substitutes.
NEMA insisted that 3,000-hour and longer lifetimes must be
available in the commercial market for the product line to maintain
viability, as long life is a consumer-demanded utility. Lamp lifetimes
shorter than 3,000 hours for premium and expensive halogen PAR38 lamps
would not be sustainable or acceptable in the commercial market. (NEMA,
No. 54 at p. 21)
NEMA further explained that the only remaining method to increase
IRL efficacy is by shortening their lifetime, and many IRLs are already
rated at 1,000 hours. NEMA noted that a 1,000-hour lifetime represents
a previous loss of utility from complying with efficacy requirements,
and that the shortened lifetime has resulted in public backlash. NEMA
warned that with the standards proposed in the NOPR, consumers would
lose the utility of lifetime. Using a calculation from The Science of
Incandescence,\41\ NEMA stated that the higher efficacy of EL 1 would
result in a 30 percent reduction in lifetime for these lamps, causing a
total loss of financial feasibility. (NEMA, No. 54 at pp. 21, 29, 49)
Westinghouse remarked that IRLs are already at max tech, and that
unlike with GSFLs, there is no opportunity for tradeoffs between
efficacy and utility. (Westinghouse,
[[Page 4077]]
Public Meeting Transcript, No. 49 at pp. 54-56)
---------------------------------------------------------------------------
\41\ Vukcevich, Milan R., Science of Incandescence, NELA Press,
1992.
---------------------------------------------------------------------------
DOE recognizes that there is an inverse relationship between
efficacy and lifetime for IRLs. DOE believes typical lifetimes of IRLs
regulated by this rulemaking are between 1,500 and 4,400 hours. In the
engineering analysis, DOE only considered lamps with lifetimes greater
than or equal to the baseline when selecting representative lamp units.
DOE found evidence that improved technology lamps (i.e., HIR lamps)
with lifetimes higher than the baseline lifetime are prevalent on the
market. Both representative lamp units that DOE selected in the
engineering analysis have lifetimes longer than the baseline. While
manufacturers can choose to introduce shorter lifetime products in the
future, DOE does not require shortening of lamp lifetime to meet any
analyzed level. One of the representative units at EL 1 has a lifetime
of 4,200 hours. Thus, DOE ensured that products with lifetimes greater
than 3,000 hours would be available for consumers desiring longer life
products.
NEMA commented that the PAR38 lamp is not an adequately
representative lamp and inappropriately skews DOE's analysis because it
is the only lamp type in the class that can physically incorporate the
largest number of technology options, overstating the possible energy
savings. NEMA encouraged DOE to examine smaller diameter lamps to
better understand what technology options are feasible. (NEMA, No. 54
at p. 29) As an example, NEMA commented that the lifetime of the PAR30
lamp would have to be shortened to the point of being economically
infeasible and unmarketable to consumers to meet standards. (NEMA, No.
54 at pp. 29-30) NEMA could not identify a lamp that met the EL
proposed in the NOPR while still providing adequate lifetime in all
sizes. Specifically, NEMA stated that the rule proposed in the NOPR
would allow only certain PAR38 lamps to meet the regulations and most
other types and classes of covered IRLs would be eliminated. NEMA
argued, therefore, that the EL proposed in the NOPR is invalid for most
lamps. (NEMA, No. 54 at p. 29)
DOE recognizes that in addition to PAR38 lamps, the representative
product class also includes PAR30 lamps. Because it is a more common
lamp size among the covered IRLs, DOE selected PAR38 as the diameter
for the baseline lamp and more efficacious substitutes of the baseline.
DOE's research indicates that the design options identified for PAR38
lamps are also applicable to PAR30 lamps. DOE assessed the availability
of PAR30 lamps as more efficacious substitutes. DOE found that there
are PAR30 lamps with lifetimes of 3,500 and 4,400 hours that are able
to achieve the same efficacies as PAR38 lamps. See chapter 5 of the
final rule TSD for additional details.
CA IOUs expressed disappointment that there were not multiple
efficacy levels representing higher performance products. CA IOUs
stated that DOE had restricted itself to a small subset of IRLs by
focusing on PAR38 lamps and requiring lumens to be within 10 percent of
the baseline lamp, limiting the lumen range to about 963 to 1,170. CA
IOUs mentioned that any design strategies used in other lamp types,
(e.g., 800-lumen lamp, 1,200-lumen lamp, PAR30 lamp) that improved
efficacy would be fairly transferable among lamp types. CA IOUs
questioned why DOE did not consider potential efficacy improvements
from these lamp types. (CA IOUs, Public Meeting Transcript, No. 49 at
pp. 107-109) Specifically, CA IOUs noted four lamps that have better
performance than the proposed efficacy level: The GE 60 W PAR HIR Plus
operating at 21 lm/W, the Philips PAR38 Energy Halogen DiOptic
operating at 20 lm/W, the OSRAM SYLVANIA PAR38 medium-base warm white
outdoor halogen flood operating at 20 lm/W, and the OSRAM SYLVANIA
PAR38 warm white outdoor halogen flood operating at 21 lm/W. (CA IOUs,
Public Meeting Transcript, No. 49 at pp. 107-109, 118)
ASAP also disagreed with DOE's criteria of restricting lumen output
to be within 10 percent of the baseline lamp, noting that the NOPR
analysis seemed to suggest that DOE understood that technologies used
in one lamp to achieve a certain lumen package can be used in another.
Therefore, ASAP questioned why DOE rejected a more efficacious
technology used in another lamp due to the lumen output of that lamp
having a greater than 10 percent difference from the baseline lamp.
ASAP stated that DOE should have analyzed the more efficacious
technology and used scaling to maintain the baseline lumen output.
(ASAP, Public Meeting Transcript, No. 49 at p. 113)
GE, on the other hand, commented that the analysis presented in the
NOPR was fairly accurate in terms of addressing and looking at the
other potential more efficacious products. GE argued that not all of
the lamps proposed by commenters to be more efficacious were within the
scope of this rulemaking and not all of the proposed technologies were
transferable to covered lamps. (GE, Public Meeting Transcript, No. 49
at p. 112)
DOE used certain criteria when selecting more efficacious
substitutes. Specifically, DOE only considered lamps with the same
reflector shape as the baseline lamp, wattages less than the baseline
wattage, lumens within 10 percent of the baseline lumens, lifetimes
equal to or greater than the baseline lifetime, and that were
commercially available in the United States or available as prototypes.
These criteria ensured that higher efficacy lamps with similar
characteristics to the baseline were available to consumers at each
efficacy level analyzed.
When establishing efficacy levels, DOE considered all lamps
available. DOE reviewed the design options incorporated into each lamp,
the ability of lamps across lumen packages to meet the level, and the
max tech level. Regarding the four lamps that CA IOUs noted as having
better performance than the proposed efficacy level, one of them was
part of a product line for which certification data indicated that the
product line performed below or much closer to EL 1 than indicated by
its catalog data. Another of the lamps was part of a product family for
which certification data indicated that product performance was at the
existing standard level, or baseline, rather than EL 1. A third lamp in
the group of four did not have certification data available for DOE to
substantiate its performance claims in catalogs. The fourth lamp did
have both catalog and certification data available and that data
indicated that it performed above EL 1. However, this lamp was not part
of a full product line that would indicate that the technology
incorporated in the lamps could be used across all lumen packages.
While DOE is aware that it is generally the case that technology can be
shared among various lamps, modeling a product allows DOE to estimate
lamp performance but not confirm performance via certification data or
independent testing, a significant concern in this rulemaking.
Furthermore, costs for such a product would be uncertain as it would
not be commercially available at the time of the analysis. Therefore,
DOE chose not to model a higher efficacy lamp that met its criteria for
selecting representative units in the NOPR as well as the final rule
analysis.
NEEA commented that, unless the market shares of the 60 W PAR38 and
55 W PAR38 lamps are close to 90 percent of the market, DOE's analysis
was incomplete and the more efficacious lamps suggested by CA IOUs need
to be analyzed. (NEEA, Public
[[Page 4078]]
Meeting Transcript, No. 49 at pp. 111-112)
Through a review of product offerings in catalogs, DOE determined
that PAR38 is the most common lamp diameter and 60 W is at least twice
as common as any other wattage. Further, DOE did not restrain the
representative lamp units to 55 W but rather required that the wattage
be less than the baseline. DOE found that the majority of product
offerings on the market have wattages at or below 60 W. Thus, DOE finds
that the baseline and more efficacious lamp units analyzed represent
the most widely offered products on the market. Table VI.7 summarizes
the performance characteristics of the more efficacious substitutes for
IRLs. For further information see chapter 5 of the final rule TSD.
Table VI.7--IRL Representative Lamps
--------------------------------------------------------------------------------------------------------------------------------------------------------
Representative Lamps
--------------------------------------------------------------------------------------------------------------
Wattage Efficacy * Initial Lifetime
Representative product class -------------------------- light ------------
Lamp type Descriptor output
W lm/W ------------- hr
lm
--------------------------------------------------------------------------------------------------------------------------------------------------------
Standard Spectrum, Voltage <125 V, PAR38....................... HIR........................ 55 18.5 980 2,500
Diameter >2.5 Inches. PAR38....................... Improved HIR............... 55 18.5 1,120 4,200
--------------------------------------------------------------------------------------------------------------------------------------------------------
* Efficacy values are based on data from DOE's certification database.
d. Max Tech
When DOE proposes to adopt an amended standard for a type or class
of covered product, it must determine the maximum improvement in energy
efficiency or maximum reduction in energy use that is technologically
feasible for such product. (42 U.S.C. 6295(p)(1)) Accordingly, in the
engineering analysis, DOE determined the maximum technologically
feasible (``max tech'') improvements in energy efficiency for IRLs
using the design parameters for the most efficient products available
on the market or in working prototypes.
For IRLs, DOE presented one efficacy level (EL 1) for consideration
in the NOPR analysis. Therefore, this level was also the max tech level
identified for IRLs. DOE received several comments on the proposed max
tech level.
ASAP and CA IOUs commented that DOE made a mistake in not
considering higher ELs for IRLs. ASAP stated that CA IOUs provided
reasons for considering higher levels in response to the preliminary
analysis and DOE dismissed the suggestions with a ``grab bag'' of
unsubstantiated arguments for not considering the higher levels. (ASAP,
Public Meeting Transcript, No. 49 at p. 17; CA IOUs, Public Meeting
Transcript, No. 49 at p. 20) Further, CA IOUs commented that they do
not think that DOE adequately considered alternative technology options
they gave in response to the preliminary analysis for a more
efficacious max tech. (CA IOUs, Public Meeting Transcript, No. 49 at p.
114) CA IOUs stated that they suggested more efficacious lamps and in
not considering them, DOE has not complied with their statutory
requirement to investigate max tech. (CA IOUs, Public Meeting
Transcript, No. 49 at p. 110) CA IOUs continued that commercially
available products were available in different lumen bins or that there
were different lamp shapes from PAR38. CA IOUs noted that some of the
data they had for support were compliance certification values and some
were prototype products from the past or developed recently. (CA IOUs,
Public Meeting Transcript, No. 49 at p. 110)
DOE evaluated the more efficacious lamps proposed by stakeholders
in response to the preliminary analysis. As discussed in the NOPR, DOE
did not consider some of these lamps when evaluating the max tech level
because they were not available with the same reflector shapes or input
voltage as the IRLs covered by this rulemaking. 79 FR at 24111(April
29, 2014). In addition, as described in section VI.D.3.c, certification
data indicates that some lamps are not performing at the high
efficacies advertised in catalogs. Absent certification or independent
test data, DOE is unable to verify high efficacy claims. Finally,
although certain higher efficacy products have certification data
confirming their performance above EL 1, they are not part of a full
product line that would indicate that the technology incorporated in
the lamps could be used across all lumen packages.
Regarding prototype lamps, for the NOPR analysis, DOE contacted
manufacturers producing high efficacy prototype IRLs and conducted
independent testing of these lamps. The testing indicated that these
lamps were more efficacious than the max tech level determined by DOE
in this analysis.\42\ DOE notes that the lamps tested were prototype
lamps and were not manufactured during commercial scale production
runs. The measured efficacy of the prototype lamps greatly exceeded the
efficacy of commercially available lamps with similar lumen packages.
DOE did not, however, have the necessary information to do a cost
analysis to determine if an efficacy level based on these lamps would
be economically justified. Therefore, in the NOPR phase DOE requested
information on the incremental manufacturer production cost of a lamp
that could achieve the efficacy of the prototype lamps compared to a
lamp that complies with EL 1. DOE also sought information on the
manufacturing costs including equipment and product conversion costs
necessary to produce lamps at the efficacy of the prototype lamps.
However, DOE did not receive any information to conduct a cost
assessment of the higher efficacy prototypes and therefore, did not
include them in this final rule analysis.
---------------------------------------------------------------------------
\42\ DOE independently verified efficacy values provided by the
manufacturer. At the time of NOPR analysis, the manufacturer was
still conducting lifetime testing. DOE did not receive any updates
on lifetime testing of the prototype lamps at the time of the final
rule analysis.
---------------------------------------------------------------------------
CA IOUs stated that the efficacy standards proposed in the NOPR
would not be a challenge and an efficacy standard of more than three
times higher, as shown in appendix 5A of the NOPR TSD, would be
possible and likely be cost effective. Most manufacturers already have
the capability to meet the levels proposed in the NOPR, and the
achievement of higher efficacies was proven through the testing of
prototype lamps. CA IOUs commended DOE on its tests of prototyped
products, but expressed confusion over why DOE did not develop pricing
estimates for these products and create a corresponding EL. They also
questioned why DOE had not used the comments on projected sale prices
given during manufacturer interviews in their analysis. CA IOUs noted
that a pricing estimate could also
[[Page 4079]]
have been achieved by a teardown analysis of the prototype lamps
compared with similar, commercially available components. Specifically,
CA IOUs gave the example that lamps using high performance HIR burner
are already commercially available in A-line and MR16 bulb shapes,
selling for $3.49 and $6.90, respectively. Supported by these analyses,
CA IOUs urged DOE to conduct a complete review of the higher efficacy
prototype EL. (CA IOUs, No. 56 at p. 5)
As noted in the NOPR, while DOE was able to test the efficacies of
the prototype lamps, it had insufficient information to perform a cost
analysis. 79 FR at 24111 (April 29, 2014). DOE did not find that a
teardown analysis of the prototype lamps would be a feasible method to
estimate costs. DOE would be unable to determine through teardowns
whether the halogen burners used in various product offerings were the
same because of the difficulty in analyzing the IR coating,
specifically identifying the combinations of coatings applied. Without
this knowledge, DOE could not distinguish the specific technology
differences between one halogen burner and another and estimate costs
accordingly. Expected retail prices of the prototype lamp were provided
through comments and manufacturer interviews, but the information
indicated that the prices of the higher efficacy products would be less
than those of the lamps that comply with EL 1 and even the baseline. As
these lamps utilize a more advanced IR coating than lamps currently
available on the market, the manufacturer-provided cost was
inconsistent with the available market information. Further, this
manufacturer does not distribute covered IRLs in the U.S. market.
Therefore, DOE was unable to estimate the price of the prototype lamp
by comparing it to a similar lamp offered by the same manufacturer,
which would have allowed DOE to isolate the change in price due to the
more efficient coating. For these reasons, DOE concluded that it did
not have the information needed to conduct a cost assessment of the
higher efficacy prototype lamps and therefore, did not include them in
this final rule analysis.
e. Efficacy Levels
After identifying more efficacious substitutes for each of the
baseline lamps, in the NOPR, DOE developed ELs based on the
consideration of several factors, including: (1) The design options
associated with the specific lamps being studied; (2) the ability of
lamps across wattages to comply with the standard level of a given
product class; and (3) the max tech level. 79 FR at 24093 (April 29,
2014).
For IRLs, DOE developed a continuous equation that specifies a
minimum efficacy requirement across wattages and represents the
potential efficacy a lamp can achieve using a particular design option.
DOE observed an efficacy division among commercially available IRL
products that corresponded to the design options utilized to increase
lamp efficacy. Based on this efficacy division, DOE considered one EL
in the NOPR analysis. Id. at 24113. DOE received a comment from NEMA
regarding the EL presented for IRLs in the NOPR analysis.
NEMA stated that energy conservation standards above the current
IRL standards could not be economically justified. NEMA further stated
that the 6.2P \0.27\ level proposed in the NOPR is inappropriately set
at the higher end of the normal distribution curve for performance.
Following the CCE rules, if the average performance of the more
efficacious lamps is 6.2P \0.27\, the standard should be set at 6.0P
\0.27\. NEMA did note, however, for standard spectrum IRLs under 125 V,
it would be possible to consistently produce lamps at a higher
efficacy, up to 6.0P \0.27\ from 5.9P\0.27\, for lamps between 60 W and
205 W. NEMA expressed their belief that only this subset of IRLs could
reliably increase their efficacy, and only by that increment. NEMA
doubted that this increase would generate significant energy savings on
its own. (NEMA, No. 54 at pp. 21-22)
DOE conducted an updated engineering analysis for the final rule
and determined that EL 1 corresponded to an efficacy requirement of
6.2P \0.27\ based on certification data. DOE notes that the statistics
included in the compliance procedures are intended to ensure that
manufacturers are reporting a value that approximates the population
mean. Each tested lamp is not individually required to meet or exceed
the standard level. Designing products such that their population mean
or the performance of each individual lamp unit within the population
exceeds DOE's standard level is not required and is done so at the
discretion of individual manufacturers. Regarding an assessment of
national energy savings for IRLs see section VII.B.3. Regarding DOE's
conclusion as to whether a standard is economically justified, DOE
weighs the benefits and burdens in section VII.C.3.
For the final rule analysis, DOE again reviewed the most updated
catalog and certification data available for covered IRLs. As in the
NOPR analysis, DOE used the catalog data to identify all products on
the market and ensure consideration of all available products in the
analysis and assessed both catalog and certification efficacy values to
identify efficacy levels. In the NOPR analysis, DOE had found there to
be certification data for 51 percent of covered IRL products compliant
with the July 2012 standards. For the final rule analysis, DOE found
that updates to DOE's certification database resulted in certification
data for 61 percent of covered IRL products. While this was an increase
from the NOPR analysis, it still did not represent a comprehensive
dataset on which to base an engineering analysis. Therefore, in this
final rule analysis, DOE again used catalog data to identify all
products on the market and ensure consideration of all available
products in the analysis. DOE assessed both catalog and certification
efficacy values to identify efficacy levels. Using certification data
reported for the PAR38 2,500 hour HIR and 4,200 hour improved HIR
representative lamps, DOE adjusted EL 1. As mentioned previously, DOE
developed a continuous equation that specifies a minimum efficacy
requirement across wattages for IRLs. The EL that DOE determined based
on the representative lamps is a curve that represents a standard
across all wattages.
Table VI.8 presents the efficacy level for IRLs. See chapter 5 of
the final rule TSD for additional information on how the engineering
analysis was conducted.
Table VI.8--Efficacy Levels for Standard Spectrum, Voltage < 125 V,
Diameter > 2.5 Inches IRLs
------------------------------------------------------------------------
Efficacy level Efficacy requirement lm/W
------------------------------------------------------------------------
EL 1..................................... 6.2P \0.27\
------------------------------------------------------------------------
P = rated wattage
f. Scaling to Other Product Classes
When more than one product class exists for a covered product, DOE
identifies and selects representative product classes to analyze
directly. Efficacy levels developed for these representative product
classes are then scaled to products not analyzed directly. For IRLs,
DOE analyzed directly standard spectrum lamps greater than 2.5 inches
in diameter and with input voltages less than 125 V. The efficacy
levels developed for this representative product class were then scaled
to product classes not analyzed, using a scaling factor to adjust
levels for smaller diameter lamps, lamps with higher
[[Page 4080]]
input voltages, and modified spectrum lamps. DOE received several
comments specific to the scaling factors applied to develop efficacy
levels for the product classes analyzed directly.
Diameters Less Than or Equal to 2.5 Inches
In the NOPR analysis, DOE scaled from the EL developed for IRLs
with diameters greater than 2.5 inches (hereafter ``large diameter
lamps'') to IRLs with diameters less than or equal to 2.5 inches
(hereafter ``small diameter lamps''). Based on catalog data, DOE
determined the reduction in efficacy caused by the smaller lamp
diameter to be approximately 12 percent. DOE also determined that the
more efficient double-ended HIR burners could not fit into small
diameter lamps without extending the reflector lens. Therefore, in the
NOPR analysis, DOE applied an additional 3.5 percent reduction to
account for the ability of small diameter lamps to utilize only less
efficient single-ended HIR burners.
CA IOUs noted that small diameter lamps are less efficacious than
larger lamps and agreed with DOE's scaling factor as appropriate,
except for the 3.5 percent to account for double-ended burners, as CA
IOUs believed that small diameter lamps are capable of utilizing these
burners. CA IOUs stated that DOE had not provided enough analysis on
the potential issue that fitting double-ended burners in a small
diameter lamp would change the physical shape of the lamp and thereby
impact whether these lamps can fit in fixtures in which they are
currently used. CA IOUs questioned if DOE had collected data on the
various lengths of small diameter lamps on the market. CA IOUs noted
that they have found R20 lamps with single-ended burners that range in
length from 3.1 to 4.2 inches. They stated that the R20 lamp with a
double-ended burner they submitted to DOE was 3.5 inches long, and
therefore still in the typical R20 range. (CA IOUs, Public Meeting
Transcript, No. 49 at pp. 124-126, 128-129)
OSI commented that, in general, technologies used in PAR30 lamps
cannot be used in PAR20 lamps. (OSI, Public Meeting Transcript, No. 49
at p. 127) OSI noted that luminaire manufacturers construct luminaires
for the actual lamp length on the market, not to the ANSI
specifications for the bulb shape. OSI clarified, therefore, that a
lamp longer than what is otherwise on the market would not fit in
luminaires, regardless of whether it still met the ANSI requirements
for the bulb shape. (OSI, Public Meeting Transcript, No. 49 at pp. 128-
129) GE agreed and added that a small increase in lamp length would not
matter for certain luminaires, such as a track lighting fixture, but
that DOE could not assume the new design would fit in all existing
fixtures. (GE, Public Meeting Transcript, No. 49 at p. 125) OSI
explained that fitting the lamp with the double-ended burner into the
luminaire would not be the only problem, DOE should also consider the
temperature limits that the double-ended burner might force the lamp to
exceed. (OSI, Public Meeting Transcript, No. 49 at p. 127) NEMA
commented that lamps need to be designed to match the physical shape of
the luminaires in the market. (NEMA, No. 54 at p. 49)
DOE must consider how the use of a design option affects product
utility and whether a more efficacious product is an appropriate
substitute for an existing less efficacious product. (42 U.S.C.
6295(o)(2)(B)(i)) DOE confirmed that a double-ended burner was present
in the small diameter (PAR20) prototype lamp mentioned previously and
also in a commercially available PAR20 lamp that is outside the scope
of this rulemaking. However, manufacturers noted that fitting a double-
ended burner into a small diameter lamp requires changes to the
physical shape of the lamp, specifically requiring an extension of the
reflector lens. (NEMA, no. 36 at p. 12; GE, Public Meeting Transcript,
No. 49 at p. 125) While the modified lamp may still meet ANSI standards
for a small diameter lamp such as a PAR20, it would be larger than
PAR20 lamps sold in the past and those currently installed. Because the
lamp shape would be different from the standard sizes of commercially
available small diameter lamps, the modified lamp may not fit in
existing structures. DOE conducted an analysis by comparing lengths of
small diameter lamps to existing fixtures. The lengths of lamps with
double-ended burners varied and DOE cannot state with certainty that
these lengths will fit in all fixtures. Further, within the wattage
range of lamps covered by this rulemaking (40 W or higher), heat
dissipation in lamps with a smaller envelope using a double-ended
burner could also become an issue. Additionally, manufacturer feedback
indicated that even if the double-ended burner could fit into a small
diameter lamp, it would be difficult to place the burner/filament in
the optimal position such that the benefits in efficacy could be
realized.
Therefore, in this final rule DOE continued to apply an additional
3.5 percent reduction factor when scaling efficacies of large diameter
to small diameter lamps to account for the ability of small diameter
lamps to utilize only single-ended burners.
Operating Voltages Greater Than or Equal to 125 Volts
In the NOPR analysis, DOE scaled from IRLs with voltages less than
125 V to IRLs with voltages greater than or equal to 125 V. DOE
developed a scaling factor that would require 130 V lamps operating at
120 V \43\ to use the same technology and possess the same general
performance characteristics as 120 V lamps operating at 120 V. DOE
found that while there may be a slight decrease in efficacy, the
lifetime of a 130 V lamp is doubled when it is operated at 120 V,
giving it an advantage over 120 V lamps. Using the Illuminating
Engineering Society of North America (IESNA) Lighting Handbook
equations that relate lifetime, lumens, and wattage to voltage of
incandescent lamps, DOE determined that a 15 percent scaling factor was
necessary.
---------------------------------------------------------------------------
\43\ While a 130 V lamp is typically operated at 120 V, DOE test
procedures require that lamps rated at 130 V be tested at 130 V.
---------------------------------------------------------------------------
NEMA commented that in the 2009 Lamps Rule, DOE set a level for 130
V lamps which was approximately 15 percent higher than achievable with
the maximum available technology. NEMA argued that, as the efficacy of
130 V lamps is actually slightly lower than 120 V lamps, the only way
to achieve such efficacy levels is to greatly shorten lamp life to less
than 500 hours even if a 130 V lamp was operated on 120 V. If the
consumer had a high voltage problem and was operating near 130 V, the
lamp life would be shortened to a few hundred hours. In both scenarios,
very short life products are unmarketable to the consumer, especially
for 130 V consumers who were primarily buying the lamp due to its long
life on 120 V operation during voltage fluctuations. Giving the example
of the 130 V IRL, NEMA commented that DOE is incorrect in its
assumptions that no utility would be lost with higher IRL standards.
Specifically, NEMA explained that 130 V IRLs were able to operate under
elevated voltage spike and transient conditions, and are now eliminated
from the market due to the 2009 Lamps Rule standards. (NEMA, no. 54 at
p. 48)
Philips commented that the scaling factor used for any new 130 V
lamp standards would not matter as the lamp is already out of the
market. (Philips, Public Meeting Transcript, No. 49 at p. 123) GE
commented that the max tech for 120 V and 130 V lamps are almost
identical, so the 15 percent scaling factor used to scale between the
two
[[Page 4081]]
lamps in the 2009 Lamps Rule is responsible for eliminating 130 V lamps
from the marketplace, along with its utility. (GE, Public Meeting
Transcript, No. 49 at p. 123)
DOE has not found evidence that more efficacious 130 V IRLs are not
technologically feasible or practicable to manufacture. DOE research
indicates that the basic structure, components, and operating
requirements of these lamps do not prevent the application of design
options considered in the engineering analysis to achieve EL 1.
Therefore, in this final rule analysis, DOE continued to determine a
higher efficacy level for these lamp types.
Further, DOE remains concerned, that the operation of 130 V lamps
at 120 V has the potential to significantly affect energy savings.
DOE's research has shown that 130 V lamps are usually operated by
consumers at 120 V rather than on a higher voltage line. This could
incentivize manufacturers to design a less efficient and less expensive
130 V lamp that would meet standards when tested at 130 V. Because they
would be cheaper, there could be a market migration to 130 V lamps and
due to the lower lumen output when 130 V lamps are operated at 120 V,
consumers may purchase more 130 V lamps, resulting in increased energy
consumption.
DOE's research indicates that operating 130 V lamps at 120 V
increases lifetime and lowers efficacy compared to operating these
lamps at 130 V. Therefore, to develop an appropriate scaling factor,
DOE determined the efficacy of 130 V lamps operated at 120 V if their
additional lifetime over that of 120 V lamps were instead used to
increase their efficacy. DOE found this increase in efficacy to be 15
percent. Therefore in this final rule analysis, DOE is using a scaling
factor of a 15 percent efficacy increase from an IRL with voltages less
than 125 V to voltages greater than or equal to 125 V.
Modified Spectrum
In the NOPR analysis, DOE established ELs for modified spectrum
IRLs by scaling from the ELs developed for the standard spectrum
product class. DOE determined that a reduction of 15 percent from the
standard spectrum ELs would be appropriate for modified spectrum IRLs.
EEOs cited a 2009 study by Ecos Consulting which found a 9-11
percent light loss associated with IRL modified spectrum lenses, and
recommended either eliminating the allowance altogether or reducing it
to 10 percent. (EEOs, No. 55 at p. 7)
Regarding the use of a 15 percent scaling factor from standard
spectrum to modified spectrum IRLs, DOE based this determination on
both its understanding of the differences in characteristics and
performance of these two lamp types. In the 2009 Lamps Rule, DOE
assessed the efficacy differences between standard and modified
spectrum IRLs by measuring the efficacies of commercially available
standard and modified spectrum lamps. 74 FR 34080 (July 14, 2009). In
that analysis, DOE correlated the measured color point data of the
lamps with lamp light output reduction and lamp spectral power
distribution. By analyzing the data, DOE established that a reduction
of 15 percent from the standard spectrum to modified spectrum lamps was
necessary. Using the available data for standards-compliant modified
spectrum lamps on the market, DOE compared the efficacies of these two
lamps with standard spectrum lamps with the same wattage and lifetime
by the same manufacturer, and confirmed a 15 percent reduction in
efficacy from a modified spectrum lamp to a standard spectrum lamp.
Therefore, DOE maintained a 15 percent efficacy reduction from a
standard spectrum IRL to a modified spectrum IRL for this final rule.
g. Xenon
DOE identified higher efficiency inert fill gas as a design option
for improving lamp efficacy of IRLs. Specifically, xenon, due to its
low thermal conductivity, can greatly increase lamp efficacy and is
utilized in most covered standards-compliant IRLs.
NEMA commented that the scarcity of xenon makes it questionable
that IRL products will be able to comply with the proposed standards
just by adding more xenon to the lamp burners. NEMA stated that due to
a xenon shortage last year manufacturers had to reduce the use of
xenon. NEMA explained that the remaining efficacy margin under current
standards allows continued production of IRLs during xenon shortages.
Further, NEMA noted that the big xenon producing companies have not
expanded their production capacity as much and there is high demand and
limited production capacity for this gas. (NEMA, No. 54 at p. 35) NEMA
remarked that DOE's xenon price analysis ignores xenon shortages.
(NEMA, No. 54 at p. 11) Further, NEMA stated the current high cost of
xenon is at 13 Euros per liter compared to its previously low price in
early 2013. NEMA predicted that xenon prices would not drop again and
instead continue to increase with the increased number of incandescent
A-line replacement lamps (which also utilize xenon). (NEMA, No. 54 at
p. 35)
NEMA warned that manufacturers are at risk of not being able to
make compliant lamps consistently due to the availability of xenon for
IRLs, and if are unable to do so, they will stop making them, as they
did with the 130 V IRLs. (NEMA, No. 54 at pp. 13-14) NEMA reported that
a member's global buyer for noble gases had reported that xenon
availability is at a minimum. NEMA concluded that the EL should be
reduced due to the unavailability of xenon and noted that lighting
legislation hugely affects the supply and demand of xenon. (NEMA, No.
54 at p. 35)
DOE acknowledges that xenon supply and prices are important factors
for IRLs. Therefore, in the NOPR analysis DOE conducted a market
assessment of xenon supply, demand, and prices as well as LCC and NIA
sensitivities to determine the impact of increased end user lamp prices
due to increases in the price of xenon. DOE updated this market and
price assessment as well as the sensitivities for the final rule
analysis.
Based on this research, DOE determined that even if there are short
term shortages of xenon, the long term supply of xenon is stable due to
its availability in the air. Thus, supply could be increased to meet a
continued increase in demand. DOE acknowledges that the supply of xenon
cannot be quickly altered in the short term, and therefore conducted a
sensitivity analysis to determine the impact of an increased price of
xenon. In the final rule analysis, using NEMA's estimation of the
current price of xenon, DOE updated the xenon price utilized in the LCC
sensitivity analysis from $10 per liter to $18 per liter. Based on the
results of this analysis, DOE determined that positive LCC savings
could still be achieved at EL 1 with higher xenon prices. Additionally,
in the NIA, DOE performed an alternative analysis in which the price of
xenon is assumed to increase by a factor of ten in the near future and
remain at these elevated levels throughout the analysis period. The
impacts of the modeled xenon price increase on the NES and NPV of this
rulemaking were minimal. See appendix 7C of the final rule TSD for
complete details on the xenon price sensitivity conducted in the LCC,
and chapter 12 of this final rule TSD for details on the xenon price
sensitivity conducted in the NIA.
h. Proprietary Technology
In response to the EL (and max tech) proposed for IRLs in the NOPR,
DOE
[[Page 4082]]
received several comments regarding proprietary technology. 79 FR at
24111 (April 29, 2014). NEMA stated that processes for silver, the best
higher efficiency reflector coating, are patent-protected intellectual
property (IP). (NEMA, No. 54 at p. 21)
While DOE had determined in the 2009 Lamps Rule that the silver
reflector was patented technology, DOE research indicated that there
were alternate pathways to achieve this level, such as filament
redesign to achieve higher temperature operation (thus reducing the
lifetime), non-proprietary higher efficiency reflectors, and a higher
efficiency IR coating. 74 FR 34080, 34133 (July 14, 2009). For this
rulemaking, in interviews conducted in the preliminary analysis,
manufacturers indicated that there were no specific patent or
intellectual property barriers to obtaining commercially available IRL
technologies. Further, for the NOPR analysis, DOE confirmed during
interviews that proprietary technology is not a barrier to achieving
the proposed max tech level. Therefore, DOE has concluded that several
manufacturers have found means of designing more efficacious IRLs that
are commercially available, such as through the use of IR glass
coatings and higher efficiency reflector coatings that do not use
proprietary technology. Hence, the EL for IRLs in this final rule is
based on a commercially available improved HIR lamp that does not
require proprietary technology to achieve its efficacy. Therefore, DOE
has determined that this level can be achieved without the use of
proprietary technology.
E. Product Pricing Determination
Typically, DOE develops manufacturer selling prices (MSPs) for
covered products and applies markups to create end-user prices to use
as inputs to the LCC analysis and NIA. Because GSFLs and IRLs are
difficult to reverse-engineer (i.e., not easily disassembled), DOE did
not use this approach to derive end-user prices for the lamps covered
in this rulemaking.
In the NOPR analysis, DOE gathered publicly available lamp pricing
data after the compliance date of the July 2012 standards. 79 FR at
24116 (April 29, 2014). Based on feedback from manufacturer interviews,
DOE determined that GSFLs and IRLs are sold through three main channels
(state procurement; large distributors, including do-it-yourself (DIY)
stores [i.e., Lowe's and Home Depot]; and Internet retailers). Using
these main channels and the pricing data, DOE developed three different
end-user prices as representative of a range of publicly available
prices: low, based on the state procurement channel; medium, based on
large distributors and DIY stores; and high, based on Internet
retailers. DOE then developed an end-user price weighted by
distribution channel. Using manufacturer feedback in interviews, DOE
determined an aggregated percentage of shipments that go through each
of the main channels for GSFLs and IRLs. The large distributors and DIY
stores channel was estimated at 85 percent, the state procurement
channel at 10 percent, and the Internet retail channel at 5 percent.
DOE then applied these percentages respectively to the average medium
price determined for large distributor and DIY stores, the average low
price determined for state procurement contracts, and the average high
price determined for Internet retailers. The sum of these weighted
prices was used as the average consumer price for GSFLs and IRLs in the
main LCC analysis and NIA. DOE continued to utilize the low prices and
high prices in a sensitivity analysis in the LCC analysis. DOE received
several comments on the pricing analysis.
GE remarked that the pricing methodology presented in the NOPR is a
reasonable approach. (GE, Public Meeting Transcript, No. 49 at pp. 130-
131) CA IOUs agreed that the pricing methodology is appropriate for
GSFLs but not for IRLs, as the latter is predominantly purchased
through retail channels for homes and small businesses instead of
through distributors or state procurements. (CA IOUs, Public Meeting
Transcript, No. 49 at p. 131; NEEA, Public Meeting Transcript, No. 49
at pp. 131-132)
DOE's assessment of the GSFL and IRL markets indicated that there
are three main distribution channels. Of these three, DOE determined
that the majority of volume goes through the large distributors and DIY
stores and assigned it an 80 percent weighting. Because this channel
includes stores such as Home Depot and Lowes in addition to
distributors, it encompasses channels through which residential and
small business consumers are more likely to make their purchases.
Additionally, DOE determined that while the volume may be low, IRLs are
included in state procurement contracts; therefore, DOE included them
as a distribution channel and assigned them a low weighting.
In the final rule analysis, DOE used the same methodology as
described for the NOPR analysis. For the final rule, DOE scaled the
prices from 2012$ to 2013$ in the LCC analysis and NIA, using the ratio
of the 2013 consumer price index (CPI) and 2012 CPI multiplied by the
2012$ price. See chapter 7 of the final rule TSD for further
information on the pricing analysis.
F. Energy Use
For the energy-use analysis, DOE estimated the energy use of lamps
in the field (i.e., as they are actually used by consumers). The
energy-use analysis provided the basis for other DOE analyses,
particularly assessments of the energy savings and the savings in
consumer operating costs that could result from DOE's adoption of
amended standard levels.
1. Operating Hours
In the NOPR, to develop annual energy-use estimates, DOE multiplied
annual usage (in hours per year) by the lamp power (in watts) for IRLs
and the lamp-and-ballast system input power (in watts) for GSFLs. Id.
at 24117. DOE characterized representative lamp or lamp-and-ballast
systems in the engineering analysis (see section VI.D). To characterize
the country's average use of lamps for a typical year, DOE developed
annual operating hour distributions by sector, using data published in
the 2010 U.S. Lighting Market Characterization report (2010 LMC),\44\
the Commercial Building Energy Consumption Survey (CBECS),\45\ the
Manufacturer Energy Consumption Survey (MECS),\46\ and the Residential
Energy Consumption Survey (RECS).\47\ Id. at 24118. DOE did not receive
any comments on this subject and maintained this approach for
determining operating hours for this final rule. DOE updated the MECS
data to 2010 data.\48\
---------------------------------------------------------------------------
\44\ U.S. Department of Energy, Office of Energy Efficiency and
Renewable Energy. Energy Conservation Program for Consumer Products:
2010 U.S. Lighting Market Characterization. 2012. Washington, DC.
http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/2010-lmc-final-jan-2012.pdf.
\45\ U.S. Department of Energy, Energy Information
Administration. Commercial Building Energy Consumption Survey:
Micro-level data, file 2 Building Activities, Special Measures of
Size, and Multi-building Facilities. 2003. Washington, DC.
www.eia.gov/consumption/commercial/data/2003/index.cfm?view=microdata.
\46\ U.S. Department of Energy, Energy Information
Administration. Manufacturing Energy Consumption Survey, Table 9.1:
Enclosed Floorspace and Number of Establishment Buildings. 2006.
Washington, DC. www.eia.gov/consumption/manufacturing/data/2006/xls/Table9_1.xlsl.
\47\ U.S. Department of Energy, Energy Information
Administration. RECS Public Use Microdata files. 2009. Washington,
DC. www.eia.gov/consumption/residential/data/2009.
\48\ U.S. Department of Energy, Energy Information
Administration. Manufacturing Energy Consumption Survey, Table 9.1:
Enclosed Floorspace and Number of Establishment Buildings. 2010.
Washington, DC. http://www.eia.gov/consumption/manufacturing/data/2010/.
---------------------------------------------------------------------------
[[Page 4083]]
2. Lighting Controls
DOE evaluated the impact of lighting controls on the energy use of
GSFLs and IRLs. Most lighting controls have one of two impacts:
reducing operating wattage or reducing operating hours. DOE refers to
these two groups of controls as dimmers or light sensors, and occupancy
sensors, respectively. The calculated operating hours used in the
reference case already account for the use of occupancy sensors because
the 2010 LMC operating hour data are based on building surveys and
metering data. In the NOPR analysis, DOE accounted for the use of
dimmers or light sensors by modeling GSFLs and IRLs on dimmers and
developing associated energy-use results for both types of covered
lamps as a sensitivity analysis. See appendix 6A of the final rule TSD
for further information.
DOE received an overall comment regarding its approach to lighting
controls for GSFLs and IRLs. Westinghouse suggested that DOE separate
dimming percentages between IRLs and GSFLs because in the commercial
sector, GSFLs are generally dimmed more often and IRLs are on simple
switch circuits, and in the residential sector, IRLs are frequently
dimmed and GSFLs are almost never dimmed. (Westinghouse, Public Meeting
Transcript, No. 49 at p. 142)
DOE agrees with Westinghouse that GSFLs and IRLs are used
differently and that usage varies depending on the market sector. DOE
calculated separate dimming percentages for GSFL and IRL and for each
market sector in which they are present. The following sections discuss
these percentages in more detail.
a. General Service Fluorescent Lamp Lighting Controls
In the NOPR, DOE assessed the impacts of dimmers on GSFLs by
determining the reduction in system lumen output and system input power
as a result of using dimming ballasts. Id. Based on product research
and manufacturer feedback, DOE analyzed dimming scenarios for 2-lamp 4-
foot MBP systems, 4-lamp 4-foot MBP systems, 2-lamp 4-foot T5 MiniBP SO
systems, and 2-lamp 4-foot T5 MiniBP HO systems operating in the
commercial and industrial sectors. DOE did not analyze dimmable GSFL
systems in the residential sector because DOE believes these systems
are rarely dimmed. DOE determined that the average reduction of system
lumen output for GSFLs was 33 percent, based on research and
manufacturer input. DOE did not receive any comments on this approach
to analyzing GSFL dimming and therefore maintained this approach in the
final rule.
b. Incandescent Reflector Lamp Lighting Controls
In the NOPR analysis, DOE research indicated that, on average,
consumers using dimmers reduce lamp wattage by 20 percent,
corresponding to a lumen reduction of 25 percent and an increase in
lifetime by a factor of 3.94. Id. at 24119. DOE analyzed two scenarios
in LCC sensitivity analyses: (1) The light output of the baseline lamp
was reduced by 25 percent and more efficient lamps were dimmed to the
same light output and (2) the characteristics of the lamps analyzed
represented the distribution of dimmers across the nation. For the
second scenario, DOE used the 2010 LMC to determine that 29 percent of
halogen IRLs operate on dimmers or light sensors in the residential
sector and 5 percent of halogen IRLs operate on dimmers in the
commercial sector and used these percentages to calculate weighted-
average performance characteristics. DOE received several comments on
its approach to analyzing IRL dimming.
Philips disagreed with only 5 percent dimming in the commercial
sector, stating that given the 30-year analysis period, this percentage
is understated. Philips specifically referenced California's new
requirements for dimming in all renovations and new buildings and
American Society of Heating, Refrigerating and Air Conditioning
Engineers' (ASHRAE's) support of these measures driving increased
dimming prevalence across the country. (Philips, Public Meeting
Transcript, No. 49 at pp. 137-138) NEEA agreed with Philips that 5
percent dimming for the commercial sector is too low and added that the
29 percent dimming DOE used for the residential sector is far too high.
Westinghouse also questioned the 29 percent dimming estimate for the
residential sector noting that if the percentage was for residential
IRLs only, it may be representative but was too high for GSFLs as
homeowners tend not to dim those lamps. (Westinghouse, Public Meeting
Transcript, No. 49 at p. 141)
To update DOE's numbers, NEEA suggested a report they had completed
on a 13-month residential metering study that studied 2,200 sensors in
103 houses by fixture type, technology, and room. NEEA explained that
their data include the wattage of the lamp, the controls on the socket,
the number of lamps per fixture, the number of lamps per switch, the
type of fixture, and room in which it is located. NEEA suggested that
the data contain enough samples to characterize residential lighting in
the four states included. NEEA also mentioned a census they conducted
across 1,400 houses that gathered the same data, which can then be
applied across the entire region. NEEA sent a summary of the data to
DOE for immediate use, and stated that the rest of the data would be
available for download on NEEA's and NEMA's Web sites. (NEEA, Public
Meeting Transcript, No. 49 at pp.138, 140)
Regarding the accuracy of the percentages, the 29 percent of lamps
on dimmers was applied to IRLs for the residential sector analysis and
the 5 percent of lamps on dimmers was applied to IRLs for the
commercial sector. As noted, these values are based on the 2010 LMC and
DOE believes are an accurate representation of the percentage of IRLs
on dimmers in each sector. Regarding the potential increase in
percentage, while the percentage of occupancy sensors may increase, DOE
assumed that the percentage of IRLs on dimmers will remain relatively
constant because dimmers provide utility for consumers beyond energy
savings. DOE also reviewed NEEA's data, but ultimately maintained the
methodology described above because NEEA's data is limited to the
Northwest region while the 2010 LMC lighting controls data is based
several building audit studies, spanning several geographic regions and
years of data collection, which was then scaled based an inventory of
lighting at the national level. Therefore, for this final rule, DOE
maintained its methodology for analyzing dimming for IRLs.
G. Life-Cycle Cost Analysis and Payback Period Analysis
In the NOPR analysis, DOE conducted LCC and PBP analyses to
evaluate the economic impacts of proposed energy conservation standards
for GSFLs and IRLs on individual consumers. 79 FR at 24119 (April 29,
2014). The LCC is the total consumer expense over the life of a
product, consisting of purchase, installation, and operating costs
(operating costs are expenses for energy use, maintenance, and repair).
To compute the operating costs, DOE discounted future operating costs
to the time of purchase and summed them over the lifetime of the
product. The PBP is the estimated amount of time (in years) it takes
consumers to recover the increased purchase cost (including
installation) of a more efficient product through lower operating
costs. DOE calculates the PBP by dividing the
[[Page 4084]]
change in purchase cost (normally higher) by the change in average
annual operating cost (normally lower) that results from the higher
efficiency standard. DOE used a ``simple'' PBP for this rulemaking,
which does not take into account other changes in operating expenses
over time or the time value of money.
For any given efficacy or energy-use level, DOE measures the PBP
and the change in LCC relative to an estimated base-case product
efficacy or energy-use level. The base-case estimate reflects the
market without new or amended mandatory energy conservation standards,
including the market for products that exceed the current energy
conservation standards.
Inputs to the calculation of total installed cost include the cost
of the product--which includes consumer product price and sales taxes--
and installation costs. Inputs to the calculation of operating expenses
include annual energy consumption, energy prices and price projections,
repair and maintenance costs, product lifetimes, discount rates, and
the year in which compliance with proposed standards would be required.
DOE also incorporated a residual value calculation to account for any
remaining lifetime of lamps at the end of the analysis period. The
residual value is an estimate of the product's value to the consumer at
the end of the LCC analysis period. In addition, this residual value
recognizes that a lamp may continue to function beyond the end of the
analysis period. DOE calculates the residual value by linearly
prorating the product's initial cost consistent with the methodology
described in the Life-Cycle Costing Manual for the Federal Energy
Management Program.\49\
---------------------------------------------------------------------------
\49\ Fuller, Sieglinde K. and Stephen R. Peterson. National
Institute of Standards and Technology Handbook 135 (1996 Edition);
Life-Cycle Costing Manual for the Federal Energy Management Program.
(Prepared for U. S. Department of Energy, Federal Energy Management
Program, Office of the Assistant Secretary for Conservation and
Renewable Energy.) February 1996. NIST: Gaithersburg, MD. Available
at: http://fire.nist.gov/bfrlpubs/build96/PDF/b96121.pdf.
---------------------------------------------------------------------------
As inputs to the PBP analysis, DOE used the total installed cost of
the product to the consumer for each efficacy level, as well as the
first-year annual operating costs for each efficacy level. The
calculation requires the same inputs as the LCC, except for energy
price trends and discount rates; only energy prices for the year in
which compliance with any new standard would be required (2018, in this
case) are needed.
To account for uncertainty and variability, DOE created value
distributions for inputs as appropriate, including operating hours,
electricity prices, discount rates and sales tax rates, and disposal
costs. For example, DOE created a probability distribution of annual
energy consumption in its energy-use analysis, based in part on a range
of annual operating hours. The operating hour distributions capture
variation across census divisions and large states, building types, and
lamp or lamp-and-ballast systems for three sectors (commercial,
industrial, and residential).
DOE conducted the LCC and PBP analyses using a spreadsheet model
developed in Microsoft Excel. When combined with Crystal Ball (a
commercially available software program), the spreadsheet model
generates a Monte Carlo simulation \50\ to perform the analysis by
incorporating uncertainty and variability considerations. The Monte
Carlo simulations randomly sample input values from the probability
distributions and lamp user samples, performing 1,000 iterations per
simulation run.
---------------------------------------------------------------------------
\50\ Monte Carlo simulations model uncertainty by utilizing
probability distributions instead of single values for certain
inputs and variables.
---------------------------------------------------------------------------
DOE did not receive any comments on the general methodology
regarding the LCC and PBP assessment. In the final rule analysis, DOE
generally maintained the methodology from the NOPR analysis, with a few
changes. Table VI.9 summarizes the approach and data DOE used to derive
inputs to the LCC and PBP calculations for the NOPR, as well as the
changes made for this final rule. The final rule TSD chapter 8 and its
appendices provide details on the spreadsheet model and of all the
inputs to the LCC and PBP analyses. The final rule TSD appendix 8B
provides results of the sensitivity analyses conducted using Monte
Carlo simulation. The subsections that follow discuss the comments
regarding each initial input and any changes made to them in the final
rule analysis.
Table VI.9--Summary of Inputs and Key Assumptions in the LCC and PBP Analyses *
----------------------------------------------------------------------------------------------------------------
Inputs NOPR TSD Changes for the Final Rule
----------------------------------------------------------------------------------------------------------------
Consumer Product Price................ Applied discounts to manufacturer No change.
catalog (``blue book'') pricing in
order to represent low, medium, and
high prices for all lamp categories.
Used a weighted-average price in the
main analysis based on the percentage
of shipments that go through the
distribution channel having low,
medium, or high prices.
Sales Tax............................. Derived sector-specific average tax No change.
values based on the probability of
purchasing a GSFL or IRL in each census
division and large state from data
provided by the Sales Tax Clearinghouse.
Installation Cost..................... Derived costs using the RS Means No change.
Electrical Cost Data and U.S. Bureau of
Labor Statistics to obtain average
labor times for installation, as well
as labor rates for electricians and
helpers based on wage rates, benefits,
and training costs.
Annual Operating Hours................ Determined operating hours by Updated MECS data to 2010
associating operating hours for a GSFL data.
or IRL in a specific building type
using the average lamps per square foot
and the percentage of lamps of each
type with regional distributions of
various building types using the 2010
LMC and EIA's 2003 CBECS, 2009 RECS,
and 2006 MECS.
[[Page 4085]]
Product Energy Consumption Rate....... Determined lamp input power for IRLs No change.
based on published manufacturer
literature. Calculated system input
power for GSFLs. Used lamp arc power,
catalog BF, number of lamps per system,
and tested BLE (when possible) to
calculate system input power for each
unique lamp-and-ballast combination.
Electricity Prices.................... Electricity: Based on EIA's Form 861 Electricity: Based on EIA's
data for 2011 scaled to 2012 (the Form 861 data for 2012 scaled
dollar year of the analysis) using AEO to 2013 (the dollar year of
2013 and the consumer price index. the analysis) using AEO 2014
Variability: Weighted-average national and the consumer price index.
price for each sector and lamp type Variability: No change.
calculated from the probability of a
GSFL or IRL purchased in each census
division or large state.
Electricity Price Projections......... Forecasted using AEO 2013............... Forecasted using AEO 2014.
Replacement and Disposal Costs........ Commercial and industrial: Included No change.
labor and materials costs for lamp
replacement, and disposal costs for
failed GSFLs.
Residential: Included only materials
cost for lamps, with no lamp disposal
costs.
Product Lifetime...................... Ballast lifetime based on average No change.
ballast life of 49,054 from 2011
Ballast Rule. Lamp lifetime based on
published manufacturer literature where
available.
Discount Rates........................ Commercial and industrial: Derived No change.
discount rates using the cost of
capital of publicly traded firms in the
sectors that purchase lamps, based on
data in the 2003 CBECS, Damodaran
Online,\51\ Office of Management and
Budget (OMB) Circular No. A-94,\52\ and
state and local bond interest
rates.\53\
Residential: Derived discount rates
using the finance cost of raising funds
to purchase lamps either through the
financial cost of any debt incurred to
purchase product or the opportunity
cost of any equity used to purchase
equipment, based on the Federal
Reserve's Survey of Consumer Finances
data \54\ for 1989, 1992, 1995, 1998,
2001, 2004, 2007, and 2010.
Analysis Period....................... IRLs and commercial and industrial No change.
GSFLs: Based on the baseline lamp life
in hours divided by the annual
operating hours of that lamp.
Residential GSFLs lamp failure: Based on
the lifetime of the ballast.
Residential GSFLs ballast failure and
new construction/renovation: Based on
the lifetime of the ballast.
Compliance Date of Standards.......... 2017.................................... 2018.
Lamp Purchase Events.................. Assessed three events: lamp failure, No change.
ballast failure (GSFLs only), and new
construction/renovation.
----------------------------------------------------------------------------------------------------------------
* References for the data sources mentioned in this table are provided in the sections following the table or in
chapter 8 of the final rule TSD.
1. Consumer Product Price
In the NOPR, DOE used a variety of sources to develop consumer
product prices, including lamp prices from manufacturers' blue books,
state procurement contracts, large electrical supply distributors,
hardware and home improvement stores, Internet retailers, and other
similar sources. 79 FR at 24122 (April 29, 2014). DOE then developed
low, medium, and high prices based on its findings. DOE calculated a
weighted-average price based on the percentage of shipments going
through the low discount (high price), medium discount (medium price),
and high discount (low price) distribution channels. Because
fluorescent lamps operate on a ballast in practice, DOE analyzed lamp-
and-ballast systems in the engineering analysis and therefore also
determined end-user prices for ballasts. DOE utilized the end-user
prices from the 2011 Ballast Rule converted to 2012$ to develop prices
for replacement ballasts. In the final analysis, DOE maintained the
same methodology, but converted the prices to 2013$ instead of 2012$.
For further discussion regarding end-user prices, see section VI.E.
---------------------------------------------------------------------------
\51\ Damodaran Online, The Data Page: Historical Returns on
Stocks, Bonds, and Bills--United States (2014). Available at: http:/
/pages.stern.nyu.edu/~adamodar.
\52\ U.S. Office of Management and Budget, Circular No. A-94
Appendix C (2013). Available at: www.whitehouse.gov/omb/circulars_a094/a94_appx-c.
\53\ Federal Reserve Board, Statistics: Releases and Historical
Data--Selected Interest Rates--State and Local Bonds (2014).
Available at: www.federalreserve.gov/datadownload/Build.aspx?rel=H15.
\54\ The Federal Reserve Board, Survey of Consumer Finances.
Available at: www.federalreserve.gov/PUBS/oss/oss2/scfindex.html.
---------------------------------------------------------------------------
On February 22, 2011, DOE published a notice of data availability
(NODA; 76 FR 9696) stating that DOE may consider whether its regulatory
analysis would be improved by addressing product price trends. Using
three decades of historic data on the quantities and values of domestic
shipments of fluorescent lamps and PAR lamps reported by the U.S.
Census Bureau in their Current Industrial Reports, DOE examined product
prices trends, fitting the data to an experience curve, as described in
chapter 11 of the NOPR TSD. DOE found that the data are well-
represented by the experience curve and consistent with price learning
theory. Therefore, consistent with the NODA, DOE incorporated price
trends into this rulemaking. In the LCC analysis, DOE
[[Page 4086]]
adjusts prices for each year using the experience curve.
2. Sales Tax
In the NOPR analysis, DOE obtained state and local sales tax data
from the Sales Tax Clearinghouse. Id. The data represented weighted
averages that included county and city rates. DOE used the data to
calculate a weighted-average sales tax based on the probability of a
GSFL or IRL purchased for a particular building type in each census
division and large state (New York, California, Texas, and Florida).
DOE used information in the 2010 LMC, such as the number of lamps per
square feet and the percentage of lamps within a building that are
linear fluorescent or halogen. In combination with this information,
DOE used CBECS, MECS, and RECS, respectively, for commercial,
industrial, and residential building data on building types in each
census division and large state. DOE did not receive any feedback on
its approach to determining sales tax. In this final rule analysis, DOE
used the same methodology with updated sales tax data from the Sales
Tax Clearinghouse.\55\
---------------------------------------------------------------------------
\55\ Sales Tax Clearinghouse. Aggregate State Tax Rates. (2014).
Available at: http://thestc.com/STrates.stm.
---------------------------------------------------------------------------
3. Installation Cost
The installation cost is the total cost to the consumer to install
the product, excluding the consumer product price. Installation costs
include labor, overhead, and any miscellaneous materials and parts. As
detailed in the NOPR analysis, DOE considered the total installed cost
of a lamp or lamp-and-ballast system to be the consumer product price
(including sales taxes) plus the installation cost. For the commercial
and industrial sectors, DOE assumed consumers must pay to install the
lamp or lamp-and-ballast system and assumed the installation cost was
the product of the average labor rate and the time needed to install a
lamp or lamp and ballast. In the residential sector, DOE assumed that
consumers must pay for only the installation of a lamp-and-ballast
system. Therefore, the installation cost assumed was the product of the
average labor rate and the time needed to install the lamp-and-ballast
system. DOE assumed that residential consumers would install their own
replacement lamps and, thus, would incur no installation cost when
replacing their own lamp. Id.
DOE did not receive any comments on the installation cost. DOE
retained this methodology for determining installation costs in this
final rule analysis.
4. Annual Energy Use
As discussed in section VI.F, DOE estimated the annual energy use
of representative lamp or lamp-and-ballast systems by multiplying input
power and sector operating hours. For further discussion regarding
annual energy-use calculations, see section VI.F.1. DOE maintained its
methodology of determining annual energy-use inputs in this final rule
analysis.
5. Product Energy Consumption Rate
As in the NOPR analysis, DOE determined lamp input power for IRLs
based on published manufacturer literature. 79 FR at 24123 (April 29,
2014). For GSFLs, DOE calculated the system input power using published
manufacturer literature and test data. DOE used lamp arc power, catalog
BF, number of lamps per system, and tested BLE (when possible) to
calculate system input power for each unique lamp-and-ballast
combination. The rated system input power was then multiplied by the
annual operating hours of the system to determine the annual energy
consumption. DOE did not receive any comments on energy consumption
rate calculations. DOE retained this methodology for determining energy
consumption in this final rule analysis.
6. Electricity Prices
For the LCC and PBP in the NOPR analysis, DOE derived average
energy prices for 13 U.S. geographic areas consisting of the nine
census divisions, with four large states (New York, Florida, Texas, and
California) treated separately. Id. For census divisions containing one
of these large states, DOE calculated the regional average, excluding
the data for the large state. The derivation of prices was based on
data from EIA Form 861, ``Annual Electric Power Industry Database.''
DOE calculated weighted-average electricity prices based on the
probability of a GSFL or IRL purchased in each census division and
large state. The same methodology as noted previously for determining
average weighted sales tax was used to calculate average weighted
electricity prices. DOE used data published in the 2010 LMC in
combination with CBECS, MECS, and RECS to determine an average weighted
electricity price based on the probability of a GSFL or IRL in a
particular building type in each census division and large state. DOE
did not receive any comments on this approach. DOE retained this
methodology for determining electricity prices in this final rule
analysis.
7. Electricity Price Projections
To estimate the trends in energy prices for the NOPR analysis, DOE
used the price forecasts in AEO 2013. Id. To arrive at prices in future
years, DOE multiplied current average prices by the forecast of annual
average price changes in AEO 2013. In this final rule analysis, DOE
used the same approach, but updated its energy price forecasts using
AEO 2014. In addition, the spreadsheet tools that DOE used to conduct
the LCC and PBP analyses allow users to select price forecasts from
AEO's low-growth, high-growth, and reference case scenarios to estimate
the sensitivity of the LCC and PBP to different energy price forecasts.
DOE did not receive any comments on this approach and maintained this
methodology for determining electricity price projections in the final
rule analysis.
8. Replacement and Disposal Costs
In its NOPR analysis, DOE addressed lamp replacements occurring
within the analysis period as part of installed costs for considered
lamp or lamp-and-ballast system designs. Id. Replacement costs in the
commercial and industrial sectors included the labor and materials
costs associated with replacing a lamp at the end of its lifetime,
discounted to 2012$. For the residential sector, DOE assumed that
consumers would install their own replacement lamps and incur no
related labor costs.
Some consumers recycle failed GSFLs, thus incurring a disposal
cost. In its research, DOE found average disposal costs of 10 cents per
linear foot for GSFLs.\56\ A 2004 report by the Association of Lighting
and Mercury Recyclers noted that approximately 30 percent of lamps used
by businesses and 2 percent of lamps in the residential sector are
recycled nationwide.\57\ DOE considered the 30 percent lamp-recycling
rate to be significant and incorporated GSFL disposal costs into the
LCC analysis for commercial and industrial consumers. Given the very
low (2 percent) estimated lamp-recycling rate in the residential
sector, DOE assumed that residential consumers would be less likely to
voluntarily incur the higher disposal costs. Therefore, DOE excluded
the
[[Page 4087]]
disposal costs for lamps and ballasts from the LCC analysis for
residential GSFLs.
---------------------------------------------------------------------------
\56\ Environmental Health and Safety Online's fluorescent lights
and lighting disposal and recycling Web page--Recycling Costs.
Available at www.ehso.com/fluoresc.php.
\57\ Association of Lighting and Mercury Recyclers, ``National
Mercury-Lamp Recycling Rate and Availability of Lamp Recycling
Services in the U.S.'' Nov. 2004.
---------------------------------------------------------------------------
DOE received no comments concerning these assumed recycling rates,
disposal costs, and their application in the LCC analysis. DOE
maintained this approach in the final rule analysis.
9. Lamp Purchase Events
DOE designed the LCC and PBP analyses for this rulemaking around
scenarios where consumers need to purchase a lamp. Each of these events
may give the consumer a different set of lamp or lamp-and-ballast
designs and, therefore, a different set of LCC savings for a certain
efficacy level. In the NOPR analysis, DOE evaluated three types of
events that would prompt a consumer to purchase a lamp. Id at 24123.
These events are described in the following list. Though described
primarily in the context of GSFLs, lamp purchase events can be applied
to IRLs as well. However, considering that IRLs are not used with a
ballast, the only lamp purchase events applicable to IRLs are lamp
failure (Event I) and new construction and renovation (Event III).
Lamp Failure (Event I): This event reflects a scenario in
which a lamp has failed (spot relamping) or is about to fail (group
relamping). In the base case, identical lamps are installed as
replacements. In the standards case, the consumer installs a standards-
compliant lamp that is compatible with the existing ballast.
Ballast Failure (Event II): This is a scenario in which
the failure of the installed ballast triggers a lamp-and-ballast
purchase.
New Construction and Renovation (Event III): This event
encompasses all fixture installations where the lighting design will be
completely new or can be completely changed. During new construction
and renovation, the spatial layout of fixtures in a building space is
not constrained to any previous configuration. However, because DOE's
higher efficacy replacements generally maintain lumen output within 10
percent of the baseline system, DOE did not assume that spacing was
changed.
DOE received several comments regarding the lamp purchasing events
assessed in the NOPR analysis. OSI questioned if, in the event of
ballast failure in the new construction and renovation scenario, the
installed cost includes the price of controls that are required by
recent building codes, especially ASHRAE 90.1. (OSI, Public Meeting
Transcript, No. 49 at pp. 144-145) ASHRAE 90.1 is a standard that
provides the minimum requirements for energy-efficient design of
certain commercial buildings. OSI noted that any replacement of lamps
and ballasts that could be considered renovation would be subject to
building codes requiring the installation of lighting controls, and
this cost should be added to the scenarios. (OSI, Public Meeting
Transcript, No. 49 at p. 146) Westinghouse agreed, stating that having
to buy a control for a lamp should be treated no differently than
having to hire an electrician and is part of the installation cost for
a typical end-user product. (Westinghouse, Public Meeting Transcript,
No. 49 at p. 145) NEEA acknowledged that controls may be required by
building codes, but pointed out that a building code would apply
regardless of the EL chosen. Thus the costs of controls would be the
same at each level and would be unlikely to change the incremental
installed costs analyzed in the LCC analysis. (NEEA, Public Meeting
Transcript, No. 49 at p. 146)
DOE agrees that in the LCC analysis, a consumer that purchases a
new lamp will have to comply with the same building code in both the
base case (absent amended energy conservation standards) and the
standards case (with amended energy conservation standards). In
instances where the building code would require lighting controls, DOE
reviewed the lighting systems analyzed in the GSFL engineering analysis
for this rulemaking and determined that the required controls would not
differ between the baseline systems analyzed and each higher efficacy
system. Because the controls would be the same at each level, the
incremental costs associated with the controls (price and installation)
would not be different for the different ELs, Therefore, DOE did not
include the cost of controls in the final rule analysis.
Regarding more efficient replacement systems analyzed, NEMA noted
switching from T12 or T8 to T5 lamps is expensive, and therefore
suggested that the LCC and PBP analyses include the re-ballasting costs
for lamps, luminaires, ballasts, labor, and down time. (NEMA, No. 54 at
p. 48)
The LCC and PBP analyses determine the economic impacts to a
consumer within an individual product class. Because only one type of
lamp (i.e., T5 or T8) is specified within each product class, DOE does
not account for product class switching in the LCC and PBP analyses.
DOE does, however, account for product class switching in the shipments
analysis and, subsequently, the NIA. See VI.I for additional details on
product class switching in the shipments analysis.
DOE received no other comments on lamp purchase events and is
maintaining the lamp purchase events and the associated assumptions in
this final rule analysis.
10. Product Lifetime
a. Lamp Lifetime
In the NOPR analysis, DOE used manufacturer literature to determine
lamp lifetimes. DOE also considered the impact of group relamping
practices on GSFL lifetime in the commercial and industrial sectors. In
the NOPR analysis, DOE assumed that a lamp subject to group relamping
operates for 85 percent of its rated lifetime based on information from
manufacturers in interviews that consumer behavior had changed due to
recent economic conditions and group relamping occurred at 85-90
percent of rated life. Id. at 24124.
Westinghouse agreed that relamping would occur at 85 percent of
rated life in the commercial sector, however, they noted that in the
residential sector, relamping would occur when the resident cannot see
or when the lamp fails. (Westinghouse, Public Meeting Transcript, No.
49 at p. 144) Philips further commented that older consumers would
relamp sooner, due to impaired eyesight. (Philips, Public Meeting
Transcript, No. 49 at p. 144)
DOE assumed that during group relamping, a consumer removes and
replaces a collection of lamps that are near the end of their lives at
once, as a way of avoiding the failure of any individual lamp in the
collection. While DOE models this behavior in the commercial sector,
DOE assumed that residential sector consumers replace their lamps
either when they fail or when the associated fixture is removed; thus,
there are no spot or group relamping lifetime impacts on the
residential sector.
NEMA noted that group relamping is commonly recommended at 70-80
percent of rated life. During the 2010-2011 rare earth crises, group
relamping may have been delayed, but it has since come back in line
with the recommended time frame. (NEMA, No. 54 at p. 32)
DOE acknowledges that the economic conditions that impacted group
relamping decisions may have been temporary and, taking into
consideration NEMA's observation, changed the group relamping
assumption to 75 percent of rated life for the final rule analysis. See
chapter 8 of the final rule TSD for further details.
[[Page 4088]]
In the NOPR, DOE used 15 years as the estimated fixture and ballast
lifetime in the residential sector for purposes of its analyses. NEMA
commented that DOE should not assume a normal average lifetime for
residential GSFLs as these lamps typically fail from frequent switching
rather than deterioration of the emitter. NEMA mentioned that failure
due to rapid switching is unpredictable and variable, based on the
frequency of switches, and therefore it is difficult to define an
average lifetime in this sector. NEMA suggested that DOE review their
analysis for residential GSFL lifetime by incorporating switching and
hours of use data from the NEEA residential building stock assessment
metering study. (NEMA, No. 54 at pp. 31-32)
Based on a report, DOE found that the average fixture and ballast
in the residential sector lasts for 15 years.\58\ Therefore, in its
residential sector analysis for GSFLs, DOE established 15 years as the
average ballast lifetime in the residential sector, regardless of
operating hours. Because the lamp lifetime exceeds the ballast lifetime
under average operating hours conditions, DOE assumed that the ballast
lifetime of 15 years limits the lamp lifetime. While the typical
lifetime of a GSFL is about 37 years in the residential sector, by
basing the analysis period on the ballast lifetime, DOE used a much
shorter analysis period than the product lifetime in its analysis for
residential GSFLs and, therefore, likely accounted for early failure of
lamps due to frequent switching. As recommended by NEMA, DOE also
reviewed NEEA's data, but found that the data did not provide the
lifetime data on the GSFLs DOE analyzed in the residential sector.
Therefore, DOE maintained the lamp lifetime of 15 years based on the
ballast lifetime for this final rule analysis.
---------------------------------------------------------------------------
\58\ Economic Research Associates, Inc., and Quantec, LLC.
Revised/Updated EULs Based On Retention And Persistence Studies
Results. Southern California Edison, 2005.
---------------------------------------------------------------------------
b. Ballast Lifetime
Chapter 8 of the NOPR TSD detailed DOE's development of average
ballast lifetimes, which were based on assumptions used in the 2011
Ballast Rule. For ballasts in the commercial and industrial sectors,
DOE used an average ballast lifetime of 49,054 hours. Consistent with
the 2011 Ballast Rule, DOE assumed an average ballast lifetime of
approximately 15 years in the residential sector. DOE received no
comments on this approach and retained these ballast lifetimes in the
final rule.
11. Discount Rates
The calculation of consumer LCC requires the use of an appropriate
discount rate. DOE used the discount rate to determine the present
value of lifetime operating expenses. The discount rate used in the LCC
analysis represents the rate from an individual consumer's
perspective.\59\
---------------------------------------------------------------------------
\59\ The consumer discount rate is in contrast to the discount
rates used in the NIA, which are intended to represent the rate of
return of capital in the U.S. economy, as well as the societal rate
of return on private consumption.
---------------------------------------------------------------------------
In the NOPR analysis, for the residential sector, DOE derived
discount rates from estimates of the interest or ``finance cost'' to
purchase residential products. 79 FR at 24125 (April 29, 2014). The
finance cost of raising funds to purchase these products can be
interpreted as: 1) the financial cost of any debt incurred to purchase
products (principally interest charges on debt), or 2) the opportunity
cost of any equity used to purchase products (principally interest
earnings on household equity). Household equity is represented by
holdings in assets, such as stocks and bonds, as well as the return on
homeowner equity. Much of the data required, which involves determining
the cost of debt and equity, comes from the Federal Reserve Board's
triennial ``Survey of Consumer Finances.'' \60\ For the commercial and
industrial sectors, DOE derived discount rates from the cost of capital
of publicly traded firms in the business sectors that purchase lamps.
---------------------------------------------------------------------------
\60\ The Federal Reserve Board. Survey of Consumer Finances
1989, 1992, 1995, 1998, 2001, 2004, 2007, 2010. Federal Reserve
Board: Washington, DC. Available at: www.federalreserve.gov/pubs/
oss/oss2/scfindex.html.
---------------------------------------------------------------------------
DOE received no comments concerning the determination of discount
rates. Thus, DOE maintained this approach in the final rule analysis.
For further details on discount rates, see chapter 8 and appendix 8C of
the final rule TSD.
12. Analysis Period
The analysis period is the span of time over which the LCC is
calculated. In the NOPR analysis, DOE used the longest baseline lamp
life in a product class divided by the annual operating hours of that
lamp as the analysis period. Id. During Monte Carlo simulations for the
LCC analysis, DOE selected the analysis period based on the longest
baseline lamp life divided by the annual operating hours chosen by
Crystal Ball. For GSFLs in the residential sector, the analysis period
is based on the useful life of the baseline lamp for a specific event.
GE and Philips commented that this approach seemed reasonable. (GE,
Public Meeting Transcript, No. 49 at p. 147; Philips, Public Meeting
Transcript, No. 49 at p. 148) DOE maintained this approach for
determining the analysis period in the final rule analysis.
13. Compliance Date of Standards
The compliance date is the date when a covered product is required
to meet a new or amended standard. Consistent with 42 U.S.C.
6295(i)(5), DOE analyzed a compliance date in 2018, three years after
the publication of the final amended standards. DOE calculated the LCC
for all end users, as if each one would purchase a new lamp in the year
compliance with the standard is required.
14. Incandescent Reflector Lamp Life-Cycle Cost Results in the NOPR
DOE received several comments regarding the LCC results of IRLs in
the NOPR analysis. GE commented that the LCC analysis appeared to be
done mostly for commercial customers of PAR38 lamps and would have a
dramatically different and negative outcome for the residential sector
and other consumers. (GE, Public Meeting Transcript, No. 49 at p. 152)
DOE conducted separate LCC analyses for the commercial sector and
residential sector. See chapter 8 of the final rule TSD for all results
by sector.
NEMA commented that consumers were unlikely to realize the
operating cost savings DOE claimed in the NOPR. (NEMA, No. 54 at p. 11)
NEMA questioned how the proposed rulemaking can generate positive
savings for consumers of IRLs when the increased product costs are
higher than the energy savings. NEMA reasoned that an 18.75 lm/W PAR38
would need an infrared coated burner to reach an efficacy of 19.57 lm/W
to comply with the standards proposed in the NOPR. The increased
efficacy would save the consumer $0.36 per year while the burner would
add about $1 to the cost of the lamp. NEMA further argued that the lamp
is only rated at 1,100 hours, so the consumer will never see the
payback from the improved lamp. NEMA commented that DOE cannot assume
that technological breakthroughs yet to be discovered would improve the
efficacy and lifetime of the lamp. As such, NEMA concluded that DOE
cannot prove that a full range of products would comply with the
standards proposed in the NOPR, and that DOE has not adequately
addressed the negative cost effects on the consumer. (NEMA, No. 54 at
pp. 32-33)
[[Page 4089]]
In its analysis, DOE considered only more efficacious replacements
with lifetimes greater than or equal to the baseline lifetime. Both
representative lamp units that DOE analyzed at EL 1 have lifetimes
longer than the baseline. The characteristics of the representative
lamp units were used as inputs to the LCC analysis. The LCC analysis
assumes that the analysis period is the lifetime of the baseline lamp.
Any lamps at higher efficacy levels that have longer lifetimes than
that of the baseline product incorporate a residual value into the
life-cycle cost, which subtracts the value of the lamp at the end of
the analysis period from the total life-cycle cost. Thus, the residual
values of the longer lifetime lamps increase the LCC savings.
NEMA commented that the increased efficacy of the EL 1 proposed in
the NOPR would result in a 30 percent reduction in lifetime,\61\
meaning a total loss of financial feasibility as the payback period
would be longer than the lifetime of the more efficacious lamps. (NEMA,
No. 54 at p. 29)
---------------------------------------------------------------------------
\61\ NEMA cited the following reference for this calculation:
Vukcevich, Milan R. The Science of Incandescence. NELA Press, 1992.
---------------------------------------------------------------------------
DOE recognizes that there is an inverse relationship between
efficacy and lifetime for IRLs. The engineering analysis focuses on
commercially available products and DOE does not analyze efficacy
levels that require shorter lifetimes than the baseline product.
However, DOE is aware that to meet higher efficacy levels,
manufacturers can choose to produce lamps with shorter lifetimes than
the baseline lamp to achieve higher efficacies. Given that
manufacturers responded to the July 2012 standards by introducing IRLs
with shorter lifetimes, DOE understands this is a likely path
manufacturers may take in response to higher standards. To capture the
impacts of the relationship between lifetime and efficacy in IRLs, DOE
determined how much the lifetime of a lamp with the same wattage as the
baseline lamp must be shortened to achieve each efficacy level in the
final rule analysis. (See chapter 5 of the final rule TSD for further
information.) The impact of these shortened lifetime lamps are assessed
as sensitivities in the LCC, NIA, and MIA. (See respectively, appendix
8B, chapter 12, and appendix 13B of the final rule TSD). For the
shortened lifetime sensitivity, because the wattage is the same as the
baseline, there are no energy savings and therefore, the LCC savings
are negative and a payback period cannot be calculated.
H. Consumer Subgroup Analysis
In analyzing the potential impact of new or amended standards on
consumers, DOE evaluates the impact on identifiable subgroups of
consumers (e.g., low-income households) that a national standard may
disproportionately affect. In the NOPR analysis, DOE evaluated low-
income consumers and institutions that serve low-income populations
(e.g., small nonprofits) as subgroups. DOE did not receive any comments
regarding subgroups and therefore maintained this approach for
assessing consumer subgroups in the final rule analysis. Chapter 9 of
the final rule TSD presents the results of the consumer subgroup
analysis.
I. Shipments Analysis
DOE uses projections of product shipments to calculate the national
impacts of standards on energy use, NPV, and future manufacturer cash
flows. DOE develops shipment projections based on historical data and
an analysis of key market drivers for each product. Historical
shipments data are used to build up a product stock and also to
calibrate the shipments model. The details of the shipments model are
described in chapter 11 of the final rule TSD.
The shipments model projects shipments of GSFLs and IRLs over a 30-
year analysis period for the base case (no standards) and for all
standards cases. Separate shipments projections are calculated for the
residential sector and for the commercial and industrial sectors. The
shipments model used to estimate GSFL and IRL lamp shipments for this
rulemaking has four main interacting elements: (1) A lamp demand module
that estimates the demand for GSFL and IRL lighting for each year of
the analysis period; (2) a price-learning module, which projects future
prices based on historic price trends; (3) substitution matrices, which
specify the product choices available to consumers (lamps as well as
lamp-and-ballast combinations for fluorescent lamps) depending on
whether they are renovating lighting systems, installing lighting
systems in new construction, or simply replacing lamps; and (4) a
market-share module that assigns shipments to product classes,
ballasts, and lamp options, based on consumer sensitivities to first
costs (prices) and operation and maintenance costs.
The lamp demand module first estimates the lumen demand for GSFL
and IRL lighting. The lumen demand calculation assumes that sector-
specific lighting capacity (maximum lumen output of installed lamps)
remains fixed per square foot of floor space over the analysis period.
Floor space changes over the analysis period according to the EIA's AEO
2014 projections of residential and commercial floor space; industrial
floor space is assumed to grow at the same rate as commercial floor
space. A lamp turnover calculation estimates shipments of lamps in each
year given the initial stock, the expected lifetimes of the lamps (and
ballasts for GSFLs), and sector-specific assumptions on operating
hours. The turnover model attempts to meet the lumen demand as closely
as possible, subject to the constraint that the areal density of
lighting fixtures is fixed for existing buildings that are not
renovated.
The lamp demand module accounts for the penetration of LED lighting
into the GSFL and IRL markets. The reference assumption for LED market
penetration is based on projections developed for DOE's Solid-State
Lighting (SSL) Program.\62\ The SSL Program projections extend only to
2030; DOE extrapolated to the end of the shipments forecast period. DOE
fitted the technology adoption curve to allow for an entire market
takeover by LEDs. Given the best fit to the SSL forecast, DOE estimates
that LEDs will achieve close to 100 percent penetration in both the
GSFL and IRL markets by 2046.
---------------------------------------------------------------------------
\62\ Navigant Consulting, Inc. Energy Savings Potential of
Solid-State Lighting in General Illumination Applications. U.S. DOE
Solid State Lighting Program, January 2012. Available at http://apps1.eere.energy.gov/buildings/publications/pdfs/ssl/ssl_energy-savings-report_jan-2012.pdf.
---------------------------------------------------------------------------
The shipments model accounts for the use of lighting controls,
including dimming and on-off controls, because controls affect ballast
and lamp requirements and, therefore, lifetimes and shipments. The
reference assumption for lighting system controls for the commercial
sector is that state building energy code requirements for lighting
controls remain constant at current levels, as does the ratio of
voluntary to code-driven demand. Because code provisions are
implemented only in new construction and building renovations that meet
certain threshold requirements, code-driven implementation of lighting
controls grows in slowly over time.
The price-learning module estimates lamp and ballast prices in each
year of the analysis period using a standard price-learning model.\63\
The model is
[[Page 4090]]
calibrated using three decades of historic data on the volume and value
of fluorescent and PAR lamp shipments in the U.S. market, from which
cumulative shipments and average prices are derived. Prices and
cumulative shipments are fit to an experience curve. They are then
augmented in each subsequent year of the analysis based on the
shipments determined for the prior year by the module that assigns
shipments to product classes and ELs. The current year's shipments, in
turn, affect the subsequent year's prices. As shown in chapter 11 of
the final rule TSD, because fluorescent and PAR lamps have been on the
market for decades, cumulative shipments are changing slowly.
Therefore, experience curve effects are relatively small--an effect
that is further constrained by the expected incursion of solid-state
lighting into the GSFL and IRL markets.
---------------------------------------------------------------------------
\63\ For discussion of approaches for incorporating learning in
regulatory analysis, see Taylor, Margaret, and Sydny K. Fujita.
Accounting for Technological Change in Regulatory Impact Analyses:
The Learning Curve Technique. Berkeley: Lawrence Berkeley National
Laboratory, 2013. LBNL-6195E.
---------------------------------------------------------------------------
The market-share module apportions the lamp and ballast shipments
in each year among the different product classes, ballast types, and
lamp options based on consumer sensitivities to first costs and
operation and maintenance costs. To determine the prices used as inputs
to the market-share module, DOE uses the ballast prices, weighted-
average lamp prices, and installation costs developed in the
engineering and LCC analyses. The operation and maintenance costs are
based on the power required to operate a particular lamp-and-ballast
system, the price of electricity, and the annualized cost of lamp
replacements over the lifetime of that system. To enable a fair
comparison between systems with different light output, the module
considers the prices and operating and maintenance costs computed per
kilolumen of light output. For consumers replacing lamps on existing
ballasts, only the lamp-related prices and energy costs are considered
by the market-share module. For consumers replacing an entire lamp-and-
ballast system, the full price of the system, as well as the energy and
annualized relamping costs, are considered.
The ballast types and lamp options considered in the shipments
model were determined in the engineering analysis. Whereas the earlier
analyses considered only lamp-and-ballast combinations that did not
increase energy relative to the baseline system, the shipments analysis
allows consumers to choose among different lamp-and-ballast systems.
These lamp-and-ballast combinations include full wattage and reduced
wattage lamps coupled to ballasts with high, normal, or low ballast
factors, and dimming ballasts. Programmed start and instant start
ballasts are also considered separately, where appropriate. DOE limits
or excludes lamp-and-ballast combinations that DOE's research indicates
would not provide acceptable performance or would only do so in limited
circumstances. The remaining combinations allow for a variety of
different energy-saving and non-energy-saving options relative to the
baseline. Details of the selection of allowable lamp-and-ballast
combinations are given in chapter 11 of the final rule TSD.
The market-share module allows for the possibility that consumers
will switch among the different product classes, ballast types, and
lamp options over time. Substitution matrices were developed to specify
the product choices available to consumers (lamps as well as lamp-and-
ballast combinations), depending on whether they are retrofitting
lighting systems, renovating the lighted space, installing lighting
systems in new construction, or simply replacing lamps, and depending
on the particular lighting application. In this way, the module assigns
market shares to the different product classes, ballast types, and ELs
based on historical observations of consumer sensitivity to price and
to operating and maintenance costs.
DOE projects that some fraction of the lighting market currently
being served by T8 lamps will migrate to T5 lamps in the absence of
standards. At the NOPR stage, DOE projected that the standards in this
rulemaking would make certain T5 systems more cost competitive relative
to certain T8 systems, resulting in an increase in the rate of this T8
to T5 lamp migration. DOE received comments regarding product class
switching between T8 lamps and T5 lamps. Philips, NEMA, and GE
commented that consumers will not switch from T8 lamps to T5 lamps.
Philips and NEMA stated that T5s have been on the market for 20 years
and have not been used as substitutes for T8s. NEMA and GE mentioned
that T5 lamps are shorter than T8 lamps; therefore, T5 lamps cannot be
used to retrofit T8 fixtures and vice versa. Philips, NEMA, and GE also
noted that T5 and T8 lamps are used in different applications. Because
T5 lamps have higher luminance than T8 lamps, T5 lamps are typically
used in indirect fixtures or places with high ceiling heights, whereas
T8 lamps are used in direct fixtures or places with lower ceiling
heights. Hence Philips, NEMA, and GE stated that these lamps cannot be
used interchangeably. (Philips, Public Meeting Transcript, No. 49 at p.
163-164; GE, Public Meeting Transcript, No. 49 at p. 163, p. 167-168;
NEMA, No. 54 at p. 14, p. 46)
DOE is aware that there are physical and optical differences
between T8 and T5 lamps. DOE assumes in its modeling for this
rulemaking that switching between T8 and T5 lamps does not occur during
retrofits. The potential for substitution of 4-foot MBP and 8-foot
slimline with T5 SO Lamps is only assumed at the time of new
construction and renovation, when a new luminaire would be specified.
DOE's analysis indicates that there exist T5 luminaires that compete
directly with 4-foot MBP T8 luminaires in most applications in the
largest luminaire markets (e.g., commercial offices, education,
industrial). In some cases, luminaire manufacturers offer essentially
identical luminaires in 4-foot T8 and T5 versions. Therefore, DOE
believes that the switching from T8s to T5s estimated in the NOPR, and
in the final rule, is reasonable. See appendix 11C of the final rule
TSD for examples of these luminaires and a discussion of DOE's analysis
of the substitution potential for 4-foot MBP and T5 SO Lamps.
NEMA noted that first cost is a significant driver of consumers'
choice of product class and, as a consequence, higher initial T8 lamp
costs would drive consumers to T5 products or LED products in new
construction and renovation projects. (NEMA, No. 54 at p. 46) This
comment is consistent with DOE's assumptions in the analysis for this
rulemaking.
NEMA noted that, even if the standards required the 4-foot MBP T8
to increase phosphor use, T5 lamps would remain more expensive than T8
lamps owing to differences in manufacturing technology. (NEMA, No. 54
at p. 34) DOE determined the end-user prices of lamps by applying a
shipment-weighted discount to the blue book price of the lamp. In
certain cases the end-user prices for 4-foot MBP T8 lamps are higher
than for T5 MiniBP SO lamps (see chapter 7 of the final rule TSD). At
max tech, the full-wattage 4-foot MBP T8 lamp end-user prices are
higher than the full wattage T5 MiniBP SO.
NEMA also commented that T5 lamp sales are not from T8 consumers
but are mainly from consumers switching from older inefficient
technology, like HID lamps. However, NEMA added that this rulemaking
would slow down the transition from HID products to T5 lamps. (NEMA,
No. 54 at p. 47)
In its assessment of the market, DOE did not find any T5 HO lamps
at the baseline efficacy level considered here.
[[Page 4091]]
Thus, the amended standard represents the least efficacious T5 HO lamps
on the market. For this reason DOE believes that this standard will
have no impact on the transition from HID to T5 technology.
NEMA noted that the inability of non-PAR38 lamps to meet the
proposed standard would cause consumers to switch to either expensive
LED lamps or BR lamps that consume more energy than PAR lamps. NEMA
calculated that the overall energy savings could be negative. (NEMA,
No. 54 at pp. 20, 29) NEMA stated that significant energy savings would
be lost under the proposed standards due to forcing halogen PAR30 lamp
consumers to switch to LED lamps, the reduced wattage 39W PAR30 lamps,
or 65W BR30 lamps after PAR30 lamps are eliminated from the market.
NEMA and GE predicted that the majority of consumers would switch to
the BR30 lamps, which would cause an increase of 97 kWh per year, an
inadvertent increase of 0.03 quads of energy. NEMA stated that, given
the popularity of these IRLs and the alternative lamps once they are
eliminated, no new standard should be set for PAR30 lamps. (NEMA, No.
54 at pp. 48-49; GE, Public Meeting Transcript, No. 49 at pp. 121-122)
ASAP noted that there are substitute lamps outside of the scope of this
rulemaking and that DOE needed to consider what consumer choices could
be made among the unregulated product options. (ASAP, Public Meeting
Transcript, No. 49 at pp. 114-115) GE disagreed and stated that
consumers purchase quite a number of regulated products, such as PAR20,
PAR30, and 90W PAR38 lamps. (GE, Public Meeting Transcript, No. 49 at
pp. 115-116)
DOE's analysis indicates that there are PAR30 and PAR20 products on
the market that meet EL 1. DOE recognizes that BR lamps are potential
substitutes for non-PAR38 IRLs. However, given the large price
difference between PAR and BR lamps in the current market, DOE believes
that all consumers currently using PAR lamps are obtaining a unique
utility from the PAR lamps for which they are willing to pay a
substantial price premium. Thus, DOE believes that all potential
switching from PAR to BR lamps has already taken place. DOE accounts
for some consumers shifting to LED lamps with the use of an LED market
adoption curve.
The market-share module incorporates a limit on the diffusion of
new technology into the market using the widely accepted Bass adoption
model,\64\ the parameters of which are based on historic penetration
rates of new lighting technologies into the market. It also accounts
for other observed deviations from purely price- and cost-driven
behavior using an acceptance factor, which sets an upper limit on the
market share of certain product classes and lamp options that DOE
research indicates are acceptable only to a subset of the market. The
available options depend on the case under consideration; in each of
the standards cases corresponding to the different TSLs, only those
lamp options at or above the particular standard level in each product
class are considered to be available.
---------------------------------------------------------------------------
\64\ Bass, F.M. A New Product Growth Model for Consumer
Durables. Management. 1969. 15(5): pp. 215-227.
---------------------------------------------------------------------------
Because DOE executes the market-share module for the base case and
each of the standards cases independently, the shipments analysis
allows for the possibility that setting a standard on one product class
could shift market share toward a different product class. The costs
and benefits accruing to consumers from such market share shifts are
fully accounted for in the NIA.
When the shipments model selects lamps for replacement, retrofit,
renovation, or new construction, it accepts only lamps or lamp-and-
ballast combinations that retain lumen capacity within acceptable
bounds.
As discussed previously, based on manufacturer feedback, DOE
determined that consumers would not notice a change in light output
that is up to 10 percent, and that some consumers will choose to reduce
light levels beyond 10 percent to conserve energy. Accordingly, in the
shipments analysis, DOE assumes that consumers choose between lighting
systems within 10 percent of current light output by considering the
trade-off between first cost and operating costs, and not the relative
light output. In this approach, systems that save energy in a cost-
effective way will tend to be selected over systems that increase light
output without saving energy. DOE further assumes that the fraction of
the market that will accept larger reductions in lumen output is fixed
throughout the analysis period. The size of this market segment was
estimated from the current market share of reduced wattage lamps that
reduce light levels by more than 10 percent compared to the baseline
lamp. The model does not allow cumulative reductions in light levels.
The model retains national average light levels within 10 percent of
the average level at the beginning of the analysis period. No potential
standards considered in this analysis lead to average light levels
outside of this range.
DOE is aware of the substantial impact of the ballast and lamp
choice on the energy consumption of a lamp-and-ballast system. As
discussed earlier in this section, the shipments analysis explicitly
models the possibility that consumers will choose to reduce their
ballast factor during a renovation or retrofit or switch to reduced
wattage lamps when relamping an existing system. In addition, this
analysis models the growth of dimming ballasts in the market and allows
a variety of lamps to be coupled to dimming ballasts to achieve a fixed
light output. Thus, when high-efficacy lamps are coupled to dimming
ballasts, the overall energy savings are greater than those that are
achieved when lower efficacy lamps are coupled to dimming ballasts. DOE
assigns market share to these lamp-and-ballast pairings using a model
based on historical consumer sensitivity to price and operating costs.
When a particular pairing saves energy in a cost-effective manner
compared to other pairings, its market share is increased compared to
less cost-effective options. As in the NOPR analysis, DOE did not
consider delamping in this final rule because manufacturer feedback
confirmed that delamping is not common practice when retrofitting
existing T8 systems as lumen output levels have already been reduced to
comply with newer recommended lighting levels and building codes. The
shipments model, however, allows for the possibility that consumers
will alter the number of lamps per square foot during renovations to
maintain light levels.
NEMA noted that future installations or retrofits would not
adequately ``tune'' lamp and ballast pairings, by manipulating the
ballast factor, especially during the maintenance phase of system
lifetime when lamps and ballasts get replaced on a case-by-case basis.
Furthermore, without this ballast tuning, consumers would have
increased light density with the same energy consumption as the
previous lamp-and-ballast system had. (NEMA, No. 54 at pp. 18 and 36)
DOE is aware that the ballast factor is not typically modified
during the maintenance phase of a lamp-ballast system. DOE assumes in
its modeling for this rulemaking that any tuning of the ballast and
lamp pairing does not occur during the maintenance phase. Adequate
tuning is only assumed at the time of new construction, renovation, and
retrofitting.
GE and NEMA disagreed with the assumption that ballast factors can
be
[[Page 4092]]
tuned to maintain the same light output. They both stated that ballast
factors are only available in 10 percent increments while the resulting
increase in efficacy is only about 2-3 percent. They commented that
consumers will keep the same ballast factor for retrofits, which means
that the lamps will still consume the same amount of energy but will be
giving 2-3 percent more lumen output. (GE, Public Meeting Transcript,
No. 49 at p.196-198; NEMA, No. 54 at p. 18)
DOE is aware that ballast factors tend to cluster around modal
values that are separated by roughly 10 percent. However, in analyzing
the market, DOE identified ballasts with a broad range of ballast
factors that were not restricted to these modal values. Moreover, DOE
notes that the increase in lumen output from the baseline to the full-
wattage EL 2 lamp is 7 percent for 4-ft MBP lamps, and 16 percent for
T5 SO lamps. DOE believes that, for consumers undertaking renovations,
lighting retrofits, and new construction, the selection of ballast
factor will be informed by the lamps available on the market and that
an increased fraction of consumers will choose lower ballast factors
than are now typical if typical lamp lumen ratings increase.
DOE notes that full wattage lamp options are available for all
product classes at all efficacy levels considered in this analysis.
DOE's research indicates that krypton gas is generally used to reduce
the wattage of lamps and that full wattage lamps can generally be
dimmed reliably. Also, as discussed previously, DOE found that dimming
ballasts for 4-foot MBP lamps are commonly marketed as compatible with
reduced wattage lamps, which are presumably krypton filled.
Accordingly, in the shipments analysis and the NIA, DOE allows all full
wattage lamp options to be coupled to dimming ballasts. DOE also
allowed reduced wattage options in the 4-foot MBP category to be
coupled to dimming ballasts, but, because the range of applications for
this combination is restricted, DOE limits its market share in the
analysis.
NEMA provided their Ballast Section market survey data, indicating
that dimming ballast sales decreased between 2010 and 2013. NEMA
acknowledged that CA Title 24 and ASHRAE 90.1 may increase these
shipments, but stated that the increase in shipments could not be
properly estimated at this time due to their recent or sporadic
adoption. NEMA noted that the last rulemaking constrained this
decreasing market. (NEMA, No. 54 at p. 33, p. 35, p. 47)
DOE thanks NEMA for the input on dimming ballast shipments. DOE
believes that, given the many recently updated commercial building
codes that require lighting controls, the market share of dimming
ballasts is very likely to increase in the future and that the recent
decline is likely transitory. Therefore, DOE has modeled the fraction
of commercial floorspace that is subject to such codes and utilizes
this in its analysis to estimate the future market share of dimming
ballasts, based on current usage of dimming in fluorescent lighting
systems.
Rare earth oxides (REOs) are used in GSFL phosphors to increase
their efficacy. The shipments model considers the potential impact of
changes in rare earth oxide prices on fluorescent lamp prices and,
thereby, on GSFL shipments. Large increases in rare earth oxide prices
in 2010 and 2011 raised manufacturer concerns that future price
increases could have adverse impacts on the market. DOE developed
shipments scenarios in its NOPR to reflect uncertainties in the prices
of rare earth oxides.
NEMA noted that the prices during the last REO crisis increased by
400 to 700 percent. Due to decreased REO prices and subsequent slowing
of REO supply expansion, NEMA mentioned the possibility of another
price increase as future supplies are uncertain. Therefore, NEMA
suggested that DOE revise the estimates of the high end of possible
prices to 700 percent of current prices. (NEMA, No. 54 at p. 34-35)
DOE has examined the rare earth oxide market and still considers
future rare earth prices significantly uncertain. DOE considered two
price scenarios in its shipments modeling for GSFLs, as described in
appendix 11B of the final rule TSD. The reference scenario assumes that
rare earth prices remain fixed at their June 2014 level. The high rare
earth price scenario assumes an average rare earth price 4.5 times the
reference level, representing a value that is half way between the low
pre-2010 baseline price and the 2011 peak price. This scenario
represents the average price of regular price fluctuations between the
peak and baseline amounts. DOE notes that the high rare earth price
scenario represents a high price volatility scenario where the price
could fluctuate at higher or lower levels than 4.5 times the baseline
rare earth price.
J. National Impact Analysis--National Energy Savings and Net Present
Value Analysis
The NIA assesses the NES and the national NPV of total consumer
costs and savings expected to result from amended standards for GSFLs
and IRLs at specific efficacy levels. Analyzing impacts of potential
energy conservation standards for GSFLs and IRLs requires comparing
projections of total energy consumption with amended energy
conservation standards to projections of energy consumption without the
standards (the base case).
As the shipments model allows for substitutions across product
classes when lighting systems are selected during renovation or new
construction, understanding the impact of setting a standard at any
given level for any given product class requires considering the impact
on all other product classes. Therefore, in addition to conducting the
analysis for the covered products as a whole, DOE evaluated the NPV and
NES by product class to determine the impact of consumer switching
between product classes. The NIA was developed in a Microsoft Excel
spreadsheet,\65\ allowing access to a broad range of scenario
assumptions for conducting sensitivity analyses on specific input
values. The major inputs for the NIA are described in Table VI.10.
---------------------------------------------------------------------------
\65\ Available at www1.eere.energy.gov/buildings/appliance_standards/rulemaking.aspx/ruleid/24.
Table VI.10--Inputs for the National Impact Analysis
------------------------------------------------------------------------
Input Description
------------------------------------------------------------------------
Shipments......................... Annual shipments from shipments
model.
Compliance date of standard....... January 1, 2018.
Base case efficiencies............ Estimated by market-share module of
shipments model.
Standards case efficiencies....... Estimated by market-share module of
shipments model.
Annual energy consumption per unit Calculated for each efficacy level
and product class based on inputs
from the energy use analysis.
[[Page 4093]]
Total installed cost per unit..... Lamp prices by efficacy level,
ballast prices by ballast type, and
lamp and ballast installation
costs. The weighted-average prices
and installation costs developed in
the engineering analysis and LCC
analysis were used.
Electricity expense per unit...... Annual energy use for each product
class is multiplied by the
corresponding average energy price.
Escalation of electricity prices.. AEO 2014 forecasts (to 2040) and
extrapolation beyond 2040.
Electricity site-to-primary energy A time series conversion factor;
conversion. includes electric generation,
transmission, and distribution
losses.
Discount rates.................... 3% and 7% real.
Present year...................... 2014.
------------------------------------------------------------------------
1. National Energy Savings
The inputs for determining the NES for each product class are: (1)
Lamp shipments; (2) annual energy consumption per unit; (3) installed
stocks of lamps (coupled to each analyzed ballast type for GSFLs) in
each year; and (4) site-to-primary energy and FFC conversion factors.
The lamp stocks were calculated by the shipments model for each year of
the analysis period from the prior year's stock, minus retirements,
plus new shipments, accounting for lamp and ballast lifetimes. DOE
calculated the national electricity consumption in each year by
multiplying the number of units of each product class and EL in the
stock by each unit's power consumption and operating hours. The power
consumption is determined by the lamp wattage and, for each GSFL, by
the ballast type to which each lamp is coupled. The operating hours are
estimated by taking a weighted average of the distributions developed
in the LCC analysis. The electricity savings are estimated from the
difference in national electricity consumption by GSFLs between the
base case (without new standards) and each of the standards cases for
lamps shipped during the 2018-2047 period.
DOE accounted for the impact of lighting system controls on
lighting energy use as well as on lamp shipments, as discussed in the
previous section. DOE understands that many lighting control systems
may not achieve the savings for which they were designed. Accordingly,
the estimated average energy reduction from controls is based on a
meta-analysis of studies on the performance of actual lighting controls
systems in the field.\66\
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\66\ Williams, A., B. Atkinson, K. Garbesi, E. Page, and F.
Rubinstein (2012). Lighting controls in commercial buildings. Leukos
8(3): 161-180. www.ies.org/leukos/samples/1_Jan12.pdf.
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NEMA requested clarification on DOE's assumption that no individual
reduced wattage lamp option will be coupled to more than 10 percent of
the dimming ballasts in the installed stock, owing to performance
problems that may arise in some applications. (NEMA, No. 54 at p. 33)
NEMA further commented that DOE cannot assume energy savings from
pairing 28W energy-saver lamps with dimming ballasts, as DOE cannot
presume that consumers will tolerate not having full dimming
functionality with these lamps. NEMA specified that DOE must remove all
energy savings estimated to result from the energy-saver lamps in this
scenario and instead assume full-wattage lamps would be installed.
(NEMA, No. 54 at p. 36)
In its assessment of the market, DOE noted the presence of T8
dimming ballasts whose marketing materials indicated compatibility with
reduced wattage lamps. Therefore, DOE believes that at least some
consumers with dimming ballasts would consider coupling them to such
lamps. DOE is aware, however, that in some cases significant
performance degradation is possible when coupling reduced wattage lamps
to dimming ballasts. Therefore, DOE assumed that only a small fraction
of consumers with dimming ballasts would consider purchasing reduced
wattage lamps to install on their ballasts. Specifically, DOE took this
fraction to be 10 percent of consumers who have dimming ballasts. This
represents the fraction of consumers who would consider such a lamp-
ballast combination among the set of plausible options; not all such
consumers will in fact decide to purchase reduced wattage lamps. Thus,
the fraction of dimming ballasts that are coupled to reduced wattage
lamps remains exceedingly small in DOE's projections throughout the
analysis period.
NEMA commented that, although 4-foot T8 argon lamps can have
efficacies of 89, 90, 91, or 92.4 lumens per watt, at different
efficacies these lamps will still operate at the same wattages, and
instead they would just provide different illumination. Therefore, NEMA
stated that there is no meaningful difference in national energy use
impact from choosing any of these three levels above 89 lm/W.
Furthermore, NEMA added that an energy conservation standard for 4-foot
MBP GSFLs at 89 lm/W will maintain consumer utility as well as increase
national energy savings by increasing use of dimming systems. (NEMA,
No. 54 at p. 14)
DOE does not agree that lamps at different efficacies will still
operate at the same wattages. DOE considers two modes by which energy
savings can be achieved with full-wattage lamps. First, when using more
efficacious lamps, consumers with dimming ballasts may dim their
systems to a lower input wattage to achieve the same light output.
Second, consumers undertaking renovations, lighting retrofits, and new
construction may select lower ballast factors on average if only high-
efficacy lamps are available on the market. Regarding NEMA's claim that
a standard at 89 lm/W will increase national energy savings by
maintaining utility and increasing use of dimming systems, DOE has
ensured that, at all ELs considered for 4-foot MBP lamps, lamp options
are available that can be coupled to dimming systems. Therefore DOE
does not believe that this final rule will negatively impact the energy
savings that is available from dimming.
DOE accounts for the direct rebound effect in its NES analysis.
Direct rebound reflects the idea that, as appliances become more
efficient, consumers use more of their service because their operating
cost is reduced. In the case of lighting, the rebound could be
manifested in increased hours of use or in increased lighting density
(fixtures per square foot). Based on information evaluated for the
preliminary analysis, DOE assumed no rebound for the residential or
commercial lighting in its reference scenario for the final rule
analysis.
NEMA commented that, if light levels are reduced through energy-
saver lamps or lower ballast factor ballasts, end users
[[Page 4094]]
could offset the reduction in light levels by increasing the GSFL use
or through other technologies, thereby reducing the energy-saving
benefit. NEMA referenced an article and a report that they believe
support their point of view. (NEMA, No. 54 at p. 36) Additionally,
Miller commented that DOE should evaluate whether there was a
measurable rebound effect resulting from use of more energy-efficient
lamps. (Miller, No. 50 at p. 12)
DOE is not aware of any methodologically sound studies that have
quantified a direct rebound effect for lighting efficacy improvement in
commercial buildings, where most GSFLs are used. As discussed in
chapter 12 of the final rule TSD, DOE did not find evidence of
systematic increases in operating hours or lighting density of GSFLs or
IRLs with increased efficacy of these products. The items mentioned by
NEMA refer to the potential for higher lighting demand when consumers
start using LEDs. DOE believes that adoption of LEDs would not be
impacted by the standards in this notice, so any rebound effect
associated with this lighting technology is not germane. Based on the
weight of the evidence, DOE assumed zero rebound for GSFLs or IRLs with
increased efficacy. DOE also conducted a sensitivity analysis assuming
a high rebound rate of 15 percent, which is presented in chapter 12 of
the final rule TSD. Using a high rebound rate does not change the
relative ranking of the considered TSLs.
DOE converted the site electricity consumption and savings to
primary energy (power sector energy consumption) using annual
conversion factors derived from the AEO 2014 version of NEMS.
Cumulative energy savings are the sum of the NES for each year in which
product shipped during 2018 through 2047 continue to operate.
DOE has historically presented NES in terms of primary energy
savings. In 2011, response to the recommendations of a committee on
``Point-of-Use and Full-Fuel-Cycle Measurement Approaches to Energy
Efficiency Standards'' appointed by the National Academy of Science,
DOE announced its intention to use FFC measures of energy use and
emissions in the NIA and emissions analysis included in future energy
conservation standards rulemakings. 76 FR 51281 (August 18, 2011).
After evaluating the approaches discussed in the August 18, 2011
notice, DOE published a statement of amended policy in the Federal
Register in which DOE explained its determination that NEMS is the most
appropriate tool for its FFC analysis and its intention to use NEMS for
that purpose. 77 FR 49701 (August 17, 2012). Therefore DOE is using a
NEMS-based approach to conduct FFC analyses for this rule. This
approach is further described in appendix 12C of the final rule TSD.
GE and NEMA stated that there are no energy savings from switching
from T8 lamps to T5 lamps. GE mentioned that, although the efficacies
of T5 lamps are measured at high frequency and T8 lamps are measured at
low frequency, the lamps have similar efficacies. (GE, Public Meeting
Transcript, No. 49 at p. 163) NEMA commented that the efficiencies of
T8 and T5 lamps are not directly comparable, because the efficiencies
are measured differently. (NEMA, No. 54 at p. 14, p. 46) NEMA further
added that the T5 lamp-ballast systems have the same power consumption
as the equivalent T8 lamp-ballast systems. (GE, Public Meeting
Transcript, No. 49 at p. 163; NEMA, No. 54 at p. 46)
DOE does not assume an automatic energy savings from switching from
a T8 system to a T5 system. The energy use of a lamp-and-ballast system
is calculated using the wattage of the installed lamps as well as the
ballast factor and ballast luminous efficacy of the ballast on which
the lamps are installed. DOE notes that, while it does not assume
automatic energy savings of a T5 system compared to a T8 system, there
are T5 lamp-and-ballast combinations (e.g., low ballast factor ballast
coupled with high efficacy lamps) that can have lower power consumption
compared to a T8 system of similar light output. Further, DOE agrees
that testing on high frequency circuits versus low frequency circuits
impacts efficacy measurements. Per DOE test procedure, GSFLs are tested
at low frequency unless only high frequency reference ballast
specifications are available. The T5 MiniBP SO and HO lamps and 8-foot
RDC HO should be tested on high frequency circuits, as those are the
only specifications provided for these lamp types. The 4-foot MBP, 2-
foot U-shaped and 8-foot SP slimline lamps should be tested on low
frequency circuits. Therefore, within each product class, the lamp
efficacies should be comparable, however, efficacies of lamps across
product classes may not be comparable.
NEMA noted that PAR38 lamps that currently meet the proposed
standard are not available through consumer channels and consumers
would lose all reasonable options for PAR lamps. (NEMA, No. 54 at pp.
10) DOE understands that the availability of certain PAR lamps may be
concentrated in the commercial sector. However, DOE does not find that
to be a barrier to such lamps becoming available and used in other
sectors of the market.
NEMA noted that setting new standards for 130 V IRLs would be a
waste of resources and would skew energy savings estimates, as the
product is no longer available. (NEMA, No. 54 at p. 54) DOE assumes in
its analysis that there are no 130 V IRLs on the market. No energy
savings from such products are assumed.
2. Net Present Value of Consumer Benefit
The inputs for determining the NPV of the total costs and benefits
experienced by consumers of the considered product are: (1) Total
annual installed cost; (2) total annual savings in operating costs; and
(3) a discount factor to calculate the present value of costs and
savings. DOE calculated net savings each year as the difference between
the base case and each standards case in terms of total savings in
operating costs versus total increases in installed costs. DOE
calculated savings over the lifetime of products shipped during in the
2018-2047 period. The NPV was calculated as the difference between the
present value of operating cost savings and the present value of total
installed costs.
a. Total Annual Installed Cost
The total installed cost includes both the product price and the
installation cost. For each product class, DOE utilized weighted-
average prices for each of the lamp-and-ballast options, as well as
installation costs, as developed in the engineering and LCC analyses.
DOE calculated the total installed cost for each lamp-and-ballast
option and determined annual total installed costs based on the annual
shipments of lamps and ballasts determined in the shipments model. As
noted in section VI.I, DOE assumed that GSFL and IRL prices decline
slowly over the analysis period according to a learning rate developed
from historical data.
As discussed in section VI.I, DOE considered two price scenarios in
its modeling for GSFLs. The reference scenario assumes that rare earth
prices remain fixed at their June 2014 level. The high rare earth price
scenario assumes that rare earth prices are 4.5 times higher than the
reference level, representing a value at the midpoint of the low pre-
2010 baseline price and the peak 2011 price. The impact of the latter
scenario on the NPV results is discussed in section VII.B.3.c.
NEEP expressed support for DOE's REO pricing analysis (NEEP, No. 57
at p. 3), but NEMA stated that DOE does not include an analysis of
price
[[Page 4095]]
elasticity and consumer buying practices during previous REO shortages.
NEMA also noted that the proposed standards would create an REO
shortage. (NEMA, No. 54 at p. 34; Public Meeting Transcript, No. 49 at
pp. 180-182)
DOE estimates that, for the amended standards, the annual increase
in demand for REOs will be approximately 300 tons per year in the first
5 years, which amounts to less than 1 percent of the annual 8,000-ton
global demand for REOs used in phosphors. DOE expects that demand will
steadily decrease over the analysis period owing to the increasing LED
market. Therefore, DOE does not believe that the amended standards will
cause a significant change in the supply of REOs.
For IRLs, DOE conducted a sensitivity analysis on the potential
impact on the rulemaking of a 10-fold increase in xenon prices. The
impact of the scenario on the results is discussed in section
VII.B.3.c.
b. Total Annual Operating Cost Savings
The per-unit energy savings were derived as described in section
III.C. To calculate future electricity prices, DOE applied the
projected trend in national average commercial and residential
electricity prices from the AEO 2014 Reference case, which extends to
2040, to the energy prices derived in the LCC and PBP analysis. DOE
used the trend from 2030 to 2040 to extrapolate beyond 2040. In
addition, DOE analyzed scenarios that used the trends in the AEO 2014
Low Economic Growth and High Economic Growth cases. These cases have
energy price trends that are, respectively, lower and higher in the
long term compared to the Reference case. These price trends, and the
NPV results from the associated cases, are described in chapter 12 of
the final rule TSD.
DOE estimated that annual maintenance costs do not vary with
efficacy within each product class, so they do not figure into the
annual operating cost savings for a given standards case. DOE utilized
the lamp disposal costs developed in the LCC analysis, along with the
shipments model forecast of the lamp retirements in each year, to
estimate the annual cost savings related to lamp disposal costs from
extended lamp lifetime. In the NIA, DOE assumes that 30 percent of
commercial consumers are subject to disposal costs.
In calculating the NPV, DOE multiplies the net savings in future
years by a discount factor to determine their present value. In
accordance with OMB's guidelines on regulatory analysis,\67\ DOE
calculated the NPV using both a 7-percent and a 3-percent real discount
rate. The 7-percent rate is an estimate of the average before-tax rate
of return on private capital in the U.S. economy; it reflects the
returns on real estate and small business capital as well as corporate
capital. This discount rate approximates the opportunity cost of
capital in the private sector. The 3-percent rate reflects the
potential effects of standards on private consumption (e.g., through
higher prices for product and reduced purchases of energy). This rate
represents the rate at which society discounts future consumption flows
to their present value. It can be approximated by the real rate of
return on long-term government debt (i.e., yield on U.S. Treasury
notes), which has averaged about 3 percent for the past 30 years.
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\67\ OMB Circular A-4, section E (Sept. 17, 2003). Available at:
www.whitehouse.gov/omb/circulars_a004_a-4.
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K. Manufacturer Impact Analysis
DOE conducted separate MIAs for GSFLs and IRLs to estimate the
financial impact of potential amended energy conservation standards on
manufacturers of GSFLs and IRLs, respectively. The MIA has both
quantitative and qualitative aspects. The quantitative part of the MIA
relies on the GRIM, an industry cash-flow model customized for GSFLs
and IRLs covered in this rulemaking. The key GRIM inputs are data on
the industry cost structure, product costs, shipments, and assumptions
about markups and conversion costs. The key MIA output is INPV. DOE
used the GRIM to calculate cash flows using standard accounting
principles and to compare changes in INPV between a base case and
various TSLs (the standards cases). The difference in INPV between the
base and standards cases represents the financial impact of potential
amended energy conservation standards on GSFL and IRL manufacturers.
Different sets of assumptions (scenarios) produce different INPV
results. The qualitative part of the MIA addresses factors such as
manufacturing capacity; characteristics of, and impacts on, any
particular subgroup of manufacturers; impacts on competition; and the
cumulative regulatory burden placed on GSFL and IRL manufacturers.
DOE outlined its complete methodology for the MIA in the previously
published NOPR. Also, the complete MIA is presented in chapter 13 of
the final rule TSD.
1. Manufacturer Production Costs
Manufacturing more efficacious lamps is typically more expensive
than manufacturing baseline lamps due to the need for more costly
components and materials used in the lamps as well as more extensive
R&D to design the more efficacious lamps. The resulting changes in the
manufacturer product costs (MPCs) of the representative lamps can
affect the revenues, gross margins, and cash flows of lamp
manufacturers. DOE strives to accurately model the potential changes in
these production costs, as they are a key input for the GRIM and DOE's
overall analysis. For the final rule, DOE updated the dollar year of
the MPCs from 2012$, the dollar year used in the NOPR, to 2013$.
2. Shipment Projections
Changes in sales volumes and efficacy distribution of lamps over
time can significantly affect manufacturer finances. The GRIM estimates
manufacturer revenues based on total unit shipment projections and the
distribution of shipments by efficacy level. For the final rule, DOE
slightly altered the distribution of shipments based on interested
party comments. DOE also updated the shipments to reflect the potential
amended standard going into effect in 2018 as opposed to 2017, the
standard compliance date used in the NOPR. This had a negligible effect
on the MIA results. For the MIA, the GRIM used the NIA's annual
shipment projections from 2015, the base year, to 2047, the end of the
analysis period. For a complete description of the shipment analysis
see chapter 11 of the final rule TSD.
3. Markup Scenarios
For the GSFL and IRL NOPR MIAs, DOE modeled two standards case
markup scenarios to represent the uncertainty regarding the potential
impacts on prices and profitability for manufacturers following the
implementation of potential amended energy conservation standards: (1)
A flat, or preservation of gross margin, markup scenario and (2) a
preservation of operating profit markup scenario. Each scenario leads
to different manufacturer markup values, which when applied to the
inputted MPCs, result in varying revenue and cash-flow impacts.
During the NOPR public meeting, Philips and Westinghouse commented
that DOE should consider a third markup scenario for GSFLs where
manufacturers are not able to maintain the absolute dollars on their
GSFLs, as they do in the preservation of operating
[[Page 4096]]
profit, due to the increase in MPC of GSFLs as a result of amended
energy conservation standards. Philips stated that amended standards
could cause a total commoditization of the GSFL market, especially at
max-tech, so the only way to differentiate products is by price. They
also stated that since manufacturers have already established the
pricing levels for these GSFLs, it is hard to justify an increase in
the price after standards go into effect, as many of the big box retail
stores are not going to accept a higher price for GSFLs. Both of the
factors likely will result in manufacturers reducing their manufacturer
markups. (Philips, Public Meeting Transcript, No. 49 at pp. 216-217;
Westinghouse, Public Meeting Transcript, No. 49 at pp. 221-222) Based
on the GSFL market pricing conditions described during manufacturer
interviews, DOE concluded that the markup scenario recommended by
Philips and Westinghouse is a realistic markup scenario that should be
incorporated into the MIA to reflect the range of possible outcomes
following GSFL standards. Therefore, DOE examined the INPV impacts of a
two-tiered markup scenario in the final rule for the GSFL MIA as a
result of these comments. The results of this additional markup
scenario are displayed in section VII.B.2.a, along with the rest of the
manufacturer INPV results.
In the two-tiered markup scenario, DOE assumed that higher efficacy
GSFLs command a higher manufacturer markup and baseline efficacy GSFLs
subsequently have a lower manufacturer markup. DOE estimated the
manufacturer markups for GSFLs under a two-tier pricing strategy in the
base case based on manufacturer interviews conducted as part of the
NOPR analysis. In the standards case, DOE modeled the situation in
which portfolio reduction reduces the margin of higher efficacy GSFLs
as they become the new baseline efficacy products due to amended
standards. This new two-tiered markup scenario represents the lower
bound profitability markup scenario.
4. Product and Capital Conversion Costs
Amended energy conservation standards will cause manufacturers to
incur one-time conversion costs to bring their production facilities
and product designs into compliance. For the MIA, DOE classified these
one-time conversion costs into two major groups: (1) Product conversion
costs and (2) capital conversion costs. Product conversion costs are
one-time investments in R&D, testing, compliance, marketing, and other
non-capitalized costs necessary to make product designs comply with
amended standards. Capital conversion costs are one-time investments in
property, plant, and equipment necessary to adapt or change existing
production facilities such that new product designs can be fabricated
and assembled. For the final rule, DOE only updated the dollar year of
the conversion costs from 2012$, the dollar year used in the NOPR, to
2013$.
During the NOPR public meeting GE and Philips commented that they
believe that IRL manufacturers would be unwilling to make large
investments to make sure IRLs comply with energy conservation standards
at TSL 1, since the market is changing so rapidly to LEDs and
manufacturers might not ever be able to recover any substantial
investment put in upgrading their IRLs. (Philips, Public Meeting
Transcript, No. 49 at p. 231 & GE, Public Meeting Transcript, No. 49 a
pp. 231-232) DOE understands manufacturers' concern with making
significant investments in a product that is rapidly losing market
share and projected to experience a significant decline in shipments
over the analysis period. DOE took these manufacturers' concerns into
account when selecting the standards for IRLs in this final rule.
5. Other Comments From Interested Parties
During the NOPR public meeting and comment period, interested
parties commented on the assumptions, methodology, and results of the
NOPR MIA. DOE received comments about the potential high cost to
manufacturers versus the relatively low energy savings for the NOPR
standards proposed; the potential negative impacts on competition due
to standards; and the potential impact of standards on alternative
lighting technologies. These comments are addressed in the following
sections.
a. High Cost to Manufacturers Versus Relatively Low Energy Savings
NEMA and GE commented that the pending IRL standards as proposed in
the NOPR would have a significant negative impact on IRL manufacturers'
INPV while only marginally contributing to the projected energy
savings. (NEMA, No. 54 at pp. 3-5 & GE, Public Meeting Transcript, No.
49 at pp. 217-218) DOE agrees that as proposed in the NOPR, the IRL
standards at TSL 1 could reduce IRL manufacturers' INPV by up to 29.5
percent and would save an estimated 0.013 quads. DOE carefully examines
all potential burdens, such as a potential decrease in manufacturers'
INPV and the cumulative regulatory burden placed on manufacturers by
additional regulations, against potential benefits, such as energy
savings and consumer benefits, when determining final standards. Both
the benefits and burdens for this rulemaking were closely examined
before making a final decision regarding the IRL standards. See section
VII.C.3 of this final rule for a complete description of the potential
benefits and burdens of IRL standards.
b. Impacts on Competition
A couple of interested parties commented that DOE should use the
Herfindahl-Hirschman Index (HHI) to examine whether potential energy
conservation standards could significantly lessen competition in an
industry. (Kidwell, No. 53 at pp. 1-6 & Miller, No. 50 at pp. 10-11,
13) The HHI is used by DOJ to examine market consolidation in the case
of potential mergers. In these cases there is clear market share
information before and after the event being analyzed, a potential
merger. However, when examining potential energy conservation standards
it is more difficult to accurately predict how individual manufacturers
will respond to potential standards.
The decision of an individual manufacturer to make an upfront
investment in order to comply with potential standards and remain in an
existing market as opposed to exit the market is a complex business.
For the GSFL and IRL rulemakings there is no technical reason any of
the major manufacturers could not continue to manufacture compliant
products, could maintain their current market share within an industry,
or would be forced to exit the market. DOE acknowledges that both the
GSFL and IRL markets are moderately concentrated markets, according to
the HHI. However, based on manufacturer interviews, DOE does not
believe there is any technical or proprietary reason the market share
of either the GSFL or IRL markets would substantially change due to the
energy conservation standards established in this final rule.
Therefore, an analysis using the HHI would not be able to determine if
standards lessened competition, since the market share before the
standards would be similar to the market share after the standards.
c. Impact of GSFL and IRL Standards on Alternative Lighting
Technologies
NEEP commented that the MIA should account for the potential growth
in other lighting technologies (i.e., LEDs), since alternative lighting
sales are projected to take market share away from GSFLs and IRLs in
the future.
[[Page 4097]]
(NEEP, No. 57 at p.3) DOE's shipment analysis does predict that LEDs
and other alternative lighting technologies will significantly take
more and more market share away from GSFLs and IRLs in future years.
This growing LED market share is modeled in the base case of the
shipment analysis when no energy conservation standards are enacted,
and is therefore independent from any GSFL or IRL standards that are
being analyzed in this rulemaking.
The shipment analysis does not anticipate that consumers will shift
to LEDs as a result of potential GSFL or IRL standards and therefore
the total number of lighting hours fulfilled by GSFLs and IRLs is the
same in the base case as in the standards cases. Since DOE is
attempting to model the direct impacts of the GSFL and IRL standards
independently from other external factors that are occurring in the
GSFL and IRL markets, DOE does not believe it should include revenue
from the sale of alternative lighting technologies in the MIA for GSFLs
and IRLs. See the shipments analysis in chapter 11 of the final rule
TSD for a complete description of how GSFL and IRL shipments change in
response to potential GSFL and IRL standards.
6. Manufacturer Interviews
DOE interviewed manufacturers representing more than 90 percent of
covered GSFL and more than 80 percent of covered IRL sales in the
United States. The NOPR interviews were in addition to the preliminary
interviews DOE conducted as part of the preliminary analysis. DOE
outlined the key issues for the rulemaking for GSFL and IRL
manufacturers in the NOPR. 79 FR at 24136-7 (April 29, 2014) DOE
considered the information received during these interviews in the
development of the NOPR and this final rule. Comments on the NOPR
regarding the impact of potential amended standards on manufacturers
were discussed in the previous sections. DOE did not conduct interviews
with manufacturers between the publication of the NOPR and this final
rule. Also, DOE did not receive any comments on the manufacturer key
issues identified in the NOPR.
L. Emissions Analysis
In the emissions analysis, DOE estimated the reduction in power
sector emissions of carbon dioxide (CO2), nitrogen oxides
(NOX), sulfur dioxide (SO2), and mercury (Hg)
from potential energy conservation standards for GSFLs and IRLs. In
addition, DOE estimates emissions impacts in production activities
(extracting, processing, and transporting fuels) that provide the
energy inputs to power plants. These are referred to as ``upstream''
emissions. Together, these emissions account for the full-fuel-cycle
(FFC). In accordance with DOE's FFC Statement of Policy (76 FR 51282
(Aug. 18, 2011)),\68\ the FFC analysis also includes impacts on
emissions of methane (CH4) and nitrous oxide
(N2O), both of which are recognized as greenhouse gases.
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\68\ DOE's FFC was amended in 2012 for reasons unrelated to the
inclusion of CH4 and N2O. 77 FR 49701 (Aug.
17, 2012).
---------------------------------------------------------------------------
DOE primarily conducted the emissions analysis using emissions
factors for CO2 and most of the other gases derived from
data in AEO 2014. Combustion emissions of CH4 and
N2O were estimated using emissions intensity factors
published by the Environmental Protection Agency (EPA), GHG Emissions
Factors Hub.\69\ DOE developed separate emissions factors for power
sector emissions and upstream emissions. The method that DOE used to
derive emissions factors is described in chapter 14 of the final rule
TSD.
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\69\ http://www.epa.gov/climateleadership/inventory/ghg-emissions.html.
---------------------------------------------------------------------------
For CH4 and N2O, DOE calculated emissions
reduction in tons and also in terms of units of carbon dioxide
equivalent (CO2eq). Gases are converted to CO2eq
by multiplying the physical units by the gas' global warming potential
(GWP) over a 100-year time horizon. Based on the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change,\70\ DOE used
GWP values of 28 for CH4 and 265 for N2O.
---------------------------------------------------------------------------
\70\ IPCC, 2013: Climate Change 2013: The Physical Science
Basis. Contribution of Working Group I to the Fifth Assessment
Report of the Intergovernmental Panel on Climate Change [Stocker,
T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A.
Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge
University Press, Cambridge, United Kingdom and New York, NY, USA.
Chapter 8.
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EIA prepares the Annual Energy Outlook using NEMS. Each annual
version of NEMS incorporates the projected impacts of existing air
quality regulations on emissions. AEO 2014 generally represents current
legislation and environmental regulations, including recent government
actions, for which implementing regulations were available as of
October 31, 2013.
SO2 emissions from affected electric generating units
(EGUs) are subject to nationwide and regional emissions cap-and-trade
programs. Title IV of the Clean Air Act sets an annual emissions cap on
SO2 for affected EGUs in the 48 contiguous states and the
District of Columbia (DC). SO2 emissions from 28 eastern
states and DC were also limited under the Clean Air Interstate Rule
(CAIR; 70 FR 25162 (May 12, 2005)), which created an allowance-based
trading program that operates along with the Title IV program. CAIR was
remanded to the U.S. Environmental Protection Agency (EPA) by the U.S.
Court of Appeals for the District of Columbia Circuit but it remained
in effect.\71\ In 2011, EPA issued a replacement for CAIR, the Cross-
State Air Pollution Rule (CSAPR). 76 FR 48208 (Aug. 8, 2011). On August
21, 2012, the DC Circuit issued a decision to vacate CSAPR.\72\ The
court ordered EPA to continue administering CAIR. The emissions factors
used for this rule, which are based on AEO 2014, assume that CAIR
remains a binding regulation through 2040.\73\
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\71\ See North Carolina v. EPA, 550 F.3d 1176 (D.C. Cir. 2008);
North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008).
\72\ See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38
(D.C. Cir. 2012), cert. granted, 81 U.S.L.W. 3567, 81 U.S.L.W. 3696,
81 U.S.L.W. 3702 (U.S. June 24, 2013) (No. 12-1182).
\73\ On April 29, 2014, the U.S. Supreme Court reversed the
judgment of the D.C. Circuit and remanded the case for further
proceedings consistent with the Supreme Court's opinion. The Supreme
Court held in part that EPA's methodology for quantifying emissions
that must be eliminated in certain states due to their impacts in
other downwind states was based on a permissible, workable, and
equitable interpretation of the Clean Air Act provision that
provides statutory authority for CSAPR. See EPA v. EME Homer City
Generation, No 12-1182, slip op. at 32 (U.S. April 29, 2014). On
October 23, 2014, the DC Circuit lifted the stay of CSAPR and CSAPR
is scheduled to go into effect (and the CAIR will sunset) as of
January 1, 2015. Because DOE is using emissions factors based on AEO
2014 for this rule, the final rule assumes that CAIR, not CSAPR, is
the regulation in force. The difference between CAIR and CSAPR is
not relevant for the purpose of DOE's analysis of SO2
emissions.
---------------------------------------------------------------------------
The attainment of emissions caps is typically flexible among EGUs
and is enforced through the use of emissions allowances and tradable
permits. Beginning in 2016, however, SO2 emissions will
decline significantly as a result of the Mercury and Air Toxics
Standards (MATS) for power plants. 77 FR 9304 (Feb. 16, 2012). In the
final MATS rule, EPA established a standard for hydrogen chloride as a
surrogate for acid gas hazardous air pollutants (HAP), and also
established a standard for SO2 (a non-HAP acid gas) as an
alternative equivalent surrogate standard for acid gas HAP. The same
controls are used to reduce HAP and non-HAP acid gas; thus,
SO2 emissions will be reduced as a result of the control
technologies installed on coal-fired power plants to comply with the
MATS requirements for acid gas. AEO 2014 assumes that, in order to
continue operating, coal plants must have either flue gas
desulfurization or dry sorbent injection
[[Page 4098]]
systems installed by 2016. Both technologies, which are used to reduce
acid gas emissions, also reduce SO2 emissions. Under the
MATS, emissions will be far below the cap established by CAIR, so it is
unlikely that excess SO2 emissions allowances resulting from
the lower electricity demand would be needed or used to permit
offsetting increases in SO2 emissions by any regulated EGU.
Therefore, DOE believes that energy efficiency standards will reduce
SO2 emissions in 2016 and beyond
CAIR established a cap on NOX emissions in 28 eastern
States and the District of Columbia.\74\ Energy conservation standards
are expected to have little effect on NOX emissions in those
States covered by CAIR because excess NOX emissions
allowances resulting from the lower electricity demand could be used to
permit offsetting increases in NOX emissions. However,
standards would be expected to reduce NOX emissions in the
States not affected by the caps, so DOE estimated NOX
emissions reductions from the standards considered in this rule for
these States.
---------------------------------------------------------------------------
\74\ CSAPR also applies to NOX, and it would
supersede the regulation of NOX under CAIR. As stated
previously, the current analysis assumes that CAIR, not CSAPR, is
the regulation in force. The difference between CAIR and CSAPR with
regard to DOE's analysis of NOX is slight.
---------------------------------------------------------------------------
The MATS limit mercury emissions from power plants, but they do not
include emissions caps. DOE estimated mercury emissions reduction using
emissions factors based on AEO 2014, which incorporates the MATS.
M. Monetizing Carbon Dioxide and Other Emissions Impacts
As part of the development of this rule, DOE considered the
estimated monetary benefits from the reduced emissions of
CO2 and NOX that are expected to result from each
of the TSLs considered. In order to make this calculation similar to
the calculation of the NPV of consumer benefit, DOE considered the
reduced emissions expected to result over the lifetime of products
shipped in the forecast period for each TSL. This section summarizes
the basis for the monetary values used for each of these emissions and
presents the values considered in this rulemaking.
For this rule, DOE is relying on a set of values for the social
cost of carbon (SCC) that was developed by an interagency process. A
summary of the basis for these values is provided in the following
section, and a more detailed description of the methodologies used is
provided as an appendix to chapter 15 of the final rule TSD.
1. Social Cost of Carbon
The SCC is an estimate of the monetized damages associated with an
incremental increase in carbon emissions in a given year. It is
intended to include (but is not limited to) changes in net agricultural
productivity, human health, property damages from increased flood risk,
and the value of ecosystem services. Estimates of the SCC are provided
in dollars per metric ton of carbon dioxide. A domestic SCC value is
meant to reflect the value of damages in the United States resulting
from a unit change in carbon dioxide emissions, while a global SCC
value is meant to reflect the value of damages worldwide.
Under section 1(b)(6) of Executive Order 12866, ``Regulatory
Planning and Review,'' 58 FR 51735 (Oct. 4, 1993), agencies must, to
the extent permitted by law, assess both the costs and the benefits of
the intended regulation and, recognizing that some costs and benefits
are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation
justify its costs. The purpose of the SCC estimates presented here is
to allow agencies to incorporate the monetized social benefits of
reducing CO2 emissions into cost-benefit analyses of
regulatory actions that have small, or ``marginal,'' impacts on
cumulative global emissions. The estimates are presented with an
acknowledgement of the many uncertainties involved and with a clear
understanding that they should be updated over time to reflect
increasing knowledge of the science and economics of climate impacts.
As part of the interagency process that developed the SCC
estimates, technical experts from numerous agencies met on a regular
basis to consider public comments, explore the technical literature in
relevant fields, and discuss key model inputs and assumptions. The main
objective of this process was to develop a range of SCC values using a
defensible set of input assumptions grounded in the existing scientific
and economic literatures. In this way, key uncertainties and model
differences transparently and consistently inform the range of SCC
estimates used in the rulemaking process.
a. Monetizing Carbon Dioxide Emissions
When attempting to assess the incremental economic impacts of
carbon dioxide emissions, the analyst faces a number of challenges. A
report from the National Research Council points out that any
assessment will suffer from uncertainty, speculation, and lack of
information about: (1) Future emissions of greenhouse gases; (2) the
effects of past and future emissions on the climate system; (3) the
impact of changes in climate on the physical and biological
environment; and (4) the translation of these environmental impacts
into economic damages. As a result, any effort to quantify and monetize
the harms associated with climate change will raise serious questions
of science, economics, and ethics and should be viewed as provisional.
Despite the limits of both quantification and monetization, SCC
estimates can be useful in estimating the social benefits of reducing
carbon dioxide emissions. The agency can estimate the benefits from
reduced (or costs from increased) emissions in any future year by
multiplying the change in emissions in that year by the SCC values
appropriate for that year. The NPV of the benefits can then be
calculated by multiplying each of these future benefits by an
appropriate discount factor and summing across all affected years.
It is important to emphasize that the interagency process is
committed to updating these estimates as the science and economic
understanding of climate change and its impacts on society improves
over time. In the meantime, the interagency group will continue to
explore the issues raised by this analysis and consider public comments
as part of the ongoing interagency process.
b. Development of Social Cost of Carbon Values
In 2009, an interagency process was initiated to offer a
preliminary assessment of how best to quantify the benefits from
reducing carbon dioxide emissions. To ensure consistency in how
benefits are evaluated across Federal agencies, the Administration
sought to develop a transparent and defensible method, specifically
designed for the rulemaking process, to quantify avoided climate change
damages from reduced CO2 emissions. The interagency group
did not undertake any original analysis. Instead, it combined SCC
estimates from the existing literature to use as interim values until a
more comprehensive analysis could be conducted. The outcome of the
preliminary assessment by the interagency group was a set of five
interim values: global SCC estimates for 2007 (in 2006$) of $55, $33,
$19, $10, and $5 per metric ton of CO2. These interim values
represented the first sustained interagency effort within the U.S.
government to develop an SCC for use in regulatory analysis.
[[Page 4099]]
The results of this preliminary effort were presented in several
proposed and final rules.
c. Current Approach and Key Assumptions
After the release of the interim values, the interagency group
reconvened on a regular basis to generate improved SCC estimates.
Specifically, the group considered public comments and further explored
the technical literature in relevant fields. The interagency group
relied on three integrated assessment models commonly used to estimate
the SCC: the FUND, DICE, and PAGE models. These models are frequently
cited in the peer-reviewed literature and were used in the last
assessment of the Intergovernmental Panel on Climate Change (IPCC).
Each model was given equal weight in the SCC values that were
developed.
Each model takes a slightly different approach to model how changes
in emissions result in changes in economic damages. A key objective of
the interagency process was to enable a consistent exploration of the
three models while respecting the different approaches to quantifying
damages taken by the key modelers in the field. An extensive review of
the literature was conducted to select three sets of input parameters
for these models: climate sensitivity, socio-economic and emissions
trajectories, and discount rates. A probability distribution for
climate sensitivity was specified as an input into all three models. In
addition, the interagency group used a range of scenarios for the
socio-economic parameters and a range of values for the discount rate.
All other model features were left unchanged, relying on the model
developers' best estimates and judgments.
The interagency group selected four sets of SCC values for use in
regulatory analyses.\75\ Three sets of values are based on the average
SCC from three integrated assessment models, at discount rates of 2.5
percent, 3 percent, and 5 percent. The fourth set, which represents the
95th-percentile SCC estimate across all three models at a 3-percent
discount rate, is included to represent higher-than-expected impacts
from climate change further out in the tails of the SCC distribution.
The values grow in real terms over time. Additionally, the interagency
group determined that a range of values from 7 percent to 23 percent
should be used to adjust the global SCC to calculate domestic
effects,\76\ although preference is given to consideration of the
global benefits of reducing CO2 emissions. Table VI.11
presents the values in the 2010 interagency group report, which is
reproduced in appendix 15A of the final rule TSD.
---------------------------------------------------------------------------
\75\ Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866. Interagency Working Group on Social Cost of
Carbon, United States Government, February 2010. http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
\76\ It is recognized that this calculation for domestic values
is approximate, provisional, and highly speculative. There is no a
priori reason why domestic benefits should be a constant fraction of
net global damages over time.
Table VI.11--Annual SCC Values From 2010 Interagency Report, 2010-2050
[In 2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 4.7 21.4 35.1 64.9
2015............................................ 5.7 23.8 38.4 72.8
2020............................................ 6.8 26.3 41.7 80.7
2025............................................ 8.2 29.6 45.9 90.4
2030............................................ 9.7 32.8 50.0 100.0
2035............................................ 11.2 36.0 54.2 109.7
2040............................................ 12.7 39.2 58.4 119.3
2045............................................ 14.2 42.1 61.7 127.8
2050............................................ 15.7 44.9 65.0 136.2
----------------------------------------------------------------------------------------------------------------
The SCC values used for the rule were generated using the most
recent versions of the three integrated assessment models that have
been published in the peer-reviewed literature.\77\ Table VI.12 shows
the updated sets of SCC estimates from the 2013 interagency update in
five-year increments from 2010 to 2050. Appendix 15B of the final rule
TSD provides the full set of values. The central value that emerges is
the average SCC across models at 3-percent discount rate. However, for
purposes of capturing the uncertainties involved in regulatory impact
analysis, the interagency group emphasizes the importance of including
all four sets of SCC values.
---------------------------------------------------------------------------
\77\ Technical Update of the Social Cost of Carbon for
Regulatory Impact Analysis Under Executive Order 12866. Interagency
Working Group on Social Cost of Carbon, United States Government.
May 2013; revised November 2013. http://www.whitehouse.gov/sites/default/files/omb/assets/inforeg/technical-update-social-cost-of-carbon-for-regulator-impact-analysis.pdf.
Table VI.12--Annual SCC Values From 2013 Interagency Update, 2010-2050
[In 2007 dollars per metric ton CO2]
----------------------------------------------------------------------------------------------------------------
Discount rate %
---------------------------------------------------------------
5 3 2.5 3
Year ---------------------------------------------------------------
95th
Average Average Average Percentile
----------------------------------------------------------------------------------------------------------------
2010............................................ 11 32 51 89
2015............................................ 11 37 57 109
2020............................................ 12 43 64 128
[[Page 4100]]
2025............................................ 14 47 69 143
2030............................................ 16 52 75 159
2035............................................ 19 56 80 175
2040............................................ 21 61 86 191
2045............................................ 24 66 92 206
2050............................................ 26 71 97 220
----------------------------------------------------------------------------------------------------------------
It is important to recognize that a number of key uncertainties
remain, and that current SCC estimates should be treated as provisional
and revisable since they will evolve with improved scientific and
economic understanding. The interagency group also recognizes that the
existing models are imperfect and incomplete. The National Research
Council report mentioned above points out that there is tension between
the goal of producing quantified estimates of the economic damages from
an incremental ton of carbon and the limits of existing efforts to
model these effects. There are a number of analytical challenges that
are being addressed by the research community, including research
programs housed in many of the Federal agencies participating in the
interagency process to estimate the SCC. The interagency group intends
to periodically review and reconsider those estimates to reflect
increasing knowledge of the science and economics of climate impacts,
as well as improvements in modeling.
In summary, in considering the potential global benefits resulting
from reduced CO2 emissions, DOE used the values from the
2013 interagency report, adjusted to 2013$ using the Gross Domestic
Product price deflator. For each of the four SCC cases specified, the
values used for emissions in 2015 were $12.0, $40.5, $62.4, and $119
per metric ton avoided (values expressed in 2013$). DOE derived values
after 2050 using the relevant growth rates for the 2040-2050 period in
the interagency update.
DOE multiplied the CO2 emissions reduction estimated for
each year by the SCC value for that year in each of the four cases. To
calculate a present value of the stream of monetary values, DOE
discounted the values in each of the four cases using the specific
discount rate that had been used to obtain the SCC values in each case.
The Associations objected to DOE's continued use of the SCC in the
cost-benefit analysis performed in connection with this proposed rule,
and they believe the SCC should be withdrawn as a basis for the rule.
They stated that the SCC calculation should not be used in any
rulemaking or policymaking until it undergoes a more rigorous notice,
review, and comment process. (The Associations, No. 51 at p. 4) In
contrast, the Joint Commenters stated that the current SCC values are
sufficiently robust and accurate to continue to be the basis for
regulatory analysis going forward. They argued that, if anything,
current values are significant underestimates of the SCC. They stated
that the interagency working group's analytic process was science-
based, open, and transparent, and the SCC is an important and accepted
tool for regulatory policy-making, based on well-established law and
fundamental economics. (The Joint Comment, 48 at p. 1)
NEMA presented a critique--based largely on the writing of Robert
Pindyck of the Massachusetts Institute of Technology--of the integrated
assessment models (IAMs) used in projecting future damages from
CO2 emissions. The critique included strong criticisms of
the IAMs' climate sensitivity analysis and damage function. NEMA argued
that given the enormous uncertainty in the IAMs, these models--even
``averaged'' as the Interagency Working Group has done--are poor tools
for agency decision-making, particularly with respect to products
regulated by EPCA that are not themselves a source of emissions. (NEMA,
No. 54 at pp. 39-44)
DOE acknowledges the limitations of the SCC estimates, which are
discussed in detail in the 2010 interagency working group's report.
Specifically, uncertainties in the assumptions regarding climate
sensitivity, as well as other model inputs such as economic growth and
emissions trajectories, are discussed and the reasons for the specific
input assumptions chosen are explained. However, the three integrated
assessment models used to estimate the SCC are frequently cited in the
peer-reviewed literature and were used in the last assessment of the
IPCC. In addition, new versions of the models that were used in 2013 to
estimate revised SCC values were published in the peer-reviewed
literature (see appendix 15B of the final rule TSD for discussion).
Although uncertainties remain, the revised estimates used for this rule
are based on the best available scientific information on the impacts
of climate change. The current estimates of the SCC have been developed
over many years, and with input from the public. In November 2013, OMB
announced a new opportunity for public comment on the interagency
technical support document underlying the revised SCC estimates. 78 FR
70586. OMB is reviewing comments and considering whether further
revisions to the SCC estimates are warranted. DOE stands ready to work
with OMB and the other members of the interagency working group on
further review and revision of the SCC estimates as appropriate.
NEMA stated that the monetized benefits of carbon emission
reductions are informative at some level, but should not be considered
as determinative in the Secretary's decision-making under EPCA. NEMA
believes that DOE should base its net benefit determination for
justifying a particular energy conservation on the traditional criteria
relied upon by DOE: impacts on manufacturers, consumers, employment,
energy savings, and competition. (NEMA, 54 at pp. 38 and 44) In a
similar vein, the Associations believe the SCC should be withdrawn as a
basis for the proposed rule. (The Associations, No. 51, p. 4)
The monetized benefits of carbon emission reductions are one factor
that DOE considers in its evaluation of the economic justification of
proposed standards. As shown in Table VII.58, the benefits of these
standards in terms of
[[Page 4101]]
consumer operating cost savings exceed the incremental costs of the
standards-compliant products. The benefits of CO2 emission
reductions were considered by DOE, but were not determinative in DOE's
decision to adopt these standards, nor were they a primary basis of
that decision.
2. Valuation of Other Emissions Reductions
As noted previously, DOE has taken into account how amended energy
conservation standards would reduce site NOX emissions
nationwide and increase power sector NOX emissions in those
22 States not affected by the CAIR. DOE estimated the monetized value
of net NOX emissions reductions resulting from each of the
TSLs considered for this rule based on estimates found in the relevant
scientific literature. Estimates of monetary value for reducing
NOX from stationary sources range from $476 to $4,893 per
ton in 2013$.\78\ DOE calculated monetary benefits using a medium value
for NOX emissions of $2,684 per short ton and real discount
rates of 3 percent and 7 percent.
---------------------------------------------------------------------------
\78\ U.S. Office of Management and Budget, Office of Information
and Regulatory Affairs, 2006 Report to Congress on the Costs and
Benefits of Federal Regulations and Unfunded Mandates on State,
Local, and Tribal Entities (2006) (Available at: http://www.whitehouse.gov/sites/default/files/omb/assets/omb/inforeg/2006_cb/2006_cb_final_report.pdf).
---------------------------------------------------------------------------
DOE is evaluating appropriate monetization of avoided
SO2 and Hg emissions in energy conservation standards
rulemakings. It has not included monetization in the current analysis.
N. Utility Impact Analysis
The utility impact analysis estimates several effects on the power
generation industry that would result from the adoption of new or
amended energy conservation standards. In the utility impact analysis,
DOE analyzes the changes in installed electricity capacity and
generation that would result for each TSL. The utility impact analysis
is based on published output from NEMS. Each year, NEMS is updated to
produce the AEO reference case as well as a number of side cases that
estimate the economy-wide impacts of changes to energy supply and
demand. DOE uses those published side cases that incorporate
efficiency-related policies to estimate the marginal impacts of reduced
energy demand on the utility sector. The output of this analysis is a
set of time-dependent coefficients that capture the change in
electricity generation, primary fuel consumption, installed capacity
and power sector emissions due to a unit reduction in demand for a
given end use. These coefficients are multiplied by the stream of
energy savings calculated in the NIA to provide estimates of selected
utility impacts of new or amended energy conservation standards.
Chapter 16 of the final rule TSD describes the utility impact analysis
in further detail.
O. Employment Impact Analysis
Employment impacts from new or amended energy conservation
standards include direct and indirect impacts. Direct employment
impacts are any changes in the number of employees of manufacturers of
the product subject to standards; the MIA addresses those impacts.
Indirect employment impacts are changes in national employment that
occur due to the shift in expenditures and capital investment caused by
the purchase and operation of more efficient product. Indirect
employment impacts from standards consist of the jobs created or
eliminated in the national economy, other than in the manufacturing
sector being regulated, due to: (1) Reduced spending by end users on
energy; (2) reduced spending on new energy supply by the utility
industry; (3) increased consumer spending on the purchase of new
product; and (4) the effects of those three factors throughout the
economy.
One method for assessing the possible effects on the demand for
labor of such shifts in economic activity is to compare sector
employment statistics developed by the Labor Department's Bureau of
Labor Statistics (BLS). BLS regularly publishes its estimates of the
number of jobs per million dollars of economic activity in different
sectors of the economy, as well as the jobs created elsewhere in the
economy by this same economic activity. Data from BLS indicate that
expenditures in the utility sector generally create fewer jobs (both
directly and indirectly) than expenditures in other sectors of the
economy. There are many reasons for these differences, including wage
differences and the fact that the utility sector is more capital-
intensive and less labor-intensive than other sectors. Energy
conservation standards have the effect of reducing consumer utility
bills. Because reduced consumer expenditures for energy likely lead to
increased expenditures in other sectors of the economy, the general
effect of efficiency standards is to shift economic activity from a
less labor-intensive sector (i.e., the utility sector) to more labor-
intensive sectors (e.g., the retail and service sectors). Based on the
BLS data, DOE expects that net national employment may increase because
of shifts in economic activity resulting from amended standards.
For the standard levels considered for the final rule, DOE
estimated indirect national employment impacts using an input/output
model of the U.S. economy called Impact of Sector Energy Technologies,
Version 3.1.1 (ImSET).\79\ ImSET is a special-purpose version of the
``U.S. Benchmark National Input-Output'' (I-O) model, which was
designed to estimate the national employment and income effects of
energy-saving technologies. The ImSET software includes a computer-
based I-O model having structural coefficients that characterize
economic flows among the 187 sectors. ImSET's national economic I-O
structure is based on a 2002 U.S. benchmark table, specially aggregated
to the 187 sectors most relevant to industrial, commercial, and
residential building energy use. DOE notes that ImSET is not a general
equilibrium forecasting model, and understands the uncertainties
involved in projecting employment impacts, especially changes in the
later years of the analysis. Because ImSET does not incorporate price
changes, the employment effects predicted by ImSET may over-estimate
actual job impacts over the long run. DOE used ImSET only to estimate
short-term employment impacts. For more details on the employment
impact analysis, see chapter 17 of the final rule TSD.
---------------------------------------------------------------------------
\79\ Roop, J. M., M. J. Scott, and R. W. Schultz, ImSET: Impact
of Sector Energy Technologies, 2005. Pacific Northwest National
Laboratory. Richland, WA. Report No. PNNL-15273. <http://www.pnl.gov/main/publications/external/technical_reports/PNNL-15273.pdf.
---------------------------------------------------------------------------
P. Proposed Standards in April 2014 NOPR
In the NOPR, DOE proposed to adopt new and amended standards for
all GSFL product classes and amended standards for all IRL product
classes. For GSFLs, DOE proposed adopting TSL 5, which represented the
max tech and maximum NES. Specifically, TSL 5 would set energy
conservation standards at EL 2 for the 4-foot MBP, 8-foot SP slimline,
8-foot RDC HO, and T5 MiniBP SO product classes. For IRLs, DOE proposed
adopting TSL 1, which was EL 1 and represented max tech. DOE received
general comments on the proposed standards.
Miller stated that there are three problems that DOE states it is
trying to address by setting efficacy standards for GSFLs and IRLs:
lack of consumer information, asymmetric information about the benefits
of energy-efficient commercial appliances, and externalities related to
greenhouse gas
[[Page 4102]]
emissions. However, two of the problems cited by DOE--lack of consumer
information about energy efficiency and information asymmetry--are not
addressed in its proposed efficacy standards. Additionally, DOE does
not explain why GSFL and IRL consumers would suffer from either
informational deficits or cognitive biases that would cause them to
purchase products with high lifetime costs without demanding higher
price, higher efficacy products. Miller further states that this
asymmetric information, if it exists, could be remedied by improved
labeling or other types of consumer education campaigns rather than
banning products from the marketplace, especially given the projected
penetration rates of LEDs. (Miller, No. 50 at p. 11)
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review'' requires Federal agencies to identify the problem that it
intends to address, including, where applicable, the failures of
private markets or public institutions that warrant new agency action,
as well as to assess the significance of that problem. 58 FR 51735
(Oct. 4, 1993) Section 1(b) also states that agencies should adhere to
the listed principles to the extent permitted by law. DOE's standards
rulemaking process is intended to fulfill the requirements of EPCA. Any
amended standard for a covered product must be designed to achieve the
maximum improvement in energy efficiency that is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A))
Furthermore, DOE may not adopt any standard that would not result in
the significant conservation of energy. (42 U.S.C. 6295(o)(3)) The
proposed standards, and the standards established in this final rule,
meet these criteria. By adopting standards that achieve maximum
improvement in energy efficiency that is technologically feasible and
economically justified, this rulemaking is indirectly addressing any
potential lack of consumer information regarding energy efficiency and
asymmetric information regarding these products. Alternative remedies
proposed by Miller, such as labeling and consumer information, are
covered by other programs established by EPCA. (42 U.S.C. 6294 and 42
U.S.C. 6307) However, the existence of such programs does not obviate
DOE's legal requirement to adhere to the standards rulemaking process
laid out in EPCA.
Miller stated that DOE's approach is contrary to instruction to
agencies in Executive Order 13563, which requires agencies to identify
and consider regulatory approaches that reduce burdens and maintain
flexibility and freedom of choice for the public. Miller noted that
this included warnings, appropriate default rules, and disclosure
requirements, and providing clear and intelligible information to the
public. (Miller, No. 50 at p. 11)
DOE identified and evaluated non-regulatory approaches to improving
the efficacy of GSFLs and IRLs, as described in chapter 18 of the final
rule TSD. DOE currently does not have statutory authority to implement
most of these alternatives. Furthermore, DOE concluded that all of the
non-regulatory alternatives would save less energy and have a lower NPV
than adopted standards.
Regarding warnings, default rules, and disclosure requirements, in
this final rule notice DOE clearly describes amendments to existing
standards being adopted in this rule and explains that compliance to
the new and amended standards will be required three years after the
publication date of this notice. See section VI.G.13 for compliance
date information. DOE has held public meetings and invited comments
from stakeholders in the framework, preliminary analysis, and NOPR
stages of this rulemaking and held interviews with manufacturers at the
preliminary and NOPR stages. At each stage DOE has published documents,
including this final notice, that clearly lay out the methodology,
assumptions, analysis, and results, as well as describe in detail
comments received from stakeholders and DOE's responses.
Miller also stated that DOE's proposal does not maintain
flexibility and freedom of choice for purchasers of GSFLs and IRLs, and
the resulting benefits do not justify the costs as required both by
statute and by Executive Order. (Miller, No. 50 at p. 12)
DOE determined that the proposed levels in the NOPR and the
standard being adopted do not lessen the utility or performance of
GSFLs and IRLs. DOE has ensured that the typical characteristics of
lamps meeting the existing standard, such as shape, CCT, CRI, lifetime,
and lumen package are represented at the higher efficacy levels
proposed in the NOPR and being adopted in this rule. Further, consumers
will continue to have a range of purchasing choices under the adopted
standards. For further comments and discussion on the impact of higher
efficacy levels on product availability, see section VI.D.2 for GSFLs
and section VI.D.3 for IRLs.
Miller stated that if DOE proceeds to issue the standards as
proposed in the NOPR, DOE should commit to retrospective review to
assess whether the rule meets the statutory standard of achieving the
maximum improvement in energy efficiency that is both technologically
feasible and economically justified, while also resulting in a
significant conservation of energy. Miller outlined a number of metrics
to consider in a retrospective review. These included quantifying
environmental benefits and security, reliability, and costs of
maintaining the nation's energy system as a result of standards; and
potentialities such as a rebound effect, impedance of LED technology,
adverse impacts on manufacturers, increased mercury, and loss of
product utility and optionality as a result of standards. (Miller, No.
50 at p. 12) Miller also noted that DOE should commit to measuring
metrics and assumptions of this final rule on a regular basis and
collecting information for this purpose. (Miller, No. 50 at p. 9)
As stated in DOE's Final Plan for the Retrospective Review of
Existing Rules, dated August 23, 2011,\80\ DOE is committed to
maintaining a consistent culture of retrospective review and analysis.
In the plan, DOE sets forth a process for identifying significant rules
that are obsolete, unnecessary, unjustified, excessively burdensome, or
counterproductive. Once such rules have been identified, DOE will,
after considering public input on any proposed change, determine what
action is necessary or appropriate. DOE will continually engage in
review of its rules to determine whether there are burdens on the
public that can be avoided by amending or rescinding existing
requirements. DOE's consideration of appliance standards within the
context of retrospective review is discussed at pages 9-10 of the final
plan. Since the release of its final plan, DOE has issued a number of
reports documenting its progress in the retrospective review of its
regulations.\81\ DOE has also issued a number of Requests for
Information seeking input from the public on its retrospective review
efforts, most recently on July 3, 2014. 79 FR at 37963 (April 29,
2014). DOE encourages all interested parties to provide input in DOE's
retrospective review process.
---------------------------------------------------------------------------
\80\ Available at http://energy.gov/gc/services/open-government/restrospective-regulatory-review.
\81\ These reports are also available at http://energy.gov/gc/services/open-government/restrospective-regulatory-review.
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CA IOUs and ASAP endorsed the NOPR analyses and stated they would
support a final rule similar to the rule proposed in the NOPR. (CA
IOUs, Public Meeting Transcript, No. 49 at p. 245; ASAP, Public Meeting
Transcript,
[[Page 4103]]
No. 49 at pp. 16, 244) EEOs stated the proposed standards would build
on the achievements of the 2009 Lamps Rule, which had increased minimum
efficacy by 19 percent for GSFLs and 62 percent for IRLs, by further
increasing efficacy by 4 percent for GSFLs and 8 percent for IRLs.
Specifically, EEOs highlighted the potential savings from the proposed
standards for GSFLs, but noted that potential savings from proposed IRL
standards are also significant. EEOs also pointed out that the proposed
standards were cost-effective for both commercial and residential
consumers. (EEOs, No. 55 at p. 2) GE, however, found the standard
levels proposed in the NOPR problematically high, especially with
regards to the increased burden on the industry. (GE, Public Meeting
Transcript, No. 49 at p. 243)
When considering establishing new or amending existing standards,
DOE weighs the benefits and burdens of such standards. In the NOPR, for
GSFL TSL 5 and IRL TSL 1, DOE determined that the benefits of energy
savings, positive NPV of total consumer benefits, positive impacts on
consumers, emission reductions and the estimated monetary value of the
emissions reductions would outweigh the potential reduction in industry
value. In the following sections DOE discusses comments received
specifically on the proposed standards for GSFLs and IRLs.
1. GSFLs Proposed Standards
DOE also received several comments specific to the GSFL standards
proposed in the NOPR. ASAP noted that the proposed GSFL standards, in
combination with the GSFL standards from the 2009 Lamps Rule and the
ballast standards from the 2011 Ballast Rule, would result in
substantial energy savings, in particular due to their impact on the
commercial sector. ASAP stated and CA IOUs agreed that this is an
example of how standards can couple with utility-based and voluntary
programs to shift lighting efficiency. (ASAP, Public Meeting
Transcript, No. 49 at pp. 13-15; CA IOUs, Public Meeting Transcript,
No. 49 at p. 20) CA IOUs further commented that the proposed GSFL
standards are designed to push the fluorescent lamp market to ``best-
in-class'' and the resulting energy savings estimate of 3.5 quads is
significant. (CA IOUs, No. 56 at pp. 1-2) NEEP noted that the proposed
max-tech efficacy levels for GSFL would bring over 2 TWhs of annual
electricity reduction to the NEEP region in 2020 and more than 100 MWs
of capacity reductions (9.8TWhs and 573 MW nationally). NEEP continued
that the very aggressive energy efficiency programs administered in the
region have made the proposed standards practical. (NEEP, No. 57 at p.
1)
NEMA, however, disagreed, stating that the proposed higher
performance levels would result in the unavailability of extended life
lamps, inability for manufacturers to repeatedly and consistently
produce products for testing and enforcement problems, price increases,
minimal efficiency gains, consumer diversion to full-wattage lamps with
reduced energy savings, and a significant financial impact to U.S.
industry without sufficient payback. (NEMA, No. 54 at p. 16)
As previously noted, in the NOPR analysis, DOE proposed TSL 5 for
GSFLs, which required adopting the proposed EL 2 for the 4-foot MBP
lamps, 8-foot slimline lamps, 8-foot RDC HO, 4-foot T5 MiniBP SO, and
EL 1 for 4-foot T5 MiniBP HO. 79 FR 24068, 24174 Based on an assessment
of catalog and certification data, DOE found that these levels are
technologically feasible (see chapter 5 of the NOPR TSD for the further
details on the engineering analysis) and maintained the GSFLs with
typical lifetimes (see section VI.D.2.g for further discussion).
Although DOE proposed TSL 5 in the NOPR, as discussed in section
VII.C.1, in this final rule DOE found that the burdens of TSL 5
outweigh the benefits and is therefore adopting a lower standard level.
NEMA recommended alternative standards for the GSFL product classes
than those proposed in the NOPR. For lamps with CCT <= 4,500 K, NEMA
recommended that the current standards be maintained for the 4-foot MBP
(89.0 lm/W) and 2-foot U-shaped (84.0 lm/W) product classes and
standards be amended to 98.0 lm/W for the 8-foot SP slimline product
class; 94.0 lm/W for the 8-foot RDC HO product class; 90.0 lm/W for the
4-foot T5 MiniBP SO product class; and 80.0 lm/W for the 4-foot T5
MiniBP HO product class. (NEMA, No. 54 at pp. 27-28) For lamps with CCT
> 4,500 K, NEMA recommended that the current standards be maintained
for 4-foot MBP lamps (88 lm/W); 2-foot U-shaped lamps (81 lm/W); and 8-
foot SP slimline lamps (93.0 lm/W) and standards be amended to 90 lm/W
for the 8-foot RDC HO product class; 84 lm/W for the 4-foot T5 MiniBP
SO; and 76 lm/W for the 4-foot T5 MiniBP HO product class. (NEMA, No.
54 at p. 28)
CA IOUs noted that DOE has proposed a standard for the 4-foot MBP
lamps that can be achieved by an 800 series, full-wattage, and high-
lumen T8 lamp. CA IOUs mentioned that their rebate and incentive
programs have encouraged the adoption of these third generation T8
lamps and have utilized them in cost-effective installations to achieve
large energy savings, and also mentioned that the standards would
further encourage this market transformation without adversely
impacting product performance. (CA IOUs, No. 56 at pp. 1-2) NEEP
commented that about two-thirds of the savings would be lost if the
levels of the 4-foot MBP lamps were weakened, therefore DOE should
maintain these levels as the higher performing lamps are available and
cost-effective. (NEEP, No. 57 at p. 1)
Based on catalog and certification data, for the 4-foot MBP product
class DOE determined that there were two higher efficacy levels than
the existing standard: EL 1 representing a standard 800 series full
wattage lamp and EL 2 representing an improved 800 series full wattage
lamp in which the phosphor mix and/or coating is enhanced to increase
efficacy. DOE developed standards for the 2-foot U-shaped product class
by scaling from standards for the 4-foot MBP product class. DOE
developed a scaling factor based on the efficacy difference of
comparable 4-foot MBP and 2-foot U-shaped product lines, and in this
final rule confirmed this scaling factor using updated certification
data. For this final rule, DOE used updated catalog and certification
data for all products and confirmed the higher efficacy levels above
the existing standard for the 4-foot MBP and 2-foot U-shaped lamps.
Therefore, DOE found that higher efficacy levels than the current
standards for the 4-foot MBP, 2-foot U-shaped, and 8-foot SP slimline
lamps are feasible and reflect the performance of products currently on
the market. See section VI.D.2.g for the detailed engineering analysis
of these lamp types.
In the NOPR for lamps with CCT <= 4,500 K, the proposed TSL 5
required EL 2 at 92.4 lm/W for 4-foot MBP lamps; EL 2 at 99.0 lm/W for
the 8-foot SP slimline lamps; EL 2 at 97.6 lm/W for the 8-foot RDC HO
lamps; EL 2 at 97.1 lm/W for the 4-foot T5 MiniBP SO lamps; and EL 1 at
82.7 lm/W for the 4-foot T5 MiniBP HO lamps. DOE determined the
efficacies at these levels based on commercially available lamps using
both catalog and certification data, and therefore found that these
efficacies are accurate representation of higher performing products on
the market. For this final rule, DOE analyzed updated catalog and
certification data and confirmed these efficacy levels with the
exception of T5 MiniBP SO lamps which was adjusted to be 95 lm/W
[[Page 4104]]
based on certification data. See section VI.D.2.g for the detailed
engineering analysis of these lamps.
In the NOPR, for lamps with CCT > 4,500 K, the proposed TSL 5
required EL 2 at 90.6 lm/W for 4-foot MBP lamps; EL 2 at 94.1 lm/W for
the 8-foot SP slimline lamps; EL 2 at 95.6 lm/W for the 8-foot RDC HO
lamps; EL 2 at 91.3 lm/W for the 4-foot T5 MiniBP SO lamps; and EL 1 at
78.6 lm/W for the T5 MiniBP HO lamps. Standards for GSFLs with CCT >
4,500 K were scaled from corresponding GSFLs with CCT <= 4,500 K. In
the NOPR, DOE developed scaling factors based on the differences in
efficacies between less than 4,500 K and greater than 4,500 K
comparable products on the market. DOE verified the developed scaling
factors using certification data. For this final rule, DOE adjusted
certain scaling factors based on updated certification data, which
resulted in the following changes for lamps with CCT > 4,500 K: EL 2
for the 4-foot MBP was adjusted to 89.3 lm/W; EL 2 for the 8-foot SP
slimline was adjusted to 96.0 lm/W; EL 2 for the 8-foot RDC HO lamps
was adjusted to 93.7 lm/W; EL 2 for the 4-foot T5 MiniBP SO was
adjusted to 89.3 lm/W; and EL 1 for the T5 MiniBP HO was adjusted to
76.9 lm/W. See chapter 5 of this final rule TSD for the detailed
engineering analysis of GSFL scaling.
DOE conducted a comprehensive analysis of all GSFL products
available on the market and utilized both catalog and certification
data to determine the efficacy levels for each product class. After
weighing the benefits and burdens in this final rule analysis, DOE is
adopting TSL 4 which will require EL 2 for the 4-foot MBP lamps and the
4-foot T5 MiniBP SO lamps; EL 1 for the 4-foot T5 MiniBP HO lamps; and
maintain existing standards for the 8-foot SP slimline and 8-foot RDC
HO lamps. See section VII.C.1 for a discussion on the benefits and
burdens of GSFL standards.
People's Republic of China (P.R. China) commented that for the 8-
foot SP slimline lamps with a CCT > 4,500 K the standard proposed in
the NOPR increases existing standards by 1.2 percent, while for the 4-
foot T5 MiniBP SO lamps with a CCT <= 4,500 K the existing standard is
increased by 12.9 percent. P.R. China questioned the range of increase
in efficacy in the proposed standards for these two lamp types. (P.R.
China, No. 58, p. 3)
As mentioned previously, DOE considers the 8-foot SP slimline with
CCT > 4,500 K and the 4-foot T5 MiniBP SO with CCT <= 4,500 K as two
separate product classes due to their difference in utility and
efficacy. See section VI.C.1 for more details on GSFL product classes.
Based on its review of catalog and certification data, DOE determined
that there were 4-foot T5 MiniBP SO lamps available on the market with
efficacies much higher than their existing standard compared to the
commercially available 8-foot SP slimline lamps.
NEMA commented that rare earth availability remains volatile;
particularly the phosphor mix used in argon-based 92+ lm/W lamps. NEMA
remarked that forcing all products to use specialized rare earth
phosphor mixes is extremely risky for argon-based lamps as the proposed
standard is at the high end of the technology limits, and DOE cannot
risk having only krypton based lamps available due to their lack of
dimmability. Thus, EL 2 cannot be used for 4-foot MBP lamps. (NEMA, No.
54 at p. 14)
EL 2 for the 4-foot MBP lamps was based on the performance of full
wattage, argon-based lamps that are currently on the market. DOE
acknowledges that supply and demand of rare earth phosphors should be
considered when evaluating amended standards for GSFLs. DOE conducted
LCC and NIA sensitivities for a scenario with increased rare earth
phosphor prices in the NOPR. With regards to impacts on consumers, DOE
found that proposed efficacy levels remained achievable even with
increased phosphor prices. In the NIA, DOE found that the ranking of
TSLs by NPV remained unchanged in the high rare earth phosphor price
scenario. For this final rule, DOE conducted these sensitivities with
an updated phosphor price and reached the same conclusions. See chapter
12 and appendix 7B of the final rule TSD for more detail on DOE's
assessment of impact of rare earth phosphors.
DOE also received a comment regarding the LCC results for GSFLs and
the impact on the proposed standard. For 8-foot RDC HO lamps,
Westinghouse questioned the economic justification behind consumers
losing 16-17 percent of the value of the product over its average
lifetime. (Westinghouse, Public Meeting Transcript, No. 49 at p. 152)
The LCC analysis is one of the factors that DOE considers when
weighing the benefits and burdens of TSLs. In the NOPR the 8-foot RDC
HO product class showed negative LCC savings at the proposed TSL 5. In
the final rule, DOE is adopting TSL 4 which does not amend the standard
level for 8-foot HO lamps. As discussed below, TSL 4 includes a
combination of ELs that maximizes NPV; in addition to 8-foot HO lamps,
TSL 4 also does not amend the standard level for 8-foot slimline lamps.
Additionally, DOE received a comment on choosing between TSL 4 and
TSL 5, as presented in the NOPR. NEMA commented that TSL 5 is very
similar to TSL 4 in national energy use, but has a significantly higher
conversion cost for manufacturers and the most negative INPV. NEMA
commented that the NOPR shows a modest national energy savings
difference between TSL 4 and TSL 5 in the proposed GSFL rule, as
computed by the DOE for the NOPR (3.0 v. 3.5 quads over 30 years). NEMA
claimed that the reason for this is because, considering all the
assumptions and estimates used to calculate the savings, the energy
savings estimate of both levels is within +/- 5 percent or well within
the uncertainty of both projections. (NEMA, No. 54 at p. 27) NEMA
further claimed that there is more manufacturing investment required to
go from TSL 4 ($13M) to TSL 5 ($38.6M) (79 FR at 24160, Table VII.30
[April 29, 2014]), and DOE has a legislative and executive mandated
obligation to reduce or eliminate the regulatory burden of TSL 5. NEMA
claimed that TSL 5 would require an additional investment in production
lines that are projected to decline in future years without generating
meaningful incremental national energy savings and that this is not an
acceptable or reasonable decision for the U.S. government to make. NEMA
commented that the money would be better invested into research in new
technologies with a larger energy savings impact. (NEMA, No. 54 at p.
27)
NEMA noted that that primary difference between TSL 4 and TSL 5 is
that the 8-foot slimline and 8-foot RDC HO categories jump from EL 0 to
EL 2, but NEMA added that they should not be moved any higher than EL
1, as they would not increase national energy savings and will be
costly to the manufacturer. NEMA further commented that it is
unreasonable to assume that manufacturers or consumers would make the
investment to switch from a T8 to T5 system, nor from 8-foot
fluorescent systems to T5 systems, due to the cost involved with their
lack of interchangeability. NEMA stated that DOE must remove these
false assumptions and restructure the energy savings projections.
(NEMA, No. 54 at p. 15)
In the NOPR, TSL 4 represented the maximum NPV that was achievable
in the analysis from any combination of ELs. DOE determined that the
increase in energy savings at TSL 5 compared to TSL 4, as well as
generally positive
[[Page 4105]]
impact on consumers, emission reductions and the estimated monetary
value would outweigh the potential reduction in industry value
experienced at TSL 5 compared to TSL 4. Therefore, DOE proposed TSL 5
as it represented maximum national energy savings. Further, the
uncertainty in key variables, such as energy price forecast or product
price trends would generally affect TSL 4 and TSL 5 in the same way, so
DOE would expect the relative ranking to remain.
The switching from 4-foot MBP or 8-foot SP slimline systems was
allowed only in new construction and renovation and based on DOE
research that indicated there are comparable luminaires. DOE is aware
that there are physical and optical differences between T8 and T5 lamps
and the potential for substitution of 4-foot MBP T8 or 8-foot SP
slimline T8 with T5 MiniBP SO lamps is only assumed at the time of new
construction and renovation, when a new luminaire would be specified.
DOE's analysis indicates that there exist T5 luminaires that compete
directly with 4-foot MBP T8 luminaires in most applications in the
largest luminaire markets (e.g., commercial offices, education,
industrial) and in some cases, luminaire manufacturers offer
essentially identical luminaires in 4-foot MBP T8 and T5 MiniBP
versions. For these same reasons, DOE also assumed switching between 8-
foot SP slimline with T5 MiniBP SO is possible. See appendix 11C of the
final rule TSD for examples of these luminaires and a discussion of
DOE's analysis of the substitution potential for 4-foot MBP and T5
MiniBP SO Lamps.
Further, in this final rule, DOE modified TSL 4 slightly so that
maximum NPV is achieved from a combination of ELs that minimizes the
net burden on a consumer for a product class that may have negative NPV
in the absence of product class switching (e.g., consumers substituting
a T8 system with T5 system). This modification resulted in only one EL
change between the TSL 4 proposed in the NOPR and the TSL 4 presented
in this rule: For the 8-foot RDC HO product class the efficacy level in
the TSL 4 presented for this final rule is at the baseline rather than
EL 1. DOE is adopting TSL 4 in this final rule for GSFLs. See section
VII.C.1 for a discussion on the benefits and burdens of GSFL standards.
2. IRL Proposed Standards
DOE received several comments regarding the proposed TSL 1 for IRLs
in the NOPR. NEMA commented that 130 V lamps are no longer available,
so there is no reason to establish a new standard for them since there
will be no energy savings. (NEMA, Public Meeting Transcript, No. 49 at
pp. 37-38) Philips added that 130 V lamps cannot be produced. (Philips,
Public Meeting Transcript, No. 49 at p. 37) GE stated that the proposed
130 V lamp standard exceeds the capability of making a practical lamp
as the proposed efficacy level of the 130 V lamps is 15 percent higher
than that for the 120 V lamps. GE added that the only way to reach this
efficacy is to decrease lifetime by two thirds if operated at 120 V and
even lower if operated at 130 V, making it impractical to sell. GE
stated that the proposed regulations raise the efficacy level 5 percent
higher and that this is just as impossible as the last standard. (GE,
Public Meeting Transcript, No. 49 at pp. 40-42)
CA IOUs disagreed, stating that not setting a standard for 130 V
lamps leaves the door open to potential loopholes. CA IOUs cited the
example that DOE exempted certain BR and ER lamps and these lamps have
grown in market share. Therefore, the CA IOUs stated that products that
are not on the market now but might be in the future should be
regulated. (CA IOUs, Public Meeting Transcript, No. 49 at p. 39)
DOE is aware that at the time of this final rule there are no 130 V
IRLs covered by this rulemaking on the market. However, DOE did not
find any evidence that permanently precludes these lamps from becoming
commercially available. DOE's research also does not indicate that the
lamps are not being manufactured solely due to technological barriers.
DOE remains concerned that if 130 V lamps do become available and
standards for 120 V lamps are raised and not for the 130 V lamps, there
may be a potential migration to the 130 V lamps that would result in
increased energy consumption. See section VI.C.2 and VI.D.3.f for
further discussion. Therefore, when considering higher efficacy
standards for the less than 125 V product class in TSL 1, DOE also
considered higher efficacy standards for the greater than or equal to
125 V product class.
DOE also received overall comments on the merit of proposing TSL 1,
which represented max tech (EL 1) for IRLs. CA IOUs and NEEP commented
that they support the DOE's proposal to increase the stringency of IRL
standards, but stated that the standards proposed in the NOPR could be
higher. (NEEP, No. 57 at p. 3; CA IOU, No. 56 at p. 4) NEEP stated that
additional ELs should be established that represent the maximum
technologically feasible level and typically evaluates the maximum
commercially available level. NEEP noted that there were products in
DOE's certification database with higher efficacies than the proposed
standard, which should have been considered in the analysis. (NEEP, No.
57 at p. 3) CA IOUs agreed with DOE's proposal to adopt a standard that
can be met with HIR design strategy. CA IOUs continued that they have
incentive programs that promote a shift towards higher efficiency
technology, such as LEDs, but are not able to promote and incentivize
the highest efficacy incandescent products. CA IOUs mentioned that DOE
would be the biggest driver in promoting this shift to high-efficacy
IRLs, and noted that the HIR technology is a proven and cost-effective
design. (CA IOUs, No. 56 at p. 4) ASAP stated that the proposed IRL
standard will help ensure that buyers have a choice of efficient
options in that market place, including LEDs or very efficacious
incandescent lamps. (ASAP, Public Meeting Transcript, No. 49 at pp. 15-
16)
NEMA, however, disagreed, stating that the limited benefits to the
nation from amended standards for IRLs do not justify the burden on the
manufacturers and consumers of IRLs. With regards to negative impacts
on manufacturers, NEMA presented a graph that plotted the percentage
INPV and the estimated energy savings from DOE's appliance efficiency
rulemakings since 2008. NEMA also calculated and plotted the midpoint
average percentage INPV as -10.95 percent and average projected energy
savings at 2.156 of these rulemakings. NEMA noted on this graph that
with the exception of the proposed GSFL standards, all lighting
rulemakings have resulted in INPV more negative than the midpoint INPV,
and the proposed IRL standards are the second most severe in negative
impacts to manufacturers. Further, on NEMA's graph, the proposed IRLs
standards result in the lowest energy savings compared to the average
projected energy savings of 2.156 quads. NEMA stated that on this basis
alone, the proposed IRL standards deviate from the norms and should not
be deemed economically justified. NEMA also provided a summary of the
negative INPV from various product rulemakings that result in a
cumulative regulatory burden on IRL manufacturers. NEMA noted that the
imposition of the burden of the proposed IRL standards in addition to
this cumulative regulatory burden called for ``alternatives to direct
regulation'' per Executive Order 12866, which in this case would be to
not amend the existing IRL standards as only one TSL is proposed. NEMA
also
[[Page 4106]]
stated that the IRL standards proposed in the NOPR would result in an
increase in prices that would drive consumers to alternate technologies
and manufacturers to exit the IRL market and result in the loss of all
or most domestic employment in IRL manufacturing. (NEMA, No. 54 at pp.
2-4)
With regards to impact on consumers, NEMA emphasized that the
proposed IRL standards would require IRL consumers to accept a 30-50
percent increase in price. Further, NEMA predicted that due to initial
costs, consumers would choose to purchase the less efficacious,
unregulated higher wattage IRLs. (NEMA, No. 54 at pp. 2, 10) NEMA
suggested that regulations allowing lower priced lamps at 60 W or below
as substitutes for 90 W IRLs would move consumers to more energy
efficient options. In contrast, the proposed IRL standards would limit
consumer options to higher-end commercial products that utilize HIR.
NEMA explained that halogen PAR lamps would not meet the proposed
standards unless life was reduced by at least 20 percent, which would
be a loss to consumer utility. Therefore, NEMA concluded that for these
reasons the IRL standards proposed in the NOPR would increase rather
than decrease national energy use. (NEMA, No. 54 at pp. 2, 10) GE noted
the positive LCC saving results for IRLs were likely based mainly on
commercial customers that use PAR38 lamps and would be very different
for the residential consumers. GE questioned how a standard that has no
economic benefits could be adopted. (GE, Public Meeting Transcript, No.
49 at p. 152)
DOE is aware that TSL 1 for IRLs resulted in negative impacts on
industry and would increase end-user prices. Regarding the LCC
assessment, DOE analyzed both the IRL commercial and residential
sectors at TSL 1 and found them to be positive for both representative
lamp units. As noted previously, in addition to the impact on
manufacturers and consumers, DOE weighed other factors when determining
whether or not TSL 1 was economically justified. In the NOPR, DOE found
that at TSL 1 for IRLs, the benefits of energy savings, positive NPV of
consumer benefits, positive impacts on consumers (as indicated by
positive average LCC savings and the large percentage of consumers who
would experience LCC benefits), emission reductions and the estimated
monetary value of the emissions reductions would outweigh the potential
reduction in industry value. In this final rule analysis, after
reevaluating the factors considered in weighing the benefits and
burdens of a potential standard, DOE is not amending standards for IRLs
in this rule. See section VII.C.3 for a discussion on the benefits and
burdens of IRL standards.
VII. Analytical Results
A. Trial Standard Levels
For the final rule, DOE develops TSLs for consideration. The GSFL
and IRL TSLs are formed by grouping different efficacy levels, which
are potential standard levels for each product class. TSL 5 is composed
of the max tech efficacy levels. TSL 4 is composed of the combination
of efficacy levels that yield the maximum NPV. TSL 3 is composed of
efficacy levels that yield the maximum energy savings without using any
of the EL 2 levels. For both TSL 4 and TSL 3 efficacy level
combinations, to ensure that max NES and NPV were based on consumer
options to save energy for each lamp type, DOE did not consider an
efficacy level for a product class that did not result in energy
savings from options within the product class. TSL 2 is composed of the
efficacy levels that would bring all product classes to approximately
the same level of rare earth phosphor. TSL 1 is composed of the levels
that represent the least efficacious commercially available lamps. For
IRLs, DOE considered one TSL, because only one efficacy level was
analyzed (Table VII.2).
DOE used data on the representative product classes from the
engineering and pricing analyses described in section VI.D.2.b for
GSFLs and section VI.D.3.a for IRLs to evaluate the benefits and
burdens of each of the GSFL and IRL TSLs. DOE analyzed the benefits and
burdens by conducting the analyses described in section VII.C for each
TSL. Table VII.1 presents the GSFL TSLs analyzed and the corresponding
efficacy level for each GSFL representative product class. Table VII.2
presents the IRL TSL analyzed and the corresponding efficacy level for
the representative IRL product class.
Table VII.1--Composition of TSLs for GSFLs by Efficacy Level
----------------------------------------------------------------------------------------------------------------
TSL 2 Same
Representative product class TSL 1 Current phosphor TSL 3 Best non- TSL 4 Max NPV TSL 5 Max tech
market min level EL 2
----------------------------------------------------------------------------------------------------------------
1. 4-foot medium bipin, CCT 0 0 1 2 2
<=4,500 K......................
2. 8-foot single pin slimline, 0 1 0 0 2
CCT <=4,500 K..................
3. 8-foot RDC high output, CCT 1 2 0 0 2
<=4,500 K......................
4. 4-foot T5, Mini bipin 1 1 1 2 2
standard output, CCT <=4,500 K.
5. 4-foot T5, Mini bipin high 1 1 1 1 1
output, CCT <=4,500 K..........
----------------------------------------------------------------------------------------------------------------
Table VII.2--Composition of TSLs for IRLs by Efficacy Level
------------------------------------------------------------------------
Representative product class TSL 1
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V.......... 1
------------------------------------------------------------------------
B. Economic Justification and Energy Savings
1. Economic Impacts on Individual Consumers
DOE analyzed the economic impacts on GSFL and IRL consumers by
looking at the effects standards would have on the LCC and PBP. DOE
also examined the impacts of potential standards on consumer subgroups.
These analyses are discussed in the following subsections.
a. Life-Cycle Cost and Payback Period
Consumers affected by new or amended standards usually experience
higher purchase prices and lower operating costs. Generally, these
impacts on individual consumers are best captured by changes in LCCs
and by the payback period. DOE's LCC and PBP analyses provide key
outputs for each TSL, which are reported by product class in Table
VII.3 through Table VII.15. DOE designed the LCC analysis around lamp
purchasing events and calculated the LCC savings relative
[[Page 4107]]
to the baseline for each lamp replacement event separately in each lamp
product class. Each table includes the average total LCC and the
average LCC savings, as well as the fraction of product consumers for
which the LCC will either decrease (net benefit), or increase (net
cost) relative to the base-case forecast. When an EL results in
``positive LCC savings,'' the LCC of the lamp or lamp-and-ballast
system is less than the LCC of the baseline lamp or lamp-and-ballast
system, and the consumer economically benefits. When an EL results in
``negative LCC savings,'' the LCC of the lamp or lamp-and-ballast
system is higher than the LCC of the baseline lamp or lamp-and-ballast
system, and the consumer is adversely affected economically. The last
outputs in the tables are the mean PBPs for the consumer that is
purchasing a design compliant with the TSL. Entries of ``NER'' indicate
standard levels that do not reduce operating costs, which prevents the
consumer from recovering the increased purchase cost. The PBP cannot be
calculated in those instances because the denominator of the PBP
equation is 0. Because LCC savings and PBP are not relevant at the
baseline level, results are ``N/A'' (not applicable) for the baselines.
Chapter 8 of the final rule TSD provides a detailed description of the
LCC and PBP analysis and the results. Appendix 8B of the NOPR TSD
presents Monte Carlo simulation results performed by DOE as part of the
LCC analysis and the appendix also presents sensitivity results, such
as LCC savings under the AEO 2014 high-economic-growth and low-
economic-growth cases.
The results for each TSL are relative to the energy-use
distribution in the base case (no amended standards), based on energy
consumption under conditions of actual product use. The rebuttable-
presumption PBP is based on test values under conditions prescribed by
the DOE test procedure, as required by EPCA. (42 U.S.C.
6295(o)(2)(B)(iii))
General Service Fluorescent Lamps
Table VII.3 through Table VII.11 present the results for each of
the five GSFL representative product classes that DOE analyzed.
Specifically, these were the 4-foot MBP product class, 4-foot MiniBP SO
product class, 4-foot MiniBP HO product class, 8-foot SP slimline
product class, and 8-foot RDC HO product class. For GSFLs, results for
the most common sector for each product class are presented. Chapter 8
of the final rule TSD provides the LCC and PBP results for each product
class in all relevant sectors.
[[Page 4108]]
Table VII.3--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option \82\ Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 17.38 126.22 143.80 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 90.0 Inst. 34.60 126.22 147.97 -4.17 100.0 0 NER
EL 2.............. 93.0 32.5 W T8 & 0.88 BF 30.12 105.71 136.03 7.77 0.0 100.0 3.1
EL 2.............. 95.4 Inst. 27.03 126.22 153.45 -9.65 100.0 0.0 NER
EL 2.............. 96.0 26.6 W T8 & 0.88 BF 24.25 113.41 137.86 5.94 0.0 100.0 2.6
Inst.
32.5 W T8 & 0.88 BF
Inst.
28.4 W T8 & 0.88 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 60.77 126.00 167.94 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 90.0 Inst. 77.99 112.69 158.80 9.14 0.0 100.0 0.4
Replacement. EL 2.............. 93.0 32.5 W T8 & 0.78 BF 73.51 105.51 160.20 7.74 0.0 100.0 3.1
EL 2.............. 95.4 Inst. 70.42 109.77 161.36 6.58 0.0 100.0 2.9
EL 2.............. 96.0 26.6 W T8 & 0.88 BF 67.64 108.63 157.45 10.49 0.0 100.0 1.9
Inst.
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 63.61 126.00 169.54 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 90.0 Inst. 80.84 112.69 160.40 9.14 0.0 100.0 0.4
Purchase. EL 2.............. 93.0 32.5 W T8 & 0.78 BF 76.35 105.51 161.79 7.74 0.0 100.0 3.1
EL 2.............. 95.4 Inst. 73.26 109.77 162.96 6.58 0.0 100.0 2.9
EL 2.............. 96.0 26.6 W T8 & 0.88 BF 70.49 108.63 159.04 10.49 0.0 100.0 1.9
Inst.
32.5 W T8 & 0.77 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\82\ The lifetimes of the representative lamps units range from 4.8 to 5.5 years.
Table VII.4--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option \83\ Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 17.38 200.67 218.22 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 90.0 Inst. 33.47 200.67 225.18 -6.96 100.0 0.0 NER
EL 2.............. 93.0 32.5 W T8 & 0.88 BF 30.12 168.52 198.82 19.41 0 100.0 3.1
EL 2.............. 95.4 Inst. 27.03 200.67 227.87 -9.65 100.0 0.0 NER
EL 2.............. 96.0 26.6 W T8 & 0.88 BF 24.25 180.59 205.02 13.20 0.0 100.0 2.6
Inst.
32.5 W T8 & 0.88 BF
Inst.
28.4 W T8 & 0.88 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 61.98 200.67 255.15 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 90.0 Inst. 78.07 200.67 262.11 -6.96 100.0 0.0 NER
Replacement. EL 1.............. 90.0 32.5 W T8 & 0.88 BF 78.07 168.05 229.49 25.66 0.0 100.0 0.3
EL 2.............. 93.0 Inst. 74.72 168.52 235.74 19.41 0.0 100.0 3.1
EL 2.............. 95.4 32.5 W T8 & 0.72 BF 71.63 200.67 264.80 -9.65 100.0 0.0 NER
EL 2.............. 95.4 Inst. 71.63 168.05 232.18 22.97 0.0 100.0 2.3
26.6 W T8 & 0.88 BF
Inst.
32.5 W T8 & 0.88 BF
Inst.
32.5 W T8 & 0.72 BF
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.72 BF 68.85 180.59 241.95 13.20 0.0 100.0 2.6
Inst.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 64.82 200.67 257.51 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 90.0 Prog. 80.91 200.67 264.46 -6.96 100.0 0.0 NER
Purchase. EL 1.............. 90.0 32.5 W T8 & 0.88 BF 80.91 168.05 231.84 25.66 0.0 100.0 0.3
EL 2.............. 93.0 Prog. 77.56 168.52 238.10 19.41 0.0 100.0 3.1
32.5 W T8 & 0.72 BF
Prog.
26.6 W T8 & 0.72 BF
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.88 BF 74.47 200.67 267.15 -9.65 100.0 0.0 NER
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.72 BF 74.47 168.05 234.53 22.97 0.0 100.0 2.3
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.88 BF 71.70 180.59 244.30 13.20 0.0 100.0 2.6
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\83\ The lifetimes of the representative lamps units range from 6.9 to 9.2 years.
[[Page 4109]]
Table VII.5--LCC and PBP Results for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option \84\ Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 28.26 248.52 277.17 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 90.0 Inst. 57.07 248.52 284.37 -7.21 100.0 0.0 NER
EL 2.............. 93.0 32.5 W T8 & 0.87 BF 53.75 208.09 262.22 14.94 0.0 100.0 3.1
EL 2.............. 95.4 Inst. 47.56 248.52 296.46 -19.30 100.0 0.0 NER
EL 2.............. 96.0 26.6 W T8 & 0.87 BF 42.01 265.66 265.66 11.51 0.0 100.0 2.7
Inst.
32.5 W T8 & 0.87 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 87.41 242.00 303.87 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 90.0 Inst. 116.22 220.90 289.98 13.89 0.0 100.0 0.5
Replacement. EL 2.............. 93.0 32.5 W T8 & 0.78 BF 112.90 202.40 289.76 14.12 0.0 100.0 3.2
EL 2.............. 95.4 Inst. 106.71 213.66 294.83 9.05 0.4 99.6 3.4
EL 2.............. 96.0 26.6 W T8 & 0.87 BF 101.16 217.26 292.88 10.99 0.0 100.0 2.7
Inst.
32.5 W T8 & 0.74 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 90.25 242.00 305.47 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 90.0 Inst. 119.06 220.90 305.47 13.89 0.0 100.0 0.5
Purchase. EL 2.............. 93.0 32.5 W T8 & 0.78 BF 115.74 202.40 291.58 14.12 0.0 100.0 3.2
Inst. 291.35
26.6 W T8 & 0.87 BF
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.74 BF 109.55 213.66 296.42 9.05 0.4 99.6 3.4
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 104.00 217.26 294.47 10.99 0.0 100.0 2.7
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\84\ The lifetimes of the representative lamps units range from 4.8 to 5.5 years.
Table VII.6--LCC and PBP Results for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option \85\ Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 28.26 396.53 425.14 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 90.0 Prog. 55.17 396.53 436.96 -11.82 100.0 0.0 NER
EL 2.............. 93.0 32.5 W T8 & 0.89 BF 53.75 332.51 386.60 38.54 0.0 100.0 3.1
EL 2.............. 95.4 Prog. 47.56 396.53 444.44 -19.30 100.0 0.0 NER
EL 2.............. 96.0 26.6 W T8 & 0.89 BF 42.01 356.54 398.90 26.24 0.0 100.0 2.7
Prog.
32.5 W T8 & 0.89 BF
Prog.
28.4 W T8 & 0.89 BF
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 89.27 396.53 475.65 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 90.0 Prog. 116.18 378.87 469.82 5.83 0.3 99.7 1.0
Replacement. EL 2.............. 93.0 32.5 W T8 & 0.87 BF 114.75 332.51 437.11 38.54 0.0 100.0 3.1
EL 2.............. 95.4 Prog. 108.57 378.87 477.30 -1.64 74.2 25.8 8.4
EL 2.............. 96.0 32.5 W T8 & 0.89 BF 103.02 340.36 433.24 42.42 0.0 100.0 1.9
Prog.
32.5 W T8 & 0.87 BF
Prog.
28.4 W T8 & 0.87 BF
Prog.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 92.11 396.53 478.01 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 90.0 Prog. 119.02 378.87 472.17 5.83 0.3 99.7 1.0
Purchase. EL 2.............. 93.0 32.5 W T8 & 0.87 BF 117.59 332.51 439.47 38.54 0.0 100.0 3.1
EL 2.............. 95.4 Prog. 111.41 378.87 479.65 -1.64 74.2 25.8 8.4
EL 2.............. 96.0 32.5 W T8 & 0.89 BF 105.86 340.36 435.59 42.42 0.0 100.0 1.9
Prog.
32.5 W T8 & 0.87 BF
Prog.
28.4 W T8 & 0.87 BF
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\85\ The lifetimes of the representative lamps units range from 6.9 to 9.2 years.
[[Page 4110]]
Table VII.7--LCC and PBP Results for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option \86\ Installed Discounted LCC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 10.59 49.49 60.09 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 90.0 Inst. 11.70 49.49 61.19 -1.10 100.0 0.0 NER
EL 2.............. 93.0 32.5 W T8 & 0.87 BF 23.33 41.51 64.84 -4.75 94.0 6.0 16.9
EL 2.............. 95.4 Inst. 20.24 49.49 69.74 -9.65 100.0 0.0 NER
EL 2.............. 96.0 26.6 W T8 & 0.87 BF 17.47 44.51 61.97 -1.88 86.3 13.7 14.6
Inst.
32.5 W T8 & 0.87 BF
Inst.
28.4 W T8 & 0.87 BF
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 53.44 49.49 102.93 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 90.0 Inst. 54.54 46.98 101.53 1.41 0.8 99.2 4.7
Replacement. EL 2.............. 93.0 32.5 W T8 & 0.88 BF 66.18 41.51 107.69 -4.75 94.0 6.0 16.9
EL 2.............. 95.4 Inst. 63.09 46.98 110.07 -7.14 100.0 0.0 40.8
EL 2.............. 96.0 26.6 W T8 & 0.87 BF 60.31 42.24 102.56 0.38 43.8 56.2 10.1
Inst.
32.5 W T8 & 0.83 BF
Inst.
28.4 W T8 & 0.83 BF
Inst.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 56.28 49.49 105.77 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 90.0 Inst. 57.38 46.98 104.37 1.41 0.8 99.2 4.7
Purchase. EL 2.............. 93.0 32.5 W T8 & 0.838 BF 69.02 41.51 110.53 -4.75 94.0 6.0 16.9
EL 2.............. 95.4 Inst. 65.93 46.98 112.91 -7.14 100.0 0.0 40.8
EL 2.............. 96.0 26.6 W T8 & 0.87 BF 63.15 42.24 105.40 0.38 43.8 56.2 10.1
Inst.
32.5 W T8 & 0.83 BF
Inst.
28.4 W T8 & 0.83 BF
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\86\ The lifetimes of the representative lamps units are 15 years.
Table VII.8--LCC and PBP Results for a Two-Lamp 4-Foot 54 W T5 Miniature Bipin High Output System Operating in the Industrial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option \87\ Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 18.79 198.89 217.86 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 26.89 198.89 225.96 -8.11 100.0 0.0 NER
EL 1.............. 102.0 49 W T5 & 1 BF Prog... 32.88 181.63 207.42 10.44 0.0 100.0 3.6
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 35.82 174.43 205.82 12.04 0.0 100.0 3.0
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 73.59 198.89 250.82 N/A N/A N/A N/A
Lamp & Ballast........ EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 81.69 198.89 258.93 -8.11 100.0 0.0 NER
Replacement. EL 1.............. 102.0 49 W T5 & 1 BF Prog... 87.68 181.63 240.38 10.44 0.0 100.0 3.6
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 90.62 174.43 238.78 12.04 0.0 100.0 3.0
Event III: New Construction and Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 76.43 198.89 252.53 N/A N/A N/A N/A
Renovation. New Lamp & Ballast EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 84.54 198.89 260.63 -8.11 100.0 0.0 NER
Purchase. EL 1.............. 102.0 49 W T5 & 1 BF Prog... 90.52 181.63 242.09 10.44 0.0 100.0 3.6
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 93.46 174.43 240.49 12.04 0.0 100.0 3.0
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\87\ The lifetimes of the representative lamps units range from 5.1 to 7.2 years.
[[Page 4111]]
Table VII.9--LCC and PBP Results for a Two-Lamp 4-Foot 28 W T5 Miniature Bipin Standard Output System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option \88\ Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 15.48 168.05 183.71 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 104.3 27.8 W T5 & 1 BF Prog. 19.38 168.05 187.62 -3.91 100.0 0.0 NER
EL 2.............. 109.7 27.8 W T5 & 1 BF Prog. 21.76 168.05 190.00 -6.29 100.0 0.0 NER
EL 2.............. 111.5 26 W T5 & 1 BF Prog... 24.94 157.48 182.61 1.10 35.6 64.4 5.4
EL 2.............. 116.0 25 W T5 & 1 BF Prog... 27.72 151.60 176.35 7.36 0.0 100.0 4.5
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 69.04 168.05 219.39 N/A N/A N/A N/A
Lamp & Ballast........ EL 1.............. 104.3 27.8 W T5 & 0.85 BF 72.94 147.48 202.73 16.66 0.0 100.0 1.1
Prog.
Replacement. EL 2.............. 109.7 27.8 W T5 & 0.85 BF 75.32 147.48 205.11 14.28 0.0 100.0 1.8
Prog.
EL 2.............. 111.5 26 W T5 & 0.85 BF Prog 78.50 138.30 199.12 20.28 0.0 100.0 1.9
EL 2.............. 116.0 25 W T5 & 0.85 BF Prog 81.28 133.20 193.64 25.76 0.0 100.0 2.1
Event III: New Construction and Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 71.88 168.05 221.29 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1.............. 104.3 27.8 W T5 & 0.85 BF 75.79 147.48 204.63 16.66 0.0 100.0 1.1
Purchase. Prog.
EL 2.............. 109.7 27.8 W T5 & 0.85 BF 78.17 147.48 207.01 14.28 0.0 100.0 1.8
Prog.
EL 2.............. 111.5 26 W T5 & 0.85 BF Prog 81.34 138.30 201.01 20.28 0.0 100.0 1.9
EL 2.............. 116.0 25 W T5 & 0.85 BF Prog 84.12 133.20 195.53 25.76 0.0 100.0 2.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\88\ The lifetimes of the representative lamps units range from 6.9 to 8.1 years.
Table VII.10--LCC and PBP Results for a Two-Lamp 8-Foot 59 W T8 Single Pin Slimline System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option \89\ Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 27.02 235.88 263.29 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1.............. 98.2 60.1 W T8 & 0.87 BF 29.72 235.88 266.00 -2.70 100.0 0.0 NER
Inst.
EL 2.............. 99.0 60.1 W T8 & 0.87 BF 34.89 235.88 271.17 -7.88 100.0 0.0 NER
Inst.
EL 2.............. 105.6 54 W T8 & 0.87 BF Inst 43.98 223.67 268.05 -4.75 93.5 6.5 6.6
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 51.41 207.38 259.19 4.10 18.4 81.6 4.1
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 103.85 232.93 301.36 N/A N/A N/A N/A
Inst.
Lamp & Ballast........ EL 1.............. 98.2 60.1 W T8 & 0.77 BF 106.55 207.99 279.13 22.23 0.0 100.0 0.5
Inst.
Replacement. EL 2.............. 99.0 60.1 W T8 & 0.77 BF 111.72 207.99 284.31 17.06 0.0 100.0 1.5
Inst.
EL 2.............. 105.6 54 W T8 & 0.77 BF Inst 120.81 197.22 282.62 18.75 0.0 100.0 2.3
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 128.24 204.71 297.54 3.83 21.5 78.5 4.1
Event III: New..................... Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 106.69 232.93 302.88 N/A N/A N/A N/A
Inst.
Construction and New Lamp & Ballast.... EL 1.............. 98.2 60.1 W T8 & 0.77 BF 109.39 207.99 280.65 22.23 0.0 100.0 0.5
Inst.
Renovation Purchase. EL 2.............. 99.0 60.1 W T8 & 0.77 BF 114.57 207.99 285.82 17.06 0.0 100.0 1.5
Inst.
EL 2.............. 105.6 54 W T8 & 0.77 BF Inst 123.65 197.22 284.13 18.75 0.0 100.0 2.3
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 131.08 204.71 299.06 3.83 21.5 78.5 4.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\89\ The lifetimes of the representative lamps units are 5.4 years.
[[Page 4112]]
Table VII.11--LCC and PBP Results for a Two-Lamp 8-Foot 86 W T8 Recessed Double Contact HO System Operating in the Industrial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option \90\ Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 24.73 225.36 250.47 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 34.39 225.36 260.13 -9.67 100.0 0.0 NER
EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 41.67 225.36 267.42 -16.95 100.0 0.0 NER
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 103.98 225.36 287.49 N/A N/A N/A N/A
Lamp & Ballast........ EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 113.65 225.36 297.16 -9.67 100.0 0.0 NER
Replacement. EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 120.93 225.36 304.44 -16.95 100.0 0.0 NER
Event III: New..................... Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 106.82 225.36 288.82 N/A N/A N/A N/A
Construction and New Lamp & Ballast.... EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 116.49 225.36 298.49 -9.67 100.0 0.0 NER
Renovation. Purchase. EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 123.77 225.36 305.77 -16.95 100.0 0.0 NER
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
\90\ The lifetimes of the representative lamp units are 3.6 years.
[[Page 4113]]
Incandescent Reflector Lamps
Table VII.12 through Table VII.15 present the commercial and
residential sector LCC results for the IRL representative product
class, the standard spectrum IRLs with diameters greater than 2.5
inches, input voltages less than 125 V.
[[Page 4114]]
Table VII.12--LCC and PBP Results for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure;............. Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 10.67 9.88 20.54 N/A N/A N/A N/A
Halogen.
or Event III: New Construction and Lamp Replacement or EL 1.............. 17.8 55W, 2500hrs, HIR..... 13.25 9.05 17.00 3.54 0.0 100.0 3.0
Renovation New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.13--LCC and PBP Results for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure;............. Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 9.52 10.92 20.45 N/A N/A N/A N/A
Halogen.
or Event III: New Construction and Lamp Replacement or EL 1.............. 17.8 55W, 2500hrs, HIR..... 12.10 10.01 17.74 2.71 0.0 100.0 5.2
Renovation New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.14--LCC and PBP Results for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure;............. Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 10.67 9.88 20.54 N/A N/A N/A N/A
Halogen.
or Event III: New Construction and Lamp Replacement or EL 1.............. 20.4 55W, 4200hrs, Improved 15.15 9.05 14.46 6.08 0.0 100.0 5.2
Renovation New Lamp Purchase. HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4115]]
Table VII.15--LCC and PBP Results for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 9.52 10.92 20.45 N/A N/A N/A N/A
III: New Construction and Halogen.
Renovation.
Lamp Replacement or EL 1.............. 20.4 55W, 4200hrs, Improved 14.00 10.01 15.87 4.58 0.0 100.0 9.0
New Lamp Purchase. HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4116]]
b. Consumer Subgroup Analysis
Certain consumer subgroups may be disproportionately affected by
standards. Using the LCC spreadsheet model, DOE determined the impact
of the TSLs on the following consumer subgroups: low-income consumers
and institutions that serve low-income populations.
To reflect conditions faced by the identified subgroups, DOE
adjusted particular inputs to the LCC model. For low-income consumers,
DOE only used RECS data for consumers living below the poverty line.
For institutions serving low-income populations, DOE assumed that the
majority of these institutions are small nonprofits, and used a higher
discount rate of 8.2 percent (versus 3.6 percent for the main
commercial sector analysis). DOE found the differences between the LCC
and PBP results for the subgroups analyzed and the primary LCC and PBP
analysis to be minimal. See chapter 9 of the final rule TSD further
details of the consumer subgroup analysis.
General Service Fluorescent Lamps
Table VII.16 through Table VII.24 show the LCC impacts and payback
periods for the identified subgroups for GSFLs. Entries of ``NER''
indicate standard levels that do not reduce operating costs.
[[Page 4117]]
Table VII.16--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 17.38 110.26 127.79 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1.............. 90.0 32.5 W T8 & 0.88 BF 32.05 110.26 132.38 -4.59 100 0 NER
Inst.
EL 2.............. 93.0 26.6 W T8 & 0.88 BF 30.12 92.34 122.61 5.18 1.3 98.7 3.1
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.88 BF 27.03 110.26 137.44 -9.65 100.0 0.0 NER
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.88 BF 24.25 99.07 123.47 4.32 0.0 100.0 2.6
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 60.77 110.06 156.30 N/A N/A N/A N/A
Inst.
Lamp & Ballast........ EL 1.............. 90.0 32.5 W T8 & 0.78 BF 75.44 98.44 149.27 7.03 0.0 100.0 0.4
Inst.
Replacement. EL 2.............. 93.0 26.6 W T8 & 0.88 BF 73.51 92.17 151.15 5.15 1.4 98.6 3.1
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.77 BF 70.42 95.89 151.78 4.53 0.3 99.7 2.9
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 67.64 94.89 148.01 8.30 0.0 100.0 1.9
Inst.
Event III: New..................... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 63.61 110.06 158.18 N/A N/A N/A N/A
Inst.
Construction and New Lamp & Ballast.... EL 1.............. 90.0 32.5 W T8 & 0.78 BF 78.28 98.44 151.15 7.03 0.0 100.0 0.4
Inst.
Renovation. Purchase. EL 2.............. 93.0 26.6 W T8 & 0.88 BF 76.35 92.17 153.03 5.15 1.4 98.6 3.1
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.77 BF 73.26 95.89 153.66 4.53 0.3 99.7 2.9
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 70.49 94.89 149.89 8.30 0.0 100.0 1.9
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.17--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 17.38 163.71 181.21 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1.............. 90.0 32.5 W T8 & 0.88 BF 30.05 163.71 187.69 -6.48 100.0 0.0 NER
Prog.
EL 2.............. 93.0 26.6 W T8 & 0.88 BF 30.12 137.48 167.73 13.49 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.88 BF 27.03 163.71 190.86 -9.65 100.0 0.0 NER
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.88 BF 24.25 147.33 171.71 9.51 0.0 100.0 2.6
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 61.98 163.71 220.61 N/A N/A N/A N/A
Prog.
Lamp & Ballast........ EL 1.............. 90.0 32.5 W T8 & 0.88 BF 74.65 163.71 227.09 -6.48 100.0 0.0 NER
Prog.
Replacement. EL 1.............. 90.0 32.5 W T8 & 0.72 BF 74.65 137.10 200.48 20.13 0.0 100.0 0.3
Prog.
EL 2.............. 93.0 26.6 W T8 & 0.88 BF 74.72 137.48 207.12 13.49 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.88 BF 71.63 163.71 230.26 -9.65 100.0 0.0 NER
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.72 BF 71.63 137.10 203.65 16.97 0.0 100.0 2.3
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.88 BF 68.85 147.33 211.11 9.51 0.0 100.0 2.6
Prog.
Event III: New..................... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.88 BF 64.82 163.71 223.12 N/A N/A N/A N/A
Prog.
Construction and New Lamp & Ballast.... EL 1.............. 90.0 32.5 W T8 & 0.88 BF 77.49 163.71 229.60 -6.48 100.0 0.0 NER
Prog.
Renovation. Purchase. EL 1.............. 90.0 32.5 W T8 & 0.72 BF 77.49 137.10 202.99 20.13 0.0 100.0 0.3
Prog.
EL 2.............. 93.0 26.6 W T8 & 0.88 BF 77.56 137.48 209.64 13.49 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.88 BF 74.47 163.71 232.77 -9.65 100.0 0.0 NER
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.72 BF 74.47 137.10 206.16 16.97 0.0 100.0 2.3
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.88 BF 71.70 147.33 213.62 9.51 0.0 100.0 2.6
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4118]]
Table VII.18--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 28.26 217.09 245.65 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1.............. 90.0 32.5 W T8 & 0.87 BF 52.85 217.09 253.57 -7.92 100.0 0.0 NER
Inst.
EL 2.............. 93.0 26.6 W T8 & 0.87 BF 53.75 181.77 235.82 9.83 1.9 98.1 3.1
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.87 BF 47.56 217.09 264.95 -19.30 100.0 0.0 NER
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 42.01 195.03 237.33 8.31 0.0 100.0 2.7
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 87.41 211.39 279.10 N/A N/A N/A N/A
Inst.
Lamp & Ballast........ EL 1.............. 90.0 32.5 W T8 & 0.78 BF 112.00 192.97 268.59 10.51 0.0 100.0 0.5
Inst.
Replacement. EL 2.............. 93.0 26.6 W T8 & 0.87 BF 112.90 176.80 269.99 9.11 2.2 97.8 3.2
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.74 BF 106.71 186.63 273.63 5.46 5.1 94.9 3.4
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 101.16 189.78 271.23 7.86 0.0 100.0 2.7
Inst.
Event III: New..................... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 90.25 211.39 280.98 N/A N/A N/A N/A
Inst.
Construction and New Lamp & Ballast EL 1.............. 90.0 32.5 W T8 & 0.78 BF 114.84 192.97 270.47 10.51 0.0 100.0 0.5
Inst.
Renovation. Purchase. EL 2.............. 93.0 26.6 W T8 & 0.87 BF 115.74 176.80 271.87 9.11 2.2 97.8 3.2
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.74 BF 109.55 186.63 275.51 5.46 5.1 94.9 3.4
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 104.00 189.78 273.11 7.86 0.0 100.0 2.7
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.19--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 4-Lamp 4-Foot 32 W T8 Medium Bipin Programmed Start System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LLC experience period
lm/W cost operating LCC 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 28.26 323.51 352.00 N/A N/A N/A N/A
Prog.
Lamp Replacement...... EL 1.............. 90.0 32.5 W T8 & 0.89 BF 49.53 323.51 363.05 -11.04 100.0 0.0 NER
Prog.
EL 2.............. 93.0 26.6 W T8 & 0.89 BF 53.75 271.27 325.26 26.75 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.89 BF 47.56 323.51 371.30 -19.30 100.0 0.0 NER
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.89 BF 42.01 290.88 333.13 18.88 0.0 100.0 2.7
Prog.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 89.27 323.51 405.90 N/A N/A N/A N/A
Prog.
Lamp & Ballast EL 1.............. 90.0 32.5 W T8 & 0.87 BF 110.54 309.10 402.54 3.36 4.0 96.0 1.0
Replacement Prog.
EL 2.............. 93.0 26.6 W T8 & 0.89 BF 114.75 271.27 379.15 26.75 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.87 BF 108.57 309.10 410.79 -4.89 88.8 11.2 8.4
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 103.02 277.68 373.82 32.07 0.0 100.0 1.9
Prog.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.89 BF 92.11 323.51 408.41 N/A N/A N/A N/A
Renovation. Prog.
New Lamp & Ballast EL 1.............. 90.0 32.5 W T8 & 0.87 BF 113.38 309.10 405.05 3.36 4.0 96.0 1.0
Purchase. Prog.
EL 2.............. 93.0 26.6 W T8 & 0.89 BF 117.59 271.27 381.66 26.75 0.0 100.0 3.1
Prog.
EL 2.............. 95.4 32.5 W T8 & 0.87 BF 111.41 309.10 413.30 -4.89 88.8 11.2 8.4
Prog.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 105.86 277.68 376.33 32.07 0.0 100.0 1.9
Prog.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4119]]
Table VII.20--LCC and PBP Subgroup Results for Low-Income Consumers for a 2-Lamp 4-Foot 32 W T8 Medium Bipin Instant Start System Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC LLC experience period
lm/W cost operating 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 10.60 49.49 60.09 N/A N/A N/A N/A
Inst.
Lamp Replacement...... EL 1.............. 90.0 32.5 W T8 & 0.87 BF 11.71 49.49 61.20 -1.10 100 0 NER
Inst.
EL 2.............. 93.0 26.6 W T8 & 0.87 BF 23.36 41.50 64.86 -4.77 93.3 6.7 16.9
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.87 BF 20.26 49.49 69.75 -9.66 100 0 NER
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.87 BF 17.48 44.50 61.98 -1.89 86.4 13.6 14.6
Inst.
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 53.46 49.49 102.94 N/A N/A N/A N/A
Inst.
Lamp & Ballast EL 1.............. 90.0 32.5 W T8 & 0.83 BF 54.56 46.98 101.54 1.40 0.8 99.2 4.7
Inst.
Replacement. EL 2.............. 93.0 26.6 W T8 & 0.87 BF 66.21 41.50 107.71 -4.77 93.3 6.7 16.9
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.83 BF 63.11 46.98 110.09 -7.15 100.0 0.0 40.8
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.83 BF 60.34 42.24 102.57 0.37 43.8 56.2 10.1
Inst.
Event III: New Construction and Baseline.............. Baseline.......... 89.2 32.5 W T8 & 0.87 BF 56.30 49.49 105.79 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1.............. 90.0 32.5 W T8 & 0.83 BF 57.40 46.98 104.38 1.40 0.8 99.2 4.7
Purchase. Inst.
EL 2.............. 93.0 26.6 W T8 & 0.87 BF 69.05 41.50 110.55 -4.77 93.3 6.7 16.9
Inst.
EL 2.............. 95.4 32.5 W T8 & 0.83 BF 65.96 46.98 112.93 -7.15 100.0 0.0 40.8
Inst.
EL 2.............. 96.0 28.4 W T8 & 0.83 BF 63.18 42.24 105.42 0.37 43.8 56.2 10.1
Inst.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.21--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a Two-Lamp 4-Foot 54 W T5 Miniature Bipin High Output System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp consumers that payback
Event Response Efficacy level efficacy Design option Installed Discounted LCC LLC experience period
lm/W cost operating 2013$ savings ---------------------- years
2013$ cost 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 18.78 239.73 258.66 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 26.88 239.73 266.76 -8.10 100.0 0.0 NER
EL 1.............. 102.0 49 W T5 & 1 BF Prog... 32.86 218.93 245.99 12.67 0.0 100.0 3.0
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 35.81 210.25 242.43 16.23 0.0 100.0 2.6
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 73.57 239.73 295.57 N/A N/A N/A N/A
Lamp & Ballast EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 81.67 239.73 303.67 -8.10 100.0 0.0 NER
Replacement. EL 1.............. 102.0 49 W T5 & 1 BF Prog... 87.65 218.93 282.90 12.67 0.0 100.0 3.0
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 90.60 210.25 279.34 16.23 0.0 100.0 2.6
Event III: New Construction and Baseline.............. Baseline.......... 83.6 53.8 W T5 & 1 BF Prog. 76.41 239.73 297.48 N/A N/A N/A N/A
Renovation.
New Lamp & Ballast EL 1.............. 92.9 53.8 W T5 & 1 BF Prog. 84.51 239.73 305.59 -8.10 100.0 0.0 NER
Purchase.
EL 1.............. 102.0 49 W T5 & 1 BF Prog... 90.49 218.93 284.81 12.67 0.0 100.0 3.0
EL 1.............. 102.1 47 W T5 & 1 BF Prog... 93.44 210.25 281.25 16.23 0.0 100.0 2.6
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4120]]
Table VII.22--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a Two-Lamp 4-Foot 28 W T5 Miniature Bipin Standard Output System Operating in the Commercial
Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 15.48 143.06 158.67 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 104.3 27.8 W T5 & 1 BF Prog. 19.38 143.06 162.58 -3.91 100.0 0.0 NER
EL 2.............. 109.7 27.8 W T5 & 1 BF Prog. 21.76 143.06 164.96 -6.29 100.0 0.0 NER
EL 2.............. 111.5 26 W T5 & 1 BF Prog... 24.94 134.06 159.14 -0.47 71.2 28.8 5.4
EL 2.............. 116.0 25 W T5 & 1 BF Prog... 27.72 129.06 154.58 4.09 2.5 97.5 4.5
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 69.04 143.06 199.02 N/A N/A N/A N/A
Lamp & Ballast........ EL 1.............. 104.3 27.8 W T5 & 0.85 BF 72.94 125.55 185.42 13.60 0.0 100.0 1.1
Prog.
Replacement. EL 2.............. 109.7 27.8 W T5 & 0.85 BF 75.32 125.55 187.80 11.22 0.0 100.0 1.8
Prog.
EL 2.............. 111.5 26 W T5 & 0.85 BF Prog 78.50 117.74 183.17 15.86 0.0 100.0 1.9
EL 2.............. 116.0 25 W T5 & 0.85 BF Prog 81.28 113.39 179.27 19.75 0.0 100.0 2.1
Event III: New..................... Baseline.............. Baseline.......... 94.6 27.8 W T5 & 1 BF Prog. 71.88 143.06 201.16 N/A N/A N/A N/A
Construction and New Lamp & Ballast.... EL 1.............. 104.3 27.8 W T5 & 0.85 BF 75.79 125.55 187.56 13.60 0.0 100.0 1.1
Prog.
Renovation. Purchase. EL 2.............. 109.7 27.8 W T5 & 0.85 BF 78.17 125.55 189.94 11.22 0.0 100.0 1.8
Prog.
EL 2.............. 111.5 26 W T5 & 0.85 BF Prog 81.34 117.74 185.31 15.86 0.0 100.0 1.9
EL 2.............. 116.0 25 W T5 & 0.85 BF Prog 84.12 113.39 181.41 19.75 0.0 100.0 2.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.23--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a Two-Lamp 8-Foot 59 W T8 Single Pin Slimline System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 27.02 206.75 234.09 N/A N/A N/A N/A
Inst.
Lamp Replacement EL 1.............. 98.2 60.1 W T8 & 0.87 BF 29.72 206.75 236.79 -2.70 100.0 0.0 NER
Inst.
EL 2.............. 99.0 60.1 W T8 & 0.87 BF 34.89 206.75 241.97 -7.88 100.0 0.0 NER
Inst.
EL 2.............. 105.6 54 W T8 & 0.87 BF Inst 43.98 196.05 240.35 -6.26 99.8 0.2 6.6
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 51.41 181.77 233.51 0.58 59.9 40.1 4.1
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 103.85 204.17 279.48 N/A N/A N/A N/A
Inst.
Lamp & Ballast........ EL 1.............. 98.2 60.1 W T8 & 0.77 BF 106.55 182.31 260.33 19.15 0.0 100.0 0.5
Inst.
Replacement. EL 2.............. 99.0 60.1 W T8 & 0.77 BF 111.72 182.31 265.50 13.98 0.0 100.0 1.5
Inst.
EL 2.............. 105.6 54 W T8 & 0.77 BF Inst 120.81 172.87 265.14 14.34 0.0 100.0 2.3
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 128.24 179.43 279.14 0.34 63.2 36.8 4.1
Event III: New Construction and Baseline.............. Baseline.......... 96.5 60.1 W T8 & 0.87 BF 106.69 204.17 281.25 N/A N/A N/A N/A
Renovation. Inst.
New Lamp & Ballast EL 1.............. 98.2 60.1 W T8 & 0.77 BF 109.39 182.31 262.10 19.15 0.0 100.0 0.5
Purchase. Inst.
EL 2.............. 99.0 60.1 W T8 & 0.77 BF 114.57 182.31 267.27 13.98 0.0 100.0 1.5
Inst.
EL 2.............. 105.6 54 W T8 & 0.77 BF Inst 123.65 172.87 266.91 14.34 0.0 100.0 2.3
EL 2.............. 108.0 50 W T8 & 0.87 BF Inst 131.08 179.43 280.91 0.34 63.2 36.8 4.1
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4121]]
Table VII.24--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a Two-Lamp 8-Foot 86 W T8 Recessed Double Contact HO System Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Design option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure.............. Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 24.72 279.36 304.43 N/A N/A N/A N/A
Lamp Replacement...... EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 34.38 279.36 314.09 -9.66 100.0 0.0 NER
EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 41.66 279.36 321.37 -16.94 100.0 0.0 NER
Event II: Ballast Failure.......... Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 103.96 279.36 345.38 N/A N/A N/A N/A
Lamp & Ballast........ EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 113.62 279.36 355.04 -9.66 100.0 0.0 NER
Replacement. EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 120.90 279.36 362.32 -16.94 100.0 0.0 NER
Event III: New..................... Baseline.............. Baseline.......... 92.0 84 W T8 & 0.95 BF Prog 106.80 279.36 346.85 N/A N/A N/A N/A
Construction and New Lamp & Ballast.... EL 1.............. 95.2 84 W T8 & 0.95 BF Prog 116.47 279.36 356.51 -9.66 100.0 0.0 NER
Renovation. Purchase. EL 2.............. 97.6 84 W T8 & 0.95 BF Prog 123.74 279.36 363.79 -16.94 100.0 0.0 NER
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4122]]
Incandescent Reflector Lamps
Table VII.25 through Table VII.28 show the LCC impacts and payback
periods for the identified subgroups for IRLs.
[[Page 4123]]
Table VII.25--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 10.67 9.46 20.13 N/A N/A N/A N/A
III: New Construction and ...................... .................. ......... Halogen. ......... .......... ......... ......... ......... ......... .........
Renovation. Lamp Replacement or EL 1.............. 17.8 55W, 2500hrs, HIR..... 13.25 8.67 16.62 3.51 0.0 100.0 3.0
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.26--LCC and PBP Subgroup Results for Low-Income Consumers for a 55 W PAR38 2,500 Hour HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LCC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 9.53 10.77 20.31 N/A N/A N/A N/A
III: New Construction and ...................... .................. ......... Halogen. ......... .......... ......... ......... ......... ......... .........
Renovation. Lamp Replacement or EL 1.............. 17.8 55W, 2500hrs, HIR..... 12.11 9.88 17.61 2.70 0.0 100.0 5.3
New Lamp Purchase.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.27--LCC and PBP Subgroup Results for Institutions Serving Low-Income Populations for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Commercial Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 10.67 9.46 20.13 N/A N/A N/A N/A
III: New Construction and ...................... .................. ......... Halogen. ......... .......... ......... ......... ......... ......... .........
Renovation. Lamp Replacement or EL 1.............. 20.4 55W, 4200hrs, Improved 15.15 8.67 14.08 6.05 0.0 100.0 5.2
New Lamp Purchase. HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4124]]
Table VII.28--LCC and PBP Subgroup Results for Low-Income Consumers for a 55 W PAR38 4,200 Hour Improved HIR EL 1 Representative Lamp Operating in the Residential Sector
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Life-cycle cost Life-cycle cost savings
-------------------------------------------------------------------
Rated Percentage of Mean
lamp Discounted consumers that payback
Event Response Efficacy level efficacy Lamp option Installed operating LCC LLC experience period
lm/W cost cost 2013$ savings ---------------------- years
2013$ 2013$ 2013$ Net
Net cost benefit
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Event I: Lamp Failure; or Event Baseline.............. Baseline.......... 17.8 60W, 1500hrs, Improved 9.53 10.77 20.31 N/A N/A N/A N/A
III: New Construction and ...................... .................. ......... Halogen. ......... .......... ......... ......... ......... ......... .........
Renovation. Lamp Replacement or EL 1.............. 20.4 55W, 4200hrs, Improved 14.01 9.88 15.74 4.57 0.0 100.0 9.2
New Lamp Purchase. HIR.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 4125]]
c. Rebuttable-Presumption Payback
EPCA establishes a rebuttable presumption that an energy
conservation standard is economically justified if the increased
purchase cost for a product that meets the standard is less than three
times the value of the first-year energy savings resulting from the
standard. DOE's LCC and PBP analyses generate values that calculate the
payback period for consumers of potential energy conservation
standards, which include, but are not limited to, the 3-year payback
period contemplated under the rebuttable-presumption test. However, DOE
routinely conducts a full economic analysis that considers the full
range of impacts--including those on consumers, manufacturers, the
nation, and the environment--as required under 42 U.S.C.
6295(o)(2)(B)(i). The results of this analysis serve as the basis for
DOE to evaluate the economic justification for a potential standard
level (thereby supporting or rebutting the results of any preliminary
determination of economic justification).
Table VII.29 shows the GSFL payback periods that are less than 3
years for the most common sector for each product class. There are no
IRL payback periods less than 3 years.
Table VII.29--GSFL Efficacy Levels With Rebuttable Payback Period Less Than Three Years
--------------------------------------------------------------------------------------------------------------------------------------------------------
Mean
Efficacy Rated lamp payback
Lamp description Sector Event Response level efficacy Design option period
lm/W years
--------------------------------------------------------------------------------------------------------------------------------------------------------
2-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.88 BF 2.6
Instant Start. Failure. Inst.
Event II: Ballast Lamp & Ballast..... EL 1 90.0 32.5 W T8 & 0.78 BF 0.4
Failure. Inst.
Replacement EL 2 95.4 32.5 W T8 & 0.77 BF 2.9
Inst.
EL 2 96.0 28.4 W T8 & 0.87 BF 1.9
Inst.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.4
Construction and Purchase. Inst.
Renovation.
EL 2 95.4 32.5 W T8 & 0.77 BF 2.9
Inst.
EL 2 96.0 28.4 W T8 & 0.87 BF 1.9
Inst.
2-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.88 BF 2.6
Programmed Start. Failure. Prog.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.72 BF 0.3
Failure. Replacement. Prog.
EL 2 95.4 32.5 W T8 & 0.72 BF 2.3
Prog.
EL 2 96.0 28.4 W T8 & 0.88 BF 2.6
Prog.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.72 BF 0.3
Construction and Purchase. Prog.
Renovation.
EL 2 95.4 32.5 W T8 & 0.72 BF 2.3
Prog.
EL 2 96.0 28.4 W T8 & 0.88 BF 2.6
Prog.
4-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.87 BF 2.7
Instant Start. Failure. Inst.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.5
Failure. Replacement. Inst.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.7
Inst.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.78 BF 0.5
Construction and Purchase. Inst.
Renovation.
EL 2 96.0 28.4 W T8 & 0.87 BF 2.7
Inst.
4-Lamp 4-foot Medium Bipin Commercial......... Event I: Lamp Lamp Replacement... EL 2 96.0 28.4 W T8 & 0.89 BF 2.7
Programmed Start. Failure. Prog.
Event II: Ballast Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.87 BF 1.0
Failure. Replacement. Prog.
EL 2 96.0 28.4 W T8 & 0.87 BF 1.9
Prog.
Event III: New New Lamp & Ballast EL 1 90.0 32.5 W T8 & 0.87 BF 1.0
Construction and Purchase. Prog.
Renovation.
EL 2 96.0 28.4 W T8 & 0.87 BF 1.9
Prog.
T5 Miniature Bipin Standard Commercial......... Event II: Ballast Lamp & Ballast EL 1 104.3 27.8 W T5 & 0.85 BF 1.1
Output. Failure. Replacement. Prog.
EL 2 109.7 27.8 W T5 & 0.85 BF 1.8
Prog.
EL 2 111.5 26 W T5 & 0.85 BF 1.9
Prog.
EL 2 116.0 25 W T5 & 0.85 BF 2.1
Prog.
Event III: New New Lamp & Ballast EL 1 104.3 27.8 W T5 & 0.85 BF 1.1
Construction and Purchase. Prog.
Renovation.
[[Page 4126]]
EL 2 109.7 27.8 W T5 & 0.85 BF 1.8
Prog.
EL 2 111.5 26 W T5 & 0.85 BF 1.9
Prog.
EL 2 116.0 25 W T5 & 0.85 BF 2.1
Prog.
T8 Single Pin Slimline.......... Commercial......... Event II: Ballast Lamp & Ballast EL 1 98.2 60.1 W T8 & 0.77 BF 0.5
Failure. Replacement. Prog.
EL 2 99.0 60.1 W T8 & 0.77 BF 1.5
Prog.
EL 2 105.6 54 W T8 & 0.77 BF 2.3
Prog.
Event III: New New Lamp & Ballast EL 1 98.2 60.1 W T8 & 0.77 BF 0.5
Construction and Purchase. Prog.
Renovation.
EL 2 99.0 60.1 W T8 & 0.77 BF 1.5
Prog.
EL 2 105.6 54 W T8 & 0.77 BF 2.3
Prog.
--------------------------------------------------------------------------------------------------------------------------------------------------------
2. Economic Impacts on Manufacturers
DOE performed MIAs to estimate the impact of amended energy
conservation standards on manufacturers of GSFLs and IRLs. The
following section describes the expected impacts on GSFL and IRL
manufacturers at each TSL. Chapter 13 of the final rule TSD explains
the MIA in further detail.
a. Industry Cash-Flow Analysis Results
The tables in this section depict the financial impacts
(represented by changes in INPV) of potential amended energy standards
on GSFL and IRL manufacturers, as well as the conversion costs that DOE
estimates GSFL and IRL manufacturers would incur at each TSL. DOE
separately breaks out the impacts on GSFL and IRL manufacturers. To
evaluate the range of cash-flow impacts on the GSFL and IRL industries,
DOE modeled three markup scenarios for GSFLs and two markup scenarios
for IRLs that correspond to the range of anticipated market responses
to potential amended standards. Each scenario results in a unique set
of cash flows and corresponding industry values at each TSL.
In the following discussion, the INPV results refer to the
difference in industry value between the base case and the standards
case that result from the sum of discounted cash flows from the base
year (2015) through the end of the analysis period. The results also
discuss the difference in cash flows between the base case and the
standards case in the year before the compliance date for potential
amended energy conservation standards. This figure represents the size
of the required conversion costs relative to the cash flow generated by
the GSFL and IRL industries in the absence of potential amended energy
conservation standards.
Cash-Flow Analysis Results by TSL for General Service Fluorescent Lamps
To assess the upper (less severe) bound of the range of potential
impacts on GSFL manufacturers, DOE modeled a flat, or preservation of
gross margin, markup scenario. This scenario assumes that in the
standards case, manufacturers would be able to pass along all the
higher production costs required for more efficacious products to their
consumers. Specifically, the industry would be able to maintain its
average base-case gross margin (as a percentage of revenue) despite the
higher product costs in the standards case. In general, the larger the
product price increases, the less likely manufacturers are to achieve
the cash flow from operations calculated in this scenario because it is
less likely that manufacturers would be able to fully mark up these
larger cost increases.
To assess the lower (more severe) bound of the range of potential
impacts on the GSFL manufacturers, DOE modeled a two-tier markup
scenario. The two-tiered markup scenario assumes manufacturers offer
two different tiers of markups, one for lower efficacy levels and one
for higher efficacy levels. This scenario models a situation where a
reduction in premium markups reduces the profitability of higher
efficacy products. During manufacturer interviews, manufacturers
provided information on the range of typical efficacy levels in these
two tiers and the change in profitability at each level. DOE used this
information to estimate markups for GSFLs under a two-tier pricing
strategy. In the standards case, DOE modeled the situation in which
GSFL standards result in less product differentiation, compression of
the higher markup tier, and an overall reduction in profitability.
In addition to an upper and lower bound markup scenario, DOE also
modeled the preservation of operating profit markup scenario. This
scenario models the situation where manufacturers earn the same nominal
operating profit in the standards case as they would earn in the base
case, despite the higher production costs resulting from standards.
While this scenario does not represent an upper or lower bound for this
analysis, it displays the INPV results if manufacturers are able to
implement a common pricing strategy following abrupt changes to MPCs,
as is the case with energy conservation standards.
Table VII.30 through Table VII.32 present the projected results for
GSFLs under the flat, preservation of operating profit, and two-tier
markup scenarios. DOE examined results for all five product classes (4-
foot MBP, 8-foot SP slimline, 8-foot RDC HO, 4-foot T5 MiniBP SO, and
4-foot T5 MiniBP HO) together.
[[Page 4127]]
Table VII.30--Manufacturer Impact Analysis for General Service Fluorescent Lamps--Flat Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2013$ millions)................ 1,551.6 1,601.1 1,599.8 1,682.0 1,978.4 1,996.2
Change in INPV................................ (2013$ millions)................ .......... 49.5 48.2 130.4 426.8 444.6
(%)............................. .......... 3.2 3.1 8.4 27.5 28.7
Product Conversion Costs...................... (2013$ millions)................ .......... 0.9 2.0 5.1 7.8 9.2
Capital Conversion Costs...................... (2013$ millions)................ .......... 1.0 11.2 2.0 18.8 29.9
Total Conversion Costs........................ (2013$ millions)................ .......... 1.9 13.2 7.2 26.6 39.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.31--Manufacturer Impact Analysis for General Service Fluorescent Lamps--Preservation of Operating Profit
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2013$ millions)................ 1,551.6 1,551.0 1,542.0 1,542.9 1,525.4 1,516.4
Change in INPV................................ (2013$ millions)................ .......... (0.6) (9.6) (8.7) (26.2) (35.2)
(%)............................. .......... 0.0 -0.6 -0.6 -1.7 -2.3
Product Conversion Costs...................... (2013$ millions)................ .......... 0.9 2.0 5.1 7.8 9.2
Capital Conversion Costs...................... (2013$ millions)................ .......... 1.0 11.2 2.0 18.8 29.9
Total Conversion Costs........................ (2013$ millions)................ .......... 1.9 13.2 7.2 26.6 39.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table VII.32--Manufacturer Impact Analysis for General Service Fluorescent Lamps--Two Tier Markup Scenario
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Units Base case -----------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
INPV.......................................... (2013$ millions)................ 1,551.6 1,508.7 1,495.1 1,477.4 1,221.6 1,183.9
Change in INPV................................ (2013$ millions)................ .......... (42.9) (56.5) (74.2) (330.0) (367.7)
(%)............................. .......... -2.8 -3.6 -4.8 -21.3 -23.7
Product Conversion Costs...................... (2013$ millions)................ .......... 0.9 2.0 5.1 7.8 9.2
Capital Conversion Costs...................... (2013$ millions)................ .......... 1.0 11.2 2.0 18.8 29.9
Total Conversion Costs........................ (2013$ millions)................ .......... 1.9 13.2 7.2 26.6 39.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
TSL 1 sets the efficacy level at baseline for two product classes
(4-foot MBP and 8-foot SP slimline) and EL 1 for three product classes
(8-foot RDC HO, 4-foot T5 MiniBP SO, and 4-foot T5 MiniBP HO). EL 1 for
the 4-foot T5 MiniBP HO product class represents max tech. At TSL 1,
DOE estimates impacts on INPV range from $49.5 million to -$42.9
million, or a change in INPV of 3.2 percent to -2.8 percent. At TSL 1,
industry free cash flow (operating cash flow minus capital
expenditures) is estimated to decrease by less than 1 percent to $164.2
million, compared to the base-case value of $164.5 million in 2017, the
year leading up to the energy conservation standards.
Percentage impacts on INPV range from slightly positive to slightly
negative at TSL 1. DOE does not anticipate that manufacturers would
lose a significant portion of their INPV at this TSL. This is because
the vast majority of shipments already meets or exceeds the efficacy
levels prescribed at TSL 1. DOE projects that in the expected year of
compliance (2018), 100 percent of 4-foot MBP and 8-foot SP slimline
shipments would meet or exceed the efficacy levels at TSL 1. DOE
estimates that these lamps account for 86 percent of GSFL shipments in
2018. Meanwhile, in 2018, 32 percent of 8-foot RDC HO shipments, 46
percent of 4-foot T5 MiniBP SO, and 39 percent of 4-foot T5 MiniBP HO
shipments would meet the efficacy levels at TSL 1. Because these
products comprise only a small percentage of total GSFL shipments in
2018, a very small percentage of total GSFL shipments would need to be
converted at TSL 1 to meet these efficacy standards.
DOE expects conversion costs to be small compared to the industry
value because most of the GSFL shipments, on a total volume basis,
already meet or exceed the efficacy levels prescribed at this TSL. DOE
expects GSFL manufacturers to incur $0.9 million in product conversion
costs for lamp redesign and testing. DOE estimates manufacturers will
have minimal capital conversion costs associated with TSL 1, as most
efficacy gains will be achieved through increasing the amount of REOs
used to coat the lamps, not through any major equipment upgrades or
capital investments. DOE expects $1.0 million in capital conversion
costs for manufacturers to upgrade and recalibrate production line
automation.
At TSL 1, under the flat markup scenario, the shipment-weighted
average MPC increases by approximately 6 percent relative to the base-
case MPC. Manufacturers are able to fully pass on this cost increase to
consumers by design in this markup scenario. This slight price increase
would mitigate the $1.9 million in conversion costs estimated at TSL 1,
resulting in slightly positive INPV impacts at TSL 1 under the flat
markup scenario.
Under the preservation of operating profit markup scenario,
manufacturers earn the same nominal operating profit as would be earned
in the base case, but manufacturers do not earn additional
[[Page 4128]]
profit from their investments. The 6 percent MPC increase is slightly
outweighed by a lower average markup of 1.51 (compared to the flat
markup of 1.52) and $1.9 million in conversion costs, resulting in
slightly negative impacts at TSL 1.
Under the two-tier markup scenario, manufacturers lose
differentiation in their product offerings and premium markups erode as
high-efficacy products become baseline offerings due to standards. The
6 percent MPC increase does not mitigate the lower average markup of
1.50 and $1.9 million in conversion costs, resulting in slightly
negative impacts at TSL 1.
TSL 2 sets the efficacy level at baseline for one product class (4-
foot MBP), EL 1 for three product classes (8-foot SP slimline, 4-foot
T5 MiniBP SO, and 4-foot T5 MiniBP HO), and EL 2 for one product class
(8-foot RDC HO). EL 1 for the 4-foot T5 MiniBP HO product class and EL
2 for the 8-foot RDC HO product class represent max tech. At TSL 2, DOE
estimates impacts on INPV to range from $48.2 million to -$56.5
million, or a change in INPV of 3.1 percent to -3.6 percent. At this
standard level, industry free cash flow is estimated to decrease by
approximately 3.4 percent to $159.3 million, compared to the base case
value of $164.5 million in 2017.
Percentage impacts on INPV range from slightly positive to slightly
negative at TSL 2. DOE does not anticipate that manufacturers would
lose a significant portion of their INPV at this TSL because the vast
majority of shipments already meet or exceed the efficacy levels
prescribed at TSL 2. DOE projects that in 2018, 100 percent of 4-foot
MBP shipments would meet or exceed the efficacy levels at TSL 2. DOE
estimates that shipments of this product classes will comprise 83
percent of GSFL shipments in 2018. Meanwhile, in 2018, 60 percent of 8-
foot SP slimline lamps shipments, 10 percent of 8-foot RDC HO
shipments, 46 percent of 4-foot T5 MiniBP SO, and 39 percent of 4-foot
T5 MiniBP HO shipments would meet or exceed the efficacy levels at TSL
2.
DOE expects conversion costs to be small compared to the industry
value because most of the GSFL shipments, on a total volume basis,
already meet or exceed the efficacy levels analyzed at this TSL. DOE
expects that product conversion costs will rise from $0.9 million at
TSL 1 to $2.0 million at TSL 2 for lamp redesign and testing. Capital
conversion costs will increase from $1.0 million at TSL 1 to $11.2
million at TSL 2. This is driven by the fact that both 8-foot product
classes would have to meet higher efficacy levels at this TSL. DOE
believes this will result in higher capital conversion costs related to
upgrading and recalibrating production line automation.
At TSL 2, under the flat markup scenario, the shipment-weighted-
average MPC increases by 7 percent, relative to the base-case MPC. In
this scenario, INPV impacts are slightly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $13.2 million in conversion costs. Under the preservation
of operating profit markup scenario, the 7 percent MPC increase is
slightly outweighed by a lower average markup of 1.51 (compared to the
flat markup of 1.52) and $13.2 million in conversion costs, resulting
in slightly negative impacts at TSL 2. Under the two-tier markup
scenario, the 7 percent MPC increase is also slightly outweighed by a
lower average markup of 1.50 and $13.2 million in conversion costs,
resulting in slightly negative impacts at TSL 2.
TSL 3 sets the efficacy level at baseline for two product classes
(8-foot SP slimline and 8-foot RDC HO) and EL 1 for three product
classes (4-foot MBP, 4-foot T5 MiniBP SO, and 4-foot T5 MiniBP HO). EL
1 for the 4-foot T5 MiniBP HO product class represents max tech. At TSL
3, DOE estimates impacts on INPV to range from $130.4 million to -$74.2
million, or a change in INPV of 8.4 percent to -4.8 percent. At this
standard level, industry free cash flow is estimated to decrease by
approximately 1.5 percent to $154.1 million, compared to the base-case
value of $164.5 million in 2017.
While more significant than the impacts at TSL 2, the lower bound
markup scenario impacts on INPV at TSL 3 are still relatively minor
compared to the total industry value. Percentage impacts on INPV range
from moderately positive to slightly negative at TSL 3. DOE does not
anticipate that manufacturers would lose a significant portion of their
INPV at TSL 3. While less than the previous TSLs, a large percentage of
total shipments still already meet or exceed the efficacy levels
prescribed at TSL 3. DOE projects that in 2018, 57 percent of the 4-
foot MBP, 100 percent of 8-foot SP slimline, 100 percent of 8-foot RDC
HO shipments, 46 percent of 4-foot T5 MiniBP SO, and 39 percent of 4-
foot T5 MiniBP HO shipments would meet or exceed the efficacy levels at
TSL 3.
DOE expects conversion costs to remain small at TSL 3, compared to
the industry value, because a significant percentage of the GSFL
shipments, on a total volume basis, already meet or exceed the efficacy
levels at this TSL. TSL 3 is the first TSL that increases the efficacy
requirement for 4-foot MBP lamps, which as previously noted, comprise a
large majority of GSFL shipments. Efficacy gains for these products,
however, would likely be achieved with additional REOs, which would not
require a significant capital investment. At TSL 3, DOE expects product
conversion costs to increase from TSL 2 to $5.1 million. DOE, however,
estimates that capital conversion costs will decrease from TSL 2 to
$2.0 million at TSL 3 as no amended efficacy standards would be set at
TSL 3 for 8-foot SP slimline products or the 8-foot RDC HO product
class. The lower ELs for these two product classes outweigh the
increase in EL of the 4-ft MBP product class and would cause
manufacturers to invest less in capital conversion costs at TSL 3 than
at TSL 2.
At TSL 3, under the flat markup scenario, the shipment-weighted-
average MPC increases by 16 percent relative to the base-case MPC. In
this scenario, INPV impacts are slightly positive because
manufacturers' ability to pass the higher production costs to consumers
outweighs the $7.2 million in conversion costs. Under the preservation
of operating profit markup scenario, the 16 percent MPC increase is
slightly outweighed by a lower average markup of 1.49 (compared to the
flat markup scenario markup of 1.52) and $7.2 million in conversion
costs, resulting in slightly negative impacts at TSL 3. Under the two-
tier markup scenario, the 16 percent MPC increase is outweighed by a
lower average markup of 1.48 and $7.2 million in conversion costs,
resulting in negative impacts at TSL 3.
TSL 4 sets the efficacy level at baseline for two product classes
(8-foot SP slimline and 8-foot RDC HO), EL 1 for one product class (4-
foot T5 MiniBP HO), and EL 2 for two product classes (4-foot MBP and T5
MiniBP SO). EL 1 for the 4-foot T5 MiniBP HO product class and EL 2 for
the 4-foot MBP and T5 MiniBP SO product classes represent max tech. At
TSL 4, DOE estimates impacts on INPV to range from $426.8 million to -
$330.0 million, or a change in INPV of 27.5 percent to -21.3 percent.
At this standard level, industry free cash flow is estimated to
decrease by approximately 7 percent to $154.1 million, compared to the
base-case value of $164.5 million in the year leading up to energy
conservation standards.
Percentage impacts on INPV range from significantly positive to
moderately negative at TSL 4. DOE projects that in 2018, 23 percent of
4-
[[Page 4129]]
foot MBP, 100 percent of 8-foot SP slimline, 100 percent of 8-foot RDC
HO shipments, 14 percent of 4-foot T5 MiniBP SO, and 39 percent of 4-
foot T5 MiniBP HO shipments would meet or exceed the efficacy levels at
TSL 4.
While DOE expects conversion costs to increase from TSL 3 to TSL 4,
DOE estimates the costs will still be small compared to the total
industry value. DOE expects product conversion costs for GSFL
manufacturers to increase from $5.1 million at TSL 3 to $7.8 million at
TSL 4. DOE expects capital conversion costs to increase from $2.0
million at TSL 3 to $18.8 million at TSL 4. While a higher percentage
of shipments would need to be converted to meet the efficacy
requirements at TSL 4, increasing the efficacy of GSFLs will not likely
be a very capital-intensive process, compared to the base case INPV.
Instead, increasing GSFL efficacy will likely be more focused around
increasing the amount of REOs in the lamps.
At TSL 4, under the flat markup scenario the shipment-weighted-
average MPC increases by 52 percent relative to the base-case MPC. In
this scenario, INPV impacts are significantly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $26.6 million in conversion costs. Under the preservation
of operating profit markup scenario, the 52 percent MPC increase is
slightly outweighed by a lower average markup of 1.44 (compared to the
flat markup scenario markup of 1.52) and $26.6 million in conversion
costs, resulting in slightly negative impacts at TSL 4. Under the two-
tier markup scenario, the 52 percent MPC increase is moderately
outweighed by a lower average markup of 1.39 and $26.6 million in
conversion costs, resulting in moderately negative impacts at TSL 4.
TSL 5 sets the efficacy level at max tech for all product classes.
This represents EL 1 for one product class (4-foot T5 MiniBP HO) and EL
2 for four product classes (4-foot MBP, 8-foot SP slimline, 8-foot RDC
HO, and 4-foot T5 MiniBP SO). At TSL 5, DOE estimates impacts on INPV
to range from $444.5 million to -$367.7 million, or a change in INPV of
28.7 percent to -23.7 percent. At this standard level, industry free
cash flow is estimated to decrease by 10 percent to $148.7 million,
compared to the base-case value of $164.5 million in 2017.
Percentage impacts on INPV range from significantly positive to
significantly negative at TSL 5. DOE projects that in 2018, 23 percent
of the 4-foot MBP, 26 percent of 8-foot SP slimline, 10 percent of 8-
foot RDC HO, 14 percent of 4-foot T5 MiniBP SO, and 39 percent of 4-
foot T5 MiniBP HO shipments would meet the efficacy levels at TSL 5.
DOE expects conversion costs to increase from TSL 4 to TSL 5 due to
the 8-foot slimline and 8-foot RDC HO product classes moving to max
tech at TSL 5. DOE estimates that capital conversion costs will be
$29.9 million at TSL 5 as a result of manufacturers having to upgrade
all of their production lines to manufacture max-tech products. DOE
expects GSFL manufacturers to incur $9.2 million in product conversion
costs for lamp redesigns and testing. However, these larger total
conversion costs at TSL 5, $39.1 million, remain relatively small
compared to the approximately $1.5 billion base-case GSFL INPV.
At TSL 5, under the flat markup scenario, the shipment-weighted-
average MPC increases by 55 percent relative to the base-case MPC. In
this scenario, INPV impacts are significantly positive because of
manufacturers' ability to pass the higher production costs to consumers
outweighs the $39.1 million in conversion costs. Under the preservation
of operating profit markup scenario, the 55 percent MPC increase is
slightly outweighed by a lower average markup of 1.44 (compared to the
flat markup scenario markup of 1.52) and $39.1 million in conversion
costs, resulting in slightly negative impacts at TSL 5. Under the two-
tier markup scenario, the 55 percent MPC increase is significantly
outweighed by the lower average markup of 1.38 and $39.1 million in
conversion costs, resulting in significantly negative impacts at TSL 5.
Cash-Flow Analysis Results by TSL for Incandescent Reflector Lamps
DOE incorporated two markup scenarios to represent the upper and
lower bounds of the IRL industry: The flat, or preservation of gross
margin, markup scenario to represent the upper bound (least severe) and
the preservation of operating profit markup scenario to represent the
lower bound (most severe). DOE, however, analyzed one TSL for IRLs in
addition to the baseline level. DOE also analyzed an alternative
shipment scenario for IRLs, the shortened lifetime scenario, in
addition to the reference case. DOE acknowledges that to meet TSL 1,
IRL manufacturers may choose to shorten the lifetime of some of their
IRLs, rather than make the investments to increase the efficacy of the
lamps. DOE presents the results of this analysis in appendix 13B of
this final rule TSD.
Table VII.33 and Table VII.34 present the projected results for
IRLs under the flat markup and preservation of operating profit markup
scenarios. DOE examined results for one representative product class
for IRLs.
Table VII.33--Manufacturer Impact Analysis for Incandescent Reflector Lamps--Flat Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard
level
Units Base case ---------------
1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2013$ millions)................ 145.4 93.0
Change in INPV................................ (2013$ millions)................ .............. (52.5)
(%)............................. .............. -36.1
Product Conversion Costs...................... (2013$ millions)................ .............. 6.2
Capital Conversion Costs...................... (2013$ millions)................ .............. 66.4
Total Conversion Costs........................ (2013$ millions)................ .............. 72.6
----------------------------------------------------------------------------------------------------------------
[[Page 4130]]
Table VII.34--Manufacturer Impact Analysis for Incandescent Reflector Lamps--Preservation of Operating Profit
Markup Scenario
----------------------------------------------------------------------------------------------------------------
Trial standard
level
Units Base case ---------------
1
----------------------------------------------------------------------------------------------------------------
INPV.......................................... (2013$ millions)................ 145.4 89.2
Change in INPV................................ (2013$ millions)................ .............. (56.2)
(%)............................. .............. -38.6
Product Conversion Costs...................... (2013$ millions)................ .............. 6.2
Capital Conversion Costs...................... (2013$ millions)................ .............. 66.4
Total Conversion Costs........................ (2013$ millions)................ .............. 72.6
----------------------------------------------------------------------------------------------------------------
TSL 1 sets the efficacy level at EL 1, max tech, for the IRL
representative unit. At TSL 1, DOE estimates impacts on INPV to range
from -$52.5 million to -$56.2 million, or a change in INPV of -36.1
percent to -38.6 percent. At TSL 1, industry free cash flow is
estimated to decrease by approximately 142 percent to -$9.3 million,
compared to the base-case value of $22.64 million in 2017.
INPV impacts are significantly negative at TSL 1, regardless of the
markup scenario chosen. DOE estimates that in 2018, approximately half
of the IRL shipments would meet the efficacy requirements at TSL 1. The
other half of the shipments would need to be converted to meet the
standards at this TSL.
DOE expects substantial conversion costs for IRL manufacturers at
TSL 1 associated with increasing the efficacy of IRLs. Manufacturers
would have to invest in retooling burner machines, increasing coating
capacity, and upgrading their production lines to allow for enhanced
reflector coating. Some manufacturers expressed concern that they do
not currently possess the technology required at the analyzed standard
level and could exit the market entirely. Overall, DOE expects these
capital conversion costs to total $66.4 million for the industry. DOE
estimates that IRL manufacturers will also incur $6.2 million in
product conversion costs for lamp and production line redesign, as well
as testing and certification.
At TSL 1, under the flat markup scenario, the shipment-weighted-
average MPC increases by 12 percent relative to the base-case MPC. In
this scenario, INPV impacts are negative because the manufacturers'
ability to pass the higher production costs to consumers is outweighed
by the substantial $72.6 million conversion costs. Under the
preservation of operating profit markup scenario, the 12 percent MPC
increase is again outweighed by a lower average markup of 1.50
(compared to the flat markup scenario markup of 1.52) and $72.6 million
in conversion costs, resulting in significantly negative impacts at TSL
1. The significant capital and product conversion costs that IRL
manufacturers must make at TSL 1 cause INPV to be significantly
negative, regardless of the markup scenario analyzed.
DOE also analyzed a shortened lifetime sensitivity scenario where
manufacturers shorten the lifetime of IRLs to mitigate the investments
they must make to comply with the standards at TSL 1. By shortening the
lifetime of IRLs, manufacturers reduce the capital conversion costs
they must make to comply with the standards at TSL 1. DOE presents the
INPV results of this analysis in appendix 13B of this final rule TSD.
b. Impacts on Employment
DOE quantitatively assessed the impacts of potential amended energy
conservation standards on direct employment. DOE used the GRIM to
estimate the domestic labor expenditures and number of domestic
production workers in the base case and at each TSL from 2015 to 2047.
DOE used statistical data from the U.S. Census Bureau's 2011 Annual
Survey of Manufacturers (ASM), the results of the engineering analysis,
and interviews with manufacturers to determine the inputs necessary to
calculate industry-wide labor expenditures and domestic employment
levels. Labor expenditures involved with the manufacturing of the
product are a function of the labor intensity of the product, the sales
volume, and an assumption that wages remain fixed in real terms over
time.
In the GRIM, DOE used the labor content of each product and the
MPCs to estimate the annual labor expenditures in the industry. DOE
used census data and interviews with manufacturers to estimate the
portion of the total labor expenditures that is attributable to
domestic labor.
The production worker estimates in this section only cover workers
up to the line-supervisor level involved in fabricating and assembling
a product within a manufacturing facility. Workers performing services
that are closely associated with production operations, such as
material handing with a forklift, are also included as production
labor. DOE's estimates account for production workers who manufacture
only the specific products covered of this rulemaking. For example, a
worker on a fluorescent lamp ballast production line would not be
included with the estimate of the number of GSFL or IRL workers.
The employment impacts shown in Table VII.35 and Table VII.36
represent the potential production employment that could result
following amended energy conservation standards. The upper bound of the
results estimates the maximum change in the number of production
workers that could occur after compliance with potential amended
standards when assuming that manufacturers continue to produce the same
scope of covered products in the same production facilities. It also
assumes that domestic production does not shift to lower labor-cost
countries. Because there is a real risk of manufacturers evaluating
sourcing decisions in response to potential amended standards, the
lower bound of the employment results includes the estimated total
number of U.S. production workers in the industry who could lose their
jobs if some or all existing production were moved outside of the
United States. While the results present a range of employment impacts
following 2018, the following sections also include qualitative
discussions of the likelihood of negative employment impacts at the
various TSLs. Finally, the employment impacts shown are independent of
the employment impacts from the broader U.S. economy, documented in
chapter 17 of this final rule TSD.
[[Page 4131]]
Employment Impacts for General Service Fluorescent Lamps
Using 2011 ASM data and interviews with manufacturers, DOE
estimates that approximately three quarters of the GSFLs sold in the
United States are manufactured domestically. With this assumption, DOE
estimates that in the absence of amended energy conservation standards,
there would be approximately 1,937 domestic production workers involved
in manufacturing GSFLs in 2018. Table VII.35 shows the range of the
impacts of amended energy conservation standards on U.S. production
workers in the GSFL industry.
Table VII.35--Potential Changes in the Total Number of Domestic General Service Fluorescent Lamp Production Workers in 2018
--------------------------------------------------------------------------------------------------------------------------------------------------------
Trial standard level
Base case -------------------------------------------------------------------------
1 2 3 4 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Total Number of Domestic Production Workers in 2018 (without 1,937 1,937 1,937 1,934 1,918 1,916
changes in production locations)................................
Potential Changes in Domestic Production Workers in 2018 *....... ........... ........... ........... (3)-(1,937) (19)-(1,937) (21)-(1,937)
--------------------------------------------------------------------------------------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in parentheses indicate negative numbers.
At the upper end of the range, all examined TSLs show slight
negative impacts on domestic employment levels. DOE believes that
manufacturers could face slight negative impacts on domestic employment
levels because there would be an increase in the shipments of products
typically not manufactured domestically, such as 4-foot T5 MiniBP
lamps, and a decrease of products typically manufactured domestically,
such as 4-foot MBP lamps.
Several manufacturers emphasized that it is difficult to predict
employment impacts of energy conservation standards. One potential
uncertainty is the future price of REOs and these employment decisions
become more complex when more REOs are required for higher efficacious
products.
DOE does not expect any significant changes in domestic employment
at TSLs 1 or 2 because standards would not be amended for 4-foot MBP
lamps, which comprise approximately 83 percent of GSFL shipments in
2018. While DOE does not anticipate the entire, or even a large portion
of, domestic employment to move abroad at TSLs 3, 4, or 5, DOE
acknowledges that there could be a loss of domestic employment at these
TSLs due to the required increase in efficacy of 4-foot MBP lamps. The
potential loss of domestic employment would most likely be a result of
a possible increase in the price of REOs. Based on the REO prices
modeled in the reference case, DOE does not estimate a significant loss
of domestic employment at TSLs 3, 4, or 5. Overall, manufacturers were
uncertain about how amended energy conservation standards would affect
domestic employment and sourcing decisions. Ultimately, both employment
and sourcing decisions could be determined by the stability and
predictability of REO prices.
Employment Impacts for Incandescent Reflector Lamps
Using 2011 ASM data and interviews with manufacturers, DOE
estimates that approximately half of the IRLs sold in the United States
are manufactured domestically. With this assumption, DOE estimates that
in the absence of potential amended energy conservation standards,
there would be approximately 281 domestic production workers involved
in manufacturing IRLs in 2018. Table VII.36 shows the range of the
impacts of potential amended energy conservation standards on U.S.
production workers in the IRL industry.
Table VII.36--Potential Changes in the Total Number of Domestic
Incandescent Reflector Lamp Production Workers in 2018
------------------------------------------------------------------------
Trial standard
level
Base case ---------------
1
------------------------------------------------------------------------
Total Number of Domestic Production 281 303
Workers in 2018 (without changes in
production locations)..................
Potential Changes in Domestic Production .............. 22-(281)
Workers in 2018 *......................
------------------------------------------------------------------------
* DOE presents a range of potential employment impacts. Numbers in
parentheses indicate negative numbers
At the upper end of the range TSL 1 shows a slight positive impact
on domestic employment levels. The increasing product cost at TSL 1
would result in higher labor expenditures per-unit, which could cause
manufacturers to hire more domestic workers to meet this added labor
demand, assuming IRL production remains in domestic facilities.
Manufacturers are concerned that higher prices for IRLs will drive
consumers to alternate technologies and it may not make economic sense
for them to continue to produce IRLs. Increasing the efficacy of IRLs
would cost manufacturers millions in capital conversion costs. Some
stated that they do not have the technology to meet the potential
energy conservation standards and said it is possible they would not
spend their limited resources to convert all IRL production to meet
efficacy levels at TSL 1. Ultimately, the high investment costs
associated with increasing the efficacy of IRLs could cause some IRL
manufacturers to exit the market or move production abroad.
As part of the MIA for the NOPR, DOE presented a range of potential
impacts on domestic IRL employment at the proposed standard level, TSL
1 for the NOPR. In the NOPR analysis for IRLs, the impact at TSL 1
ranged from an additional hiring of approximately 30 employees, due to
the increase in
[[Page 4132]]
production costs of IRLs at TSL 1, to a potential decrease of
approximately 300 employees, if all domestic IRL manufacturing moved
overseas. NEMA stated that the lower bound scenario, where up to 300
domestic employees would lose their job, would be the most likely
scenario if DOE adopted IRL standards at TSL 1. (NEMA, No. 54 at p. 9)
GE similarly expressed concern at the NOPR public meeting, stating that
if IRL manufacturers are required to make significant investments to
keep IRL production in the United States, it will put any domestic IRL
production employment at risk. (GE, Public Meeting Transcript, No. 49
at p. 232)
DOE presents a range of possible domestic employment impacts due to
the uncertainty regarding the future production location of IRLs (i.e.,
domestic versus foreign) as manufacturers could move current domestic
production overseas as a result of IRL standards. DOE understands there
is a real risk that IRL manufacturers could either move domestic
production to a lower labor-cost country in an effort to reduce labor
expenditures or they could exit the IRL market altogether due to
declining market share of IRLs. DOE took into consideration any
potential negative domestic employment impact on U.S. manufacturing
caused by either manufacturers moving IRL production overseas in
response to potential standards or IRL manufacturers potentially
exiting the market before selecting the standards for IRLs in this
final rule.
NEMA also commented that the increase in the price of IRLs caused
by potential standards could cause consumers to forgo purchasing IRLs
in favor of LEDs. Therefore, NEMA believes that there could be a
significant reduction in the number of IRLs purchased by consumers, as
a result of IRL standards, which will cause domestic IRL manufacturing
to be severely impacted. (NEMA, No. 54 at p. 10) While DOE recognizes
that LEDs are increasingly taking more and more market share from IRLs
over time, DOE's shipment analysis does not model consumers switching
from IRLs to LEDs as a result of higher energy conservation standards
of IRLs. Therefore, DOE does not anticipate a reduction in the number
of domestic employees caused by consumers forgoing the purchases of
IRLs in favor of LEDs as a result of potential IRL standards. See
chapter 11 of this final rule TSD for a complete description of the
shipments analysis.
c. Impacts on Manufacturing Capacity
GSFL manufacturers stated that they did not anticipate any capacity
constraints outside of the availability of REOs. One manufacturer
pointed out during manufacturer interviews that moving the industry to
max tech could triple the amount of REOs demanded by GSFL
manufacturers. Tripling the demand for REOs that are already difficult
to obtain could trigger some capacity concerns by creating extra
volatility in the market. The sharp increase in demand for REOs could
cause wide variations in the price and availability of REOs, making
production costs more unpredictable.
A few IRL manufacturers expressed concern during manufacturer
interviews that their IR coating machines would not have a large enough
capacity and that the companies that manufacture those machines might
not be able to respond to the demand for IR coating machines necessary
to manufacture more efficacious IRLs. Meeting the high level of coating
capacity as a result of higher efficacy standards for IRLs this rule
may be more difficult for smaller manufacturers than larger
manufacturers. Some manufactures suggested that large manufacturers may
already have the coating capacity necessary and that the smaller
manufacturers may need to incur capital expenditures to add coating
capacity at higher standards.
d. Impacts on Subgroups of Manufacturers
Using average cost assumptions to develop an industry cash-flow
estimate may not be adequate for assessing differential impacts among
manufacturer subgroups. Small manufacturers, niche product
manufacturers, and manufacturers exhibiting cost structures
substantially different from the industry average could be affected
disproportionately. DOE analyzed the impacts to small businesses in
section VIII.B and did not identify any other adversely impacted
subgroups for GSFLs or IRLs for this rulemaking based on the results of
the industry characterization.
e. Cumulative Regulatory Burden
While any one regulation may not impose a significant burden on
manufacturers, the combined effects of recent or impending regulations
may have serious consequences for some manufacturers, groups of
manufacturers, or an entire industry. Assessing the impact of a single
regulation may overlook this cumulative regulatory burden. In addition
to energy conservation standards, other regulations can significantly
affect manufacturers' financial operations. Multiple regulations
affecting the same manufacturer can strain profits and lead companies
to abandon product lines or markets with lower expected future returns
than competing products. For these reasons, DOE conducts an analysis of
cumulative regulatory burden as part of its rulemakings pertaining to
product efficacy.
For the cumulative regulatory burden analysis, DOE looks at other
regulations that could affect GSFL manufacturers that will take effect
approximately 3 years before or after the compliance date of amended
energy conservation standards for these products. In written comments,
manufacturers cited Federal regulations on products other than GSFLs
that contribute to their cumulative regulatory burden. The compliance
years and expected industry conversion costs of relevant amended energy
conservation standards are indicated in Table VII.37.
Table VII.37--Compliance Dates and Expected Conversion Expenses of Federal Energy Conservation Standards
Affecting General Service Fluorescent Lamp Manufacturers
----------------------------------------------------------------------------------------------------------------
Approximate compliance Estimated total industy conversion
Federal energy conservation standards date expense
----------------------------------------------------------------------------------------------------------------
General Service Incandescent Lamps, 74 FR 2012; 2013; & 2014 N/A [dagger]
12058 (March 23, 2009).
Fluorescent Lamp Ballasts, 76 FR 70548 2014 $82 million (2010$)
(November 14, 2011).
Metal Halide Lamp Fixtures, 79 FR 7746 2017 $3.0 million (2012$)
(February 10, 2014).
General Service Lamps....................... * 2019 N/A [Dagger][Dagger]
Ceiling Fan Light Kits...................... * 2019 N/A[Dagger][Dagger]
HID Lamps, 79 FR 62910 (October 21, 2014)... ** N/A N/A[Dagger][Dagger]
Candelabra Base Incandescent Lamps and *** N/A N/A[Dagger][Dagger]
Intermediate Base Incandescent Lamps.
[[Page 4133]]
Other Incandescent Reflector Lamps.......... *** N/A N/A[Dagger][Dagger]
----------------------------------------------------------------------------------------------------------------
[dagger] For minimum performance requirements prescribed by the Energy Independence and Security Act of 2007
(EISA 2007), DOE did not estimate total industry conversion costs because an MIA was not completed as part of
a rulemaking. Pub. L. 110-140. EISA 2007 made numerous amendments to the Energy Policy and Conservation Act
(EPCA) of 1975, Pub. L. 94-163, (42 U.S.C. 6291-6309), which established an energy conservation program for
major household appliances and industrial and commercial equipment.
[Dagger][Dagger] For energy conservation standards for rulemakings awaiting DOE final action, DOE does not have
a finalized estimated total industry conversion cost.
* The dates listed are an approximation. The exact dates are pending final DOE action.
** DOE has published a notice of proposed determination that did not establish energy conservation standards for
any HID lamps.
*** These rulemakings are placed on hold due to the Consolidated Appropriations Act, 2012 (Public Law 112-74).
NEMA commented that energy conservation standards have become
increasingly burdensome on lighting manufacturers as the lighting
sector has experienced more rulemakings since EISA 2007 than any other
covered product sector. NEMA also commented that several of these
standards have required significant investment from lighting
manufacturers and resulted in a negative financial impact to these
lighting manufacturers (NEMA, No. 54 at pp. 2-3) NEMA further stated,
that given the large negative impacts to manufacturers based on the
proposed IRL standards in the NOPR and the large negative impacts to
IRL manufacturers from the previous 2009 Lamps Rule, as well as the
other DOE prescribed energy conservation standards on lighting
manufacturers, Executive Order 12866 directs DOE to consider
``alternatives to direct regulation'' so that its regulations ``impose
the least burden on society, consistent with obtaining regulatory
objectives, taking into account, among other things, and to the extent
practicable, the cost of cumulative regulations.'' (NEMA, No. 54 at p.
8)
DOE agrees with NEMA that at least four major energy conservation
standards have been enacted on lighting products since EISA 2007. These
previous standards covered GSFLs and IRLs (74 FR 34080 [July 14,
2009]), which went into effect in July 2012, fluorescent lamp ballasts
(76 FR 70548 [November 14, 2011]), which went into effect in November
2014, and metal halide lamp fixtures (79 FR 7746 [February 10, 2014]),
which will go into effect in February 2017. DOE also agrees that the
INPV impacts to manufacturers for these rulemakings ranged from
moderate to significant, depending on the markup scenario analyzed. The
cumulative regulatory burden seeks to mitigate the overlapping effects
on manufacturers of new or revised DOE standards and other regulatory
actions affecting those same manufacturers. DOE considered the
cumulative regulatory burden on lighting manufacturers as one of the
burdens of complying with potential GSFL and IRL standards when
selecting the final standards for these products in this rule.
3. National Impact Analysis
Projections of shipments are an important input to the NIA. As
discussed in section VI.I, DOE developed a shipments model that
incorporated substitution matrixes, which specify the product choices
available to consumers (lamps as well as lamp-and-ballast combinations
for fluorescent lamps) depending on whether they are renovating
lighting systems, installing lighting systems in new construction, or
simply replacing lamps. The model includes a module that assigns
shipments to product classes and efficacy levels based on consumer
sensitivities to first costs and operation and maintenance costs. The
model estimates the shipments of each lamp type in the base case and
under the conditions set by each TSL. Table VII.37 and Table VII.38
present the estimated cumulative shipments in the base case and the
relative change under each TSL.
Table VII.38--Effect of Standard Cases on Cumulative Shipments of GSFL in 2018-2047
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base case TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
---------------------------------------------------------------------------------------------------------
Change in
Lamp type Cumulative shipments Change in Change in Change in Change in
shipments relative to shipments shipments shipments shipments
millions base case relative to base relative to base relative to base relative to base
(percent) case (percent) case (percent) case case (percent)
--------------------------------------------------------------------------------------------------------------------------------------------------------
4-foot MBP.................................... 5,800 0.00 0.24 -1.8 -12 -12
8-foot SP slimline............................ 190 0.00 -5.2 3.6 35 9.6
8-foot RDC HO................................. 43 0.00 -0.28 0.00 -0.01 -0.29
4-foot T5, MiniBP SO.......................... 330 0.00 0.77 23 160 170
4-foot T5, MiniBP HO.......................... 760 0.00 0.02 -0.01 -0.07 -0.05
2-foot U-shaped............................... 240 0.00 0.00 0.00 0.00 0.00
Total GSFL *.............................. 7,300 0.00 0.09 -0.24 -1.8 -1.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
* May not sum due to rounding.
[[Page 4134]]
Table VII.39--Effect of Standard Cases on Cumulative Shipments of IRL in 2018-2047
----------------------------------------------------------------------------------------------------------------
Base case TSL 1
---------------------------------
Change in
Lamp type Cumulative shipments
shipments relative to
millions base case
----------------------------------------------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V................................. 230 -16%
----------------------------------------------------------------------------------------------------------------
a. Significance of Energy Savings
For each TSL, DOE projected energy savings for GSFLs and IRLs
purchased in the 30-year period that begins in the year of anticipated
compliance with amended standards (2018-2047). The savings are measured
over the entire lifetime of products purchased in the 30-year period.
DOE quantified the energy savings attributable to each TSL as the
difference in energy consumption between each standards case and the
base case, accounting for the effects of the standards on product
switching and shipments. Table VII.39 presents the estimated energy
savings for each considered GSFL TSL, and Table VII.40 presents the
estimated energy savings for each IRL TSL. The approach for estimating
shipments and NES is further described in sections VI.I and VI.J and is
detailed in chapter 11 and 12 of the final rule TSD.
Table VII.40--Cumulative Energy Savings for GSFL Trial Standard Levels for Units Sold in 2018-2047
----------------------------------------------------------------------------------------------------------------
Trial standard level
--------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
quads
----------------------------------------------------------------------------------------------------------------
Primary Energy (Power Sector Consumption).......................... 0.18 0.19 0.71 2.4 2.4
FFC Energy......................................................... 0.19 0.20 0.74 2.5 2.6
----------------------------------------------------------------------------------------------------------------
Table VII.41--Cumulative Energy Savings for IRL Trial Standard Level for
Units Sold in 2018-2047
------------------------------------------------------------------------
------------------------------------------------------------------------
Trial Standard
Level
----------------
1
----------------
quads
----------------
Primary Energy (Power Sector Consumption).............. 0.011
FFC Energy............................................. 0.011
------------------------------------------------------------------------
OMB Circular A-4 \91\ requires agencies to present analytical
results, including separate schedules of the monetized benefits and
costs that show the type and timing of benefits and costs. Circular A-4
also directs agencies to consider the variability of key elements
underlying the estimates of benefits and costs. For this rulemaking,
DOE undertook a sensitivity analysis using nine, rather than 30, years
of product shipments. The choice of a 9-year period is a proxy for the
timeline in EPCA for the review of certain energy conservation
standards and potential revision of and compliance with such revised
standards.\92\ The review timeframe established in EPCA is generally
not synchronized with the product lifetime, product manufacturing
cycles, or other factors specific to GSFLs and IRLs. Thus, this
information is presented for informational purposes only and is not
indicative of any change in DOE's analytical methodology. The NES
results based on nine years of shipments are presented in Table VII.41
and Table VII.42. The impacts are counted over the lifetime of GSFLs
and IRLs purchased in 2018-2026.
---------------------------------------------------------------------------
\91\ U.S. Office of Management and Budget, ``Circular A-4:
Regulatory Analysis'' (Sept. 17, 2003) (Available at: http://www.whitehouse.gov/omb/circulars_a004_a-4/).
\92\ Section 325(m) of EPCA requires DOE to review its standards
at least once every 6 years, and requires, for certain products, a
3-year period after any new standard is promulgated before
compliance is required, except that in no case may any new standards
be required within 6 years of the compliance date of the previous
standards. While adding a 6-year review to the 3-year compliance
period adds up to 9 years, DOE notes that it may undertake reviews
at any time within the 6-year period and that the 3-year compliance
date may yield to the 6-year backstop. A 9-year analysis period may
not be appropriate given the variability that occurs in the timing
of standards reviews and the fact that, for some consumer products,
the compliance period is 5 years rather than 3 years.
Table VII.42--Cumulative Energy Savings for GSFL Trial Standard Levels for Units Sold in 2018-2026
----------------------------------------------------------------------------------------------------------------
Trial standard level
--------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
quads
----------------------------------------------------------------------------------------------------------------
Primary Energy (Power Sector Consumption).......................... 0.098 0.10 0.38 1.2 1.2
FFC Energy......................................................... 0.10 0.11 0.39 1.2 1.2
----------------------------------------------------------------------------------------------------------------
[[Page 4135]]
Table VII.43--Cumulative Energy Savings for IRL Trial Standard Level for
Units Sold in 2018-2026
------------------------------------------------------------------------
------------------------------------------------------------------------
Trial
Standard
Level
-------------
1
-------------
quads
-------------
Primary Energy (Power Sector Consumption)................. 0.0089
FFC Energy................................................ 0.0093
------------------------------------------------------------------------
b. Net Present Value of Consumer Costs and Benefits
DOE estimated the cumulative NPV of the total costs and savings for
consumers that would result from the TSLs considered for GSFLs and
IRLs. DOE quantified the costs and benefits attributable to each TSL as
the difference in total product costs and total operating costs between
each standards case and the base case, accounting for the effects of
the standards on product switching and shipments.
A portion of the savings in operating costs in some of the TSLs is
due to switching to products with lower operating costs. In particular,
the adopted standard in the rulemaking is projected to increase the
typical cost of 4-foot MBP lamps relative to 8-foot SP slimline or 4-
foot MiniBP T5s, therefore driving some consumers to shift toward the
latter two product classes, yielding a reduction in operating costs
relative to the base case.
Table VII.43 shows the consumer NPV results for each TSL considered
for GSFLs, and Table VII.44 shows the consumer NPV results for each TSL
considered for IRLs. In each case, the impacts cover the lifetime of
product purchased in 2018-2047.
Table VII.44--Net Present Value of Consumer Benefits for GSFL Trial Standard Levels for Units Sold in 2018-2047
----------------------------------------------------------------------------------------------------------------
billion 2013$
-------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
7% discount rate.............................................. -0.37 -0.51 0.35 2.0 1.6
3% discount rate.............................................. -0.42 -0.61 1.1 5.5 4.9
----------------------------------------------------------------------------------------------------------------
Table VII.45--Net Present Value of Consumer Benefits for IRL Trial
Standard Level for Units Sold in 2018-2047
------------------------------------------------------------------------
TSL 1
-----------------
billion 2013$
------------------------------------------------------------------------
7% discount rate...................................... 0.17
3% discount rate...................................... 0.25
------------------------------------------------------------------------
The NPV results based on the aforementioned 9-year shipments period
are presented in Table VII.45 and Table VII.46. The impacts are counted
over the lifetime of product purchased in 2018-2026. As mentioned
previously, this information is presented for informational purposes
only and is not indicative of any change in DOE's analytical
methodology or decision criteria.
Table VII.46--Net Present Value of Consumer Benefits for GSFL Trial Standard Levels for Units Sold in 2018-2026
----------------------------------------------------------------------------------------------------------------
billion 2013$
-------------------------------------------------
TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
7% discount rate.............................................. -0.26 -0.37 0.16 0.65 0.33
3% discount rate.............................................. -0.25 -0.4 0.52 1.9 1.5
----------------------------------------------------------------------------------------------------------------
Table VII.47--Net Present Value of Consumer Benefits for IRL Trial
Standard Level for Units Sold in 2018-2026
------------------------------------------------------------------------
TSL 1
-----------------
billion 2013$
------------------------------------------------------------------------
7% discount rate...................................... 0.14
3% discount rate...................................... 0.19
------------------------------------------------------------------------
c. Alternative Scenario Analyses
As discussed in section VI.I and VI.J, DOE conducted several
sensitivity analyses to determine the potential impact of uncertain
future prices for materials that are important to the manufacture of
efficient GSFL and IRL products.
In the case of GSFLs, DOE considered the possibility that the price
of rare earth oxides would rise again. As mentioned in section VI.I,
rare earth oxides, used in GSFL phosphors to improve lamp efficacy,
underwent a large price spike in 2010 and 2011, but their prices have
since lowered to almost their pre-spike level. To assess the effect of
higher rare earth prices on the impact of energy conservation standards
for GSFLs, DOE performed an alternative analysis in which the average
price of rare earth oxides was assumed to be midway between the peak of
the 2011 price spike and the pre-spike level, and was assumed to remain
at that elevated level throughout the analysis period. The details of
the price model that DOE used for this analysis are given in appendix
11B of the final rule TSD. The impacts of the modeled rare earth oxide
price increase on the NES and NPV of this rulemaking were small to
moderate and did not affect the ranking of the TSLs (see chapter 12 of
the final rule TSD).
In the case of IRLs, DOE considered the possibility of a
significant increase in the price of xenon gas, which DOE believes is
now used as a fill gas in all standards-compliant IRL products. Demand
for xenon gas has been rising recently, which may lead to price
[[Page 4136]]
increases in the future. To assess the effect of a significant xenon
price increase on the impact of an energy conservation standard for
IRLs, DOE performed an alternative analysis in which the price of xenon
is assumed to increase by a factor of ten in the near future and remain
at these elevated levels throughout the analysis period. The details of
the xenon market assessment used to inform this analysis are given in
appendix 7C of the final rule TSD. The impacts of the modeled xenon
price increase on the NES and NPV of this rulemaking were minimal and
did not affect the ranking of the TSLs (see chapter 12 of the final
rule TSD).
d. Indirect Impacts on Employment
DOE expects energy conservation standards for GSFLs and IRLs to
reduce energy costs for product owners and the resulting net savings to
be redirected to other forms of economic activity. Those shifts in
spending and economic activity could affect the demand for labor. As
described in section VI.O, DOE used an input/output model of the U.S.
economy to estimate indirect employment impacts of the TSLs that DOE
considered in this rulemaking. DOE understands that there are
uncertainties involved in projecting employment impacts, especially
changes in the later years of the analysis. Therefore, DOE generated
results for near-term time frames, where these uncertainties are
reduced.
The results suggest that the standards are likely to have
negligible impact on the net demand for labor in the economy. The net
change in jobs is so small that it would be imperceptible in national
labor statistics and might be offset by other, unanticipated effects on
employment. Chapter 17 of the final rule TSD presents detailed results.
4. Impact on Utility or Performance of Equipment
DOE concluded that the standards it proposed in the NOPR will not
lessen the utility or performance of GSFLs and IRLs. DOE reached this
conclusion based on the analyses conducted to develop the proposed GSFL
and IRL efficacy levels. In the engineering analysis, DOE considered
only technology options that would not have adverse impacts on product
utility. See section VI.B and chapter 4 of the final rule TSD for
further details regarding the screening analysis. DOE also divided
products in to classes based on performance-related features that
justify different standard levels such as those impacting consumer
utility. DOE then developed separate standard levels for each product
class. See section VI.C and chapter 3 of the final rule TSD for further
details regarding product classes selected and consumer utility.
Further, DOE's evaluation shows that products meeting proposed
efficacy levels are not of lesser utility or performance than products
at existing standard levels. DOE considered several characteristics
when evaluating utility and performance of GSFLs including physical
constraints (i.e., shape and size), diameter, lumen package, color
quality (i.e., CCT and CRI), lifetime, and ability to dim. As discussed
in section VI.B.1, DOE ensured full wattage lamps were able to meet the
proposed efficacy levels to preserve reliable dimming. DOE determined
that these GSFL performance characteristics were not diminished for any
proposed standard level. For IRLs, DOE considered lumen package,
lifetime, shape, and diameter when evaluating utility and performance.
DOE determined that these IRL performance characteristics were not
diminished for any proposed standard level. DOE did not assess CRI or
CCT for IRLs because they are intended as a measure of the light
quality of non-incandescent/halogen lamps when compared with
incandescent/halogen lamps. See section VI.D and chapter 5 of the final
rule TSD for further details on the selection of more efficacious
substitutes for the baseline and development of proposed efficacy
levels.
5. Impact of Any Lessening of Competition
Per EPCA, DOE is required to establish energy conservation
standards that ``shall be designed to achieve the maximum improvement
in energy efficiency * * * which the Secretary determines is
technologically feasible and economically justified.'' (42 U.S.C.
6295(o)(2)(A)) To determine economic justification, DOE considers
(among other factors) ``the economic impact of the standard on the
manufacturers'' and ``the impact of any lessening of competition * * *
that is likely to result.'' (42 U.S.C. 6295(o)(2)(B)(i))
NEMA noted that the efficacy levels proposed for IRLs in the NOPR
were dependent on the use of a single-ended IR burner which is limited
to a single company due to patent, and that DOE legally cannot favor a
single company over all others. (NEMA, No. 54 at p. 10) NEMA commented
that only one US manufacturer has an industrial setup to produce
single-ended IR burners which are used in smaller diameter lamps. NEMA
remarked that the 3.5 percent discount in efficacy would grant a
competitive advantage to this manufacturer. (NEMA, No. 54 at pp. 30-31)
In the engineering analysis, DOE scaled the efficacy levels of
large diameter IRLs (i.e., greater than 2.5 inches) to determine the
efficacy levels of small diameter IRLs (i.e., equal to or less than 2.5
inches). In addition to a reduction in efficacy due to a small
diameter, DOE also applied an additional 3.5 percent reduction to
account for the need to use single-ended burners in small diameter
lamps to maintain the same shape. DOE did not find a patent specific to
single-ended burners used in small diameter IRLs and therefore,
believes single-ended technology is accessible. Also, based on
interviews with manufacturers DOE does not believe there are any
technical impediments to setting up the production of single-ended
small diameter IRLs. DOE acknowledges that manufacturers who do not
currently have the industrial setup to produce single-ended IR burners,
could face additional conversion costs to implement this production
setup than manufacturers that already have this production setup. DOE
did not include these additional conversion costs for those
manufacturers without single-ended burner production capabilities in
the MIA since there are no manufacturers currently producing small
diameter IRLs that are within the scope of this rulemaking and the MIA
typically only analyzes the costs associated with maintaining the total
base case production volume at the standards efficacy levels for each
product class.
While DOE acknowledges that there could be additional costs for
manufacturers without single-ended burner production capabilities,
based on manufacturer interviews and an assessment of the technology,
DOE does not believe there is a technical or legal (i.e., patent)
barrier to implementing a single-ended burner manufacturing process.
Therefore, DOE concluded that the efficacy level determined for IRLs in
this final rule would not result in competitive disadvantage to
manufacturers.
DOJ also reviewed the standards proposed in the NOPR analysis for
GSFLs and IRLs and similarly concluded that they are unlikely to have a
significant adverse impact on competition.
6. Need of the Nation To Conserve Energy
Enhanced energy efficiency, where economically justified, improves
the nation's energy security, strengthens the economy, and reduces the
[[Page 4137]]
environmental impacts or costs of energy production. Reduced
electricity demand due to energy conservation standards is also likely
to reduce the cost of maintaining the reliability of the electricity
system, particularly during peak-load periods. As a measure of this
reduced demand, the Utility Impact Analysis show reductions in
electricity generation and installed capacity across the analysis
period, with the magnitude and peak of these reductions varying by
electricity source fuel type, such as coal, natural gas, nuclear, oil,
and renewables. Chapter 16 in the final rule TSD presents the estimated
reduction in generation and installed capacity for the TSLs that DOE
considered in this rulemaking.
Energy savings from standards for GSFLs and IRLs could also produce
environmental benefits in the form of reduced emissions of air
pollutants and GHGs associated with electricity production. Table
VII.47 and Table VII.48 provide DOE's estimate of cumulative emissions
reductions projected to result from the TSLs considered in this
rulemaking. DOE reports annual emissions reductions for each TSL in
chapter 14 of the final rule TSD.
Table VII.48--Cumulative Emissions Reduction Estimated for GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Trial Standard Level
-----------------------------------------------------------
1 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 12 12 45 150 150
SO2 (thousand tons)................................. 11 11 41 140 140
NOX (thousand tons)................................. 9.4 9.8 36 120 120
Hg (tons)........................................... 0.033 0.034 0.13 0.42 0.43
CH4 (thousand tons)................................. 1.0 1.1 4.0 14 14
N2O (thousand tons)................................. 0.15 0.15 0.58 2.0 2.0
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 0.58 0.60 2.3 7.7 7.9
SO2 (thousand tons)................................. 0.11 0.11 0.41 1.4 1.4
NOX (thousand tons)................................. 8.2 8.5 32 110 110
Hg (tons)........................................... 0.00024 0.00025 0.00093 0.0031 0.0032
CH4 (thousand tons)................................. 48 50 190 640 650
N2O (thousand tons)................................. 0.0052 0.0054 0.020 0.069 0.070
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
CO2 (million metric tons)........................... 12 13 48 160 160
SO2 (thousand tons)................................. 11 11 42 140 140
NOX (thousand tons)................................. 18 18 69 230 240
Hg (tons)........................................... 0.033 0.035 0.13 0.43 0.44
CH4 (thousand tons)................................. 49 51 190 650 660
CH4 (million tons CO2eq) *.......................... 1,400 1,400 5,400 18,000 19,000
N2O (thousand tons)................................. 0.15 0.16 0.60 2.0 2.1
N2O (thousand tons CO2eq) *......................... 41 42 160 540 550
----------------------------------------------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
Table VII.49--Cumulative Emissions Reduction Estimated for IRL Trial
Standard Level
------------------------------------------------------------------------
Trial
Standard
Level
-----------
1
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.74
SO2 (thousand tons)......................................... 0.75
NOX (thousand tons)......................................... 0.62
Hg (tons)................................................... 0.0023
CH4 (thousand tons)......................................... 0.06
N2O (thousand tons)......................................... 0.0085
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.032
SO2 (thousand tons)......................................... 0.006
NOX (thousand tons)......................................... 0.45
Hg (tons)................................................... 0.000014
CH4 (thousand tons)......................................... 0.0003
N2O (thousand tons)......................................... 2.6
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
CO2 (million metric tons)................................... 0.77
SO2 (thousand tons)......................................... 0.76
NOX (thousand tons)......................................... 1.1
Hg (tons)................................................... 0.0023
CH4 (thousand tons)......................................... 2.7
CH4 (thousand tons CO2eq)*.................................. 76
N2O (thousand tons)......................................... 0.0088
N2O (thousand tons CO2eq)*.................................. 2.3
------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
As part of the analysis for this rule, DOE estimated monetary
benefits likely to result from the reduced emissions of CO2
and NOX that DOE estimated for each of the TSLs considered.
As discussed in section VI.M.1, DOE used the most recent values for the
SCC developed by an interagency process. The four sets of SCC values
resulting from that process (expressed in 2013$) represented by $12.0/
metric ton (the average value from a distribution that uses a 5-percent
discount rate), $40.5/metric ton (the average value from a distribution
that uses a 3-percent discount rate), $62.4/metric ton (the average
value from a distribution that uses a 2.5-percent discount rate), and
$119/metric ton (the 95th-percentile value from a distribution that
uses a 3-percent discount rate). These values correspond to the value
of emission reductions in 2015; the values for later years are higher
due to increasing
[[Page 4138]]
damages as the projected magnitude of climate change increases.
Table VII.49 and Table VII.50 present the global value of
CO2 emissions reductions at each TSL. For each of the four
cases, DOE calculated a present value of the stream of annual values
using the same discount rate as was used in the studies upon which the
dollar-per-ton values are based. DOE calculated domestic values as a
range from 7 percent to 23 percent of the global values, and these
results are presented in chapter 15 of the final rule TSD.
Table VII.50--Estimates of Global Present Value of CO2 Emissions Reduction Under GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
SCC Case *
---------------------------------------------------------------------------
TSL 5% discount rate, 3% discount rate, 2.5% discount 3% discount rate,
average * average * rate, average * 95th percentile *
----------------------------------------------------------------------------------------------------------------
Million 2013$
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 100 430 660 1,300
2................................... 110 440 690 1,400
3................................... 390 1,600 2,600 5,000
4................................... 1,300 5,400 8,500 17,000
5................................... 1,300 5,600 8,700 17,000
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 5.0 21 33 65
2................................... 5.2 22 34 67
3................................... 19 82 130 250
4................................... 65 270 430 840
5................................... 66 280 440 860
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 110 450 690 1,400
2................................... 110 470 720 1,400
3................................... 410 1,700 2,700 5,300
4................................... 1,400 5,700 8,900 18,000
5................................... 1,400 5,800 9,100 18,000
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.0, $40.5, $62.4, and $119
per metric ton (2013$).
Table VII.51--Estimates of Global Present Value of CO2 Emissions Reduction Under IRL Trial Standard Level
----------------------------------------------------------------------------------------------------------------
SCC Case *
---------------------------------------------------------------------------
TSL 5% discount rate, 3% discount rate, 2.5% discount 3% discount rate,
average * average * rate, average * 95th percentile *
----------------------------------------------------------------------------------------------------------------
Million 2013$
----------------------------------------------------------------------------------------------------------------
Power Sector Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 7.1 28 44 86
----------------------------------------------------------------------------------------------------------------
Upstream Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 0.31 1.2 1.9 3.7
----------------------------------------------------------------------------------------------------------------
Total Emissions
----------------------------------------------------------------------------------------------------------------
1................................... 7.4 30 46 90
----------------------------------------------------------------------------------------------------------------
* For each of the four cases, the corresponding SCC value for emissions in 2015 is $12.0, $40.5, $62.4, and $119
per metric ton (2013$).
DOE is well aware that scientific and economic knowledge about the
contribution of CO2 and other GHG emissions to changes in
the future global climate and the potential resulting damages to the
world economy continues to evolve rapidly. Thus, any value placed on
reducing CO2 emissions in this rulemaking is subject to
change. DOE, together with other Federal agencies, will continue to
review various methodologies for estimating the monetary value of
reductions in CO2 and other GHG emissions. This ongoing
review will consider the comments on this subject that are part of the
public record for this and other rulemakings, as well as other
methodological assumptions and issues. However, consistent with DOE's
legal obligations, and taking into account the uncertainty involved
with this particular issue, DOE has included in this amended rule the
[[Page 4139]]
most recent values and analyses resulting from the interagency process.
DOE also estimated the cumulative monetary value of the economic
benefits associated with NOX emissions reductions
anticipated to result from amended standards for GSFLs and IRLs. The
dollar-per-ton value that DOE used is discussed in section VI.L. Table
VII.51 and Table VII.52 present the cumulative present values for each
TSL calculated using 7-percent and 3-percent discount rates.
Table VII.52--Estimates of Present Value of NOX Emissions Reduction
Under GSFL Trial Standard Levels
------------------------------------------------------------------------
3% discount 7% discount
TSL rate rate
------------------------------------------------------------------------
Million 2013$
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1............................................. 17 11
2............................................. 18 12
3............................................. 66 42
4............................................. 210 130
5............................................. 220 140
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1............................................. 14 8.8
2............................................. 15 9.3
3............................................. 56 34
4............................................. 190 110
5............................................. 190 110
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1............................................. 32 20
2............................................. 33 21
3............................................. 120 75
4............................................. 400 240
5............................................. 410 250
------------------------------------------------------------------------
Table VII.53--Estimates of Present Value of NOX Emissions Reduction
Under IRL Trial Standard Level
------------------------------------------------------------------------
3% discount 7% discount
TSL rate rate
------------------------------------------------------------------------
Million 2013$
------------------------------------------------------------------------
Power Sector Emissions
------------------------------------------------------------------------
1............................................. 1.3 0.97
------------------------------------------------------------------------
Upstream Emissions
------------------------------------------------------------------------
1............................................. 0.92 0.67
------------------------------------------------------------------------
Total Emissions
------------------------------------------------------------------------
1............................................. 2.2 1.6
------------------------------------------------------------------------
7. Summary of National Economic Impacts
The NPV of the monetized benefits associated with emissions
reductions can be viewed as a complement to the NPV of the consumer
savings calculated for each TSL considered in this rulemaking. Table
VII.53 presents the NPV values that result from adding the estimates of
the potential economic benefits resulting from reduced CO2
and NOX emissions in each of four valuation scenarios to the
NPV of consumer savings calculated for each TSL considered in this
rulemaking, at both a 7-percent and 3-percent discount rate. The
CO2 values used in the columns of each table correspond to
the four sets of SCC values discussed previously.
Table VII.54--Net Present Value of Consumer Savings Combined With Present Value of Monetized Benefits From CO2
and NOX Emissions Reductions Under GSFL Trial Standard Levels
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 3% Discount Rate added with:
---------------------------------------------------------------------------
TSL SCC Case $12.0/ SCC Case $40.5/ SCC Case $62.4/ SCC Case $119/
metric ton CO2 metric ton CO2 metric ton CO2 metric ton CO2
plus NOX* plus NOX* plus NOX* plus NOX*
----------------------------------------------------------------------------------------------------------------
Billion 2013$
----------------------------------------------------------------------------------------------------------------
1................................... -0.28 0.058 0.31 0.98
2................................... -0.47 -0.11 0.15 0.85
3................................... 1.7 3.0 3.9 6.5
4................................... 7.2 12 15 23
5................................... 6.7 11 14 23
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% Discount Rate added with:
---------------------------------------------------------------------------
TSL SCC Case $12.0/ SCC Case $40.5/ SCC Case $62.4/ SCC Case $119/
metric ton CO2 metric ton CO2 metric ton CO2 metric ton CO2
plus NOX* plus NOX* plus NOX* plus NOX*
---------------------------------------------------------------------------
Billion 2013$
----------------------------------------------------------------------------------------------------------------
1................................... -0.24 0.097 0.34 1.0
2................................... -0.37 0.153 0.24 0.94
3................................... 0.84 2.2 3.1 5.7
4................................... 3.6 8.0 11 20
5................................... 3.3 7.7 11 20
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2013$. For NOX emissions, each case uses the medium
value, which corresponds to $2,684 per ton.
[[Page 4140]]
Table VII.55--Net Present Value of Consumer Savings Combined With Present Value of Monetized Benefits from CO2
and NOX Emissions Reductions Under IRL Trial Standard Level
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
TSL SCC Case $12.0/ SCC Case $40.5/ SCC Case $62.4/ SCC Case
metric ton CO2 metric ton CO2 metric ton CO2 $119/metric ton
plus NOX* plus NOX* plus NOX* CO2 plus NOX*
-----------------------------------------------------------------------
Billion 2013$
----------------------------------------------------------------------------------------------------------------
1....................................... 0.26 0.29 0.30 0.35
----------------------------------------------------------------------------------------------------------------
Consumer NPV at 7% Discount Rate added with:
-----------------------------------------------------------------------
TSL SCC Case $12.0/ SCC Case $40.5/ SCC Case $62.4/ SCC Case
metric ton CO2 metric ton CO2 metric ton CO2 $119/metric ton
plus NOX* plus NOX* plus NOX* CO2 plus NOX*
-----------------------------------------------------------------------
Billion 2013$
----------------------------------------------------------------------------------------------------------------
1....................................... 0.18 0.20 0.22 0.26
----------------------------------------------------------------------------------------------------------------
* These label values represent the global SCC in 2015, in 2013$. For NOX emissions, each case uses the medium
value, which corresponds to $2,684 per ton.
Although adding the value of consumer savings to the values of
emission reductions provides a valuable perspective, two issues should
be considered. First, the national operating cost savings are domestic
U.S. consumer monetary savings that occur as a result of market
transactions, while the value of CO2 reductions is based on
a global value. Second, the assessments of operating cost savings and
the SCC are performed with different methods that use different time
frames for analysis. The national operating cost savings is measured
for the lifetime of product shipped in 2018-2047. The SCC values, on
the other hand, reflect the present value of future climate-related
impacts resulting from the emission of one metric ton of CO2
in each year. These impacts continue well beyond 2100.
C. Conclusions
When considering proposed standards, the new or amended energy
conservation standard that DOE adopts for any type (or class) of
covered product must be designed to achieve the maximum improvement in
energy efficiency that the Secretary determines is technologically
feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) In
determining whether a standard is economically justified, the Secretary
must determine whether the benefits of the standard exceed its burdens,
considering to the greatest extent practicable the seven statutory
factors discussed previously. (42 U.S.C. 6295(o)(2)(B)(i)) The new or
amended standard must also ``result in significant conservation of
energy.'' (42 U.S.C. 6295(o)(3)(B))
DOE considers the impacts of standards at each TSL, beginning with
the max tech level, to determine whether that level meets the
evaluation criteria. Where the max tech level is not justified, DOE
then considers the next most efficient level and undertakes the same
evaluation until it reaches the highest efficacy level that is
technologically feasible, economically justified, and saves a
significant amount of energy.
To aid the reader in understanding the benefits and/or burdens of
each TSL, Table VII.55 and Table VII.56 in this section summarize the
quantitative analytical results for each TSL, based on the assumptions
and methodology discussed herein. The efficacy levels contained in each
TSL are described in section VII.A. In addition to the quantitative
results presented in the tables, DOE also considers other burdens and
benefits that affect economic justification. These include the impacts
on identifiable subgroups of consumers who may be disproportionately
affected by a national standard (see section VII.B.1.b) and impacts on
employment. DOE discusses the impacts on employment in GSFL and IRL
manufacturing in section VII.B.2.b and discusses the indirect
employment impacts in section VII.B.3.d.
DOE also notes that the economics literature provides a wide-
ranging discussion of how consumers trade off upfront costs and energy
savings in the absence of government intervention. Much of this
literature attempts to explain why consumers appear to undervalue
energy efficiency improvements. There is evidence that consumers
undervalue future energy savings as a result of (1) a lack of
information; (2) a lack of sufficient salience of the long-term or
aggregate benefits; (3) a lack of sufficient savings to warrant
accelerating or altering purchases; (3) inconsistent weighting of
future energy cost savings relative to available returns on other
investments; (4) computational or other difficulties associated with
the evaluation of relevant tradeoffs; and (5) a divergence in
incentives (for example, renter versus owner or builder versus
purchaser). Other literature indicates that with less-than-perfect
foresight and a high degree of uncertainty about the future, it may be
rational for consumers to trade off these types of investments at a
higher-than-expected rate between current consumption and uncertain
future energy cost savings. This undervaluation suggests that
regulation that promotes energy efficiency can produce significant net
private gains (as well as producing social gains by, for example,
reducing pollution).
In DOE's current regulatory analysis, potential changes in the
benefits and costs of a regulation due to changes in consumer purchase
decisions are included in two ways. First, if consumers forego a
purchase of a product in the standards case, this decreases sales for
product manufacturers and the cost to manufacturers is included in the
MIA. Second, DOE accounts for energy savings attributable only to
products actually used by consumers in the standards case; if a
standard decreases the number of products purchased by consumers, this
decreases the potential energy savings from an energy conservation
standard. DOE provides estimates of changes in the volume of product
purchases in chapter 9 of the final rule TSD. DOE's current analysis
does not explicitly control for heterogeneity in consumer preferences,
preferences across subcategories of products or specific features, or
[[Page 4141]]
consumer price sensitivity variation according to household income.\93\
---------------------------------------------------------------------------
\93\ P.C. Reiss and M.W. White, Household Electricity Demand,
Revisited, Review of Economic Studies (2005) 72, 853-883.
---------------------------------------------------------------------------
While DOE is not prepared at present to provide a fuller
quantifiable framework for estimating the benefits and costs of changes
in consumer purchase decisions due to an energy conservation standard,
DOE is committed to developing a framework that can support empirical
quantitative tools for improved assessment of the consumer welfare
impacts of appliance standards. DOE has posted a paper that discusses
the issue of consumer welfare impacts of appliance standards, and
potential enhancements to the methodology by which these impacts are
defined and estimated in the regulatory process.\94\ DOE welcomes
comments on how to more fully assess the potential impact of energy
conservation standards on consumer choice and how to quantify this
impact in its future regulatory analysis.
---------------------------------------------------------------------------
\94\ Alan Sanstad, Notes on the Economics of Household Energy
Consumption and Technology Choice. Lawrence Berkeley National
Laboratory (2010) (Available at: http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/consumer_ee_theory.pdf.
---------------------------------------------------------------------------
1. Benefits and Burdens of Trial Standard Levels Considered for General
Service Fluorescent Lamps
Table VII.55 and Table VII.56 summarize the quantitative impacts
estimated for each TSL for GSFL.
Table VII.56--Summary of Analytical Results for GSFL: National Impacts
--------------------------------------------------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
National FFC Energy Savings quads
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.19 0.20 0.74 2.5 2.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPV of Consumer Benefits 2013$ billion
--------------------------------------------------------------------------------------------------------------------------------------------------------
13% discount rate.................................................. 0.42 0.61 1.1 5.5 4.9
17% discount rate.................................................. 0.37 0.51 0.35 2.0 1.6
rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr------------------------------------------------------------------------------------
Cumulative Emissions Reduction (Total FFC Emissions)
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (million metric tons).......................................... 12 13 48 160 160
SO2 (thousand tons)................................................ 11 11 42 140 140
NOX (thousand tons)................................................ 18 18 69 230 240
Hg (tons).......................................................... 0.033 0.035 0.13 0.43 0.44
CH4 (thousand tons)................................................ 49 51 190 650 660
CH4 (million tons CO2eq)*.......................................... 1,400 1,400 5,400 18,000 19,000
NO2 (thousand tons)................................................ 0.15 0.16 0.60 2.0 2.1
NO2 (thousand tons CO2eq) *........................................ 41 42 160 540 550
--------------------------------------------------------------------------------------------------------------------------------------------------------
Value of Emissions Reduction (Total FFC Emissions)
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2, 2013$ billion **.............................................. 0.11 to 1.4 0.11 to 1.4 0.41 to 5.3 1.4 to 18 1.4 to 18
NOX--3% discount rate, 2013$ million............................... 32 33 120 400 410
NOX--7% discount rate, 2013$ million............................... 20 21 75 240 250
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 is the quantity of CO2 that would have the same GWP.
** Range of the economic value of CO2 reductions is based on estimates of the global benefit of reduced CO2 emissions.
Table VII.57 Summary of Analytical Results for GSFL: Manufacturer and Consumer Impacts
----------------------------------------------------------------------------------------------------------------
Category TSL 1 TSL 2 TSL 3 TSL 4 TSL 5
----------------------------------------------------------------------------------------------------------------
Manufacturer Impacts
----------------------------------------------------------------------------------------------------------------
Change in Industry NPV (2013$ 49.5--(42.9) 48.2--(56.5) 130.4--(74.2) 426.8--(330.0) 444.6--(367.7)
million)[dagger]...............
(Base Case Industry NPV of
$1,551.6)......................
Change in Industry NPV 3.2--(2.8) 3.1--(3.6) 8.4--(4.8) 27.5--(21.3) 28.7--(23.7)
(%)[dagger]....................
----------------------------------------------------------------------------------------------------------------
Consumer Mean LCC Savings 2013$
----------------------------------------------------------------------------------------------------------------
4-foot MBP <=4,500 K............ 0.00 0.00 0.07 5.98 5.98
4-foot T5 MiniBP SO <=4,500 K... 2.87 2.87 2.87 5.68 5.68
4-foot T5 MiniBP HO <=4,500 K... 4.74 4.74 4.74 4.74 4.74
8-foot SP Slimline <=4,500 K.... 0.00 5.02 0.00 0.00 1.72
8-foot RDC HO <=4,500 K......... -9.66 -16.94 0.00 0.00 -16.94
Weighted Average *.............. 0.49 0.56 0.54 5.55 5.47
----------------------------------------------------------------------------------------------------------------
Consumer Mean PBP years**
----------------------------------------------------------------------------------------------------------------
4-foot MBP <=4,500 K............ 0.0 0.0 0.5 3.1 3.1
4-foot T5 MiniBP SO <=4,500 K... 1.2 1.2 1.2 4.0 4.0
4-foot T5 MiniBP HO <=4,500 K... 2.8 2.8 2.8 2.8 2.8
8-foot SP Slimline <=4,500 K.... 0.0 0.5 0.0 0.0 4.4
8-foot RDC HO <=4,500 K......... NER NER 0.0 0.0 NER
Weighted Average *.............. 0.3 0.3 0.8 3.0 3.2
[[Page 4142]]
Weighted-Average Consumers with 8.6 10.5 61.1 22.0 24.9
Net Cost (%)*..................
Weighted-Average Consumers with 5.9 6.9 34.9 73.4 75.1
Net Benefit (%)*...............
Weighted-Average Consumers with 85.5 82.6 4.0 4.6 0.0
No Impact (%)*.................
----------------------------------------------------------------------------------------------------------------
* DOE calculates the LCC savings and PBP relative to the baseline for each EL for each representative product
class. Each TSL corresponds to a specific EL for each representative product class. (See Table VII.1 for the
TSLs analyzed and the corresponding ELs.) The weighted averages are calculated by weighting the shares of each
product class in total projected shipments in 2018.
** Does not include weighting for ``NER'' scenarios. Entries of ``NER'' indicate standard levels that do not
reduce operating costs, which prevents the consumer from recovering the increased purchase cost.
[dagger] Values in parentheses are negative values.
First, DOE considered TSL 5, the most efficient level (max tech),
which would save an estimated total of 2.56 quads of energy, an amount
DOE considers significant. TSL 5 has an estimated NPV of consumer
benefit of $1.6 billion using a 7-percent discount rate, and $4.9
billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 5 are 160 million metric
tons of CO2, 240 thousand tons of NOX, 140
thousand tons of SO2, 0.44 tons of Hg, 660 thousand tons of
CH4, and 2.1 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reductions at TSL 5
ranges from $1.4 billion to $18 billion.
At TSL 5, DOE estimates industry will need to invest approximately
$39.1 million in conversion costs. At TSL 5, the projected change in
INPV ranges from a decrease of $367.7 million to an increase of $444.6
million, which equates to a decrease of 23.7 percent and an increase of
28.7 percent, respectively, in INPV for manufacturers of covered GSFLs.
At TSL 5, the weighted-average LCC savings is $5.98 for the 4-foot
MBP lamps, $5.68 for the 4-foot T5 MiniBP SO lamps, $4.74 for the 4-
foot T5 MiniBP HO lamps, $1.72 for the 8-foot SP slimline lamps, and -
$16.94 for the 8-foot RDC HO lamps.
At TSL 5, 8-foot HO lamps are required to meet EL 2, which
represents an 800 series full wattage T8 lamp. Because no reduced
wattage 8-foot HO lamps exist at this level, consumers who require 8-
foot HO lamps must purchase a more efficient lamp that consumes the
same amount of energy as lamps available at lower efficacy levels.
Thus, for an increased cost, these consumers must purchase a lamp that
produces more light but does not save energy. Because there are no
energy-saving options for 8-foot HO consumers at TSL 5, all consumers
that continue to purchase this lamp type would experience negative LCC
savings.
After considering the analysis and weighing the benefits and the
burdens, DOE has determined that at TSL 5 for GSFLs, the benefits of
energy savings, positive NPV of total consumer benefits, the overall
positive impacts on consumers, emission reductions and the estimated
monetary value of the emissions reductions would be outweighed by the
potential reduction in industry value and negative LCC savings
experienced by consumers of 8-foot RDC HO lamps. Therefore, the
Secretary has concluded that TSL 5 is not economically justified.
Next, DOE considered TSL 4, which represents the combination of ELs
that achieve the maximum NPV. TSL 4 would save an estimated total of
2.5 quads of energy, an amount DOE considers significant and approaches
maximum energy savings achieved at TSL 5. TSL 4 has an estimated NPV of
consumer benefit of $2.0 billion using a 7-percent discount rate, and
$5.5 billion using a 3 percent discount rate.
The cumulative emissions reductions at TSL 4 are 160 million metric
tons of CO2, 230 thousand tons of NOX, 140
thousand tons of SO2, 0.43 tons of Hg, 650 thousand tons of
CH4, and 2.0 thousand tons of N2O. The estimated
monetary value of the CO2 emissions reductions at TSL 4
ranges from $1.4 billion to $18 billion.
At TSL 4, DOE estimates industry will need to invest approximately
$26.6 million in conversion costs. At TSL 4, the projected change in
INPV ranges from a decrease of $330.0 million to an increase of $426.8
million, which equates to a decrease of 21.3 percent and an increase of
27.5 percent, respectively, in INPV for manufacturers of covered GSFLs.
At TSL 4, the weighted average LCC savings is $5.98 for the 4-foot
MBP lamps, $5.68 for the 4-foot T5 MiniBP SO lamps, and $4.74 for the
4-foot T5 MiniBP HO lamps. At TSL 4, no amended standard is adopted for
the 8-foot SP slimline lamps or 8- foot RDC HO lamps and therefore LCC
savings are not reported.
After considering the analysis and weighing the benefits and the
burdens, DOE determined that at TSL 4 for GSFLs, the benefits of energy
savings, positive NPV of total consumer benefits, the overall positive
impacts on consumers, emission reductions and the estimated monetary
value of the emissions reductions would outweigh the potential
reduction in industry value. The Secretary has concluded that TSL 4
would save a significant amount of energy and is technologically
feasible and economically justified.
Based on the above considerations, DOE adopts the energy
conservation standards for GSFLs at TSL 4. Table VII.57 presents the
adopted energy conservation standards for GSFLs.
Table VII.58--Energy Conservation Standards for GSFL
------------------------------------------------------------------------
Adopted level
Lamp type CCT K lm/W
------------------------------------------------------------------------
4-Foot Medium Bipin..................... <=4,500 92.4
>4,500 88.7
2-Foot U-Shaped......................... <=4,500 85.0
>4,500 83.3
8-Foot Slimline......................... <=4,500 97.0
>4,500 93.0
8-Foot High Output...................... <=4,500 92.0
>4,500 88.0
[[Page 4143]]
4-Foot Miniature Bipin Standard Output.. <=4,500 95.0
>4,500 89.3
4-Foot Miniature Bipin High Output...... <=4,500 82.7
>4,500 76.9
------------------------------------------------------------------------
2. Summary of Benefits and Costs (Annualized) of the Adopted Standards
for General Service Fluorescent Lamps
The benefits and costs of these standards, for product sold in
2018-2047, can also be expressed in terms of annualized values. The
annualized monetary values are the sum of (1) the annualized national
economic value of the benefits from consumer operation of product that
meet the amended standards (consisting primarily of operating cost
savings from using less energy, minus increases in product purchase and
installation costs, which is another way of representing consumer NPV),
and (2) the annualized monetary value of the benefits of emission
reductions, including CO2 emission reductions.\95\
---------------------------------------------------------------------------
\95\ See section VI.M for description of the method used for
annualization.
---------------------------------------------------------------------------
Estimates of annualized benefits and costs of the standards for
GSFL are shown in Table VII.58. The results under the primary estimate
are as follows. Using a 7-percent discount rate for benefits and costs
other than CO2 reduction, for which DOE used a 3-percent
discount rate along with the SCC series that has a value of $40.5/t in
2015, the cost of the standards in this rule is $841 million per year
in increased equipment costs, while the benefits are $1,030 million per
year in reduced equipment operating costs, $310 million in
CO2 reductions, and $22.4 million in reduced NOX
emissions. In this case, the net benefit amounts to $516 million per
year. Using a 3-percent discount rate for all benefits and costs and
the SCC series that has a value of $40.5/t in 2015, the cost of the
standards in this rule is $724 million per year in increased equipment
costs, while the benefits are $1,020 million per year in reduced
operating costs, $310 million in CO2 reductions, and $21.6
million in reduced NOX emissions. In this case, the net
benefit amounts to $627 million per year. \96\
---------------------------------------------------------------------------
\96\ The annualized consumer operating cost savings,
NOX reduction monetized value, and consumer incremental
product costs are higher with a 7-percent discount rate than with a
3-percent discount rate. This is in contrast to the present values
in Table VII.58. Under certain conditions, different present values
may lead to similar annualized values when calculated with different
discount rates. In this case, the combined effects of (a) projecting
to 2018 the present values that DOE calculated in 2014, and (b)
annualizing the projected values with 3 percent and 7 percent
discount rates over the 30-year analysis period, lead to similar
annualized values. For consumer incremental product costs, the
effect is more pronounced because the time series covers only 30
years, instead of the longer period covered for operating cost
savings and NOX reduction monetized value.
Table VII.59--Annualized Benefits and Costs of Amended Standards for GSFL (TSL 4) *
----------------------------------------------------------------------------------------------------------------
Low net benefits High net benefits
Discount rate Primary estimate estimate estimate
----------------------------------------------------------------------------------------------------------------
Million 2013$/year
----------------------------------------------------------------------------------------------------------------
Benefits
----------------------------------------------------------------------------------------------------------------
Consumer Operating Cost Savings. 7%................ 1,030............. 1,010............. 1,050
3%................ 1,020............. 1,000............. 1,050
CO2 Reduction Monetized Value 5%................ 97.5.............. 97.1.............. 97.5
($12.0/t case) **.
CO2 Reduction Monetized Value 3%................ 310............... 308............... 310
($40.5/t case) **.
CO2 Reduction Monetized Value 2.5%.............. 448............... 446............... 448
($62.4/t case) **.
CO2 Reduction Monetized Value 3%................ 950............... 946............... 950
($119/t case) **.
NOX Reduction Monetized Value 7%................ 22.4.............. 22.3.............. 22.4
(at $2,684/ton) **. 3%................ 21.6.............. 21.5.............. 21.6
Total Benefits [dagger]......... 7% plus CO2 range. 1,150 to 2,000.... 1,130 to 1,980.... 1,170 to 2,030
7%................ 1,360............. 1,340............. 1,390
3% plus CO2 range. 1,140 to 2,000.... 1,120 to 1,970.... 1,170 to 2,030
3%................ 1,360............. 1,330............. 1,390
----------------------------------------------------------------------------------------------------------------
Costs
----------------------------------------------------------------------------------------------------------------
Consumer Incremental Product 7%................ 841............... 882............... 841
Costs. 3%................ 724............... 763............... 724
----------------------------------------------------------------------------------------------------------------
Net Benefits
----------------------------------------------------------------------------------------------------------------
Total [dagger].................. 7% plus CO2 range. 300 to 1,160...... 241 to 1,090...... 328 to 1,180
7%................ 516............... 452............... 540
3% plus CO2 range. 415 to 1,270...... 350 to 1,200...... 443 to 1,300
[[Page 4144]]
3%................ 627............... 561............... 655
----------------------------------------------------------------------------------------------------------------
* This table presents the annualized costs and benefits associated with GSFLs shipped in 2018-2047. These
results include benefits to consumers that accrue after 2047 from the products purchased in 2018-2047. The
results account for the incremental variable and fixed costs incurred by manufacturers due to the standard,
some of which may be incurred in preparation for the rule. The Primary Benefits Estimate assumes the Reference
case energy prices from AEO 2014 and decreasing incremental product cost, due to price learning. The Low
Benefits Estimate uses the Low Economic Growth energy prices from AEO 2014 and constant real product prices.
The High Benefits Estimate assumes the Low Economic Growth energy price estimates from AEO 2014 and the same
decreasing incremental product costs as in the Primary Benefits Estimate.
** The CO2 values represent global monetized values of the SCC, in 2013$, in 2015 under several scenarios of the
updated SCC values. The first three cases use the averages of SCC distributions calculated using 5%, 3%, and
2.5% discount rates, respectively. The fourth case represents the 95th percentile of the SCC distribution
calculated using a 3% discount rate. The SCC time series used by DOE incorporate an escalation factor. The
value for NOX is the average of the low and high values used in DOE's analysis.
[dagger] Total Benefits for both the 3% and 7% cases are derived using the series corresponding to the average
SCC with 3-percent discount rate ($40.5/t case). In the rows labeled ``7% plus CO2 range'' and ``3% plus CO2
range,'' the operating cost and NOX benefits are calculated using the labeled discount rate, and those values
are added to the full range of CO2 values.
3. Benefits and Burdens of Trial Standard Levels Considered for
Incandescent Reflector Lamps
Table VII.59 and Table VII.60 summarize the quantitative impacts
estimated for the TSL for IRL.
Table VII.60--Summary of Analytical Results for IRL: National Impacts
------------------------------------------------------------------------
Category TSL 1
------------------------------------------------------------------------
National FFC Energy Savings quads
------------------------------------------------------------------------
0.011
------------------------------------------------------------------------
NPV of Consumers Benefits 2013$ billion
------------------------------------------------------------------------
3% discount rate..................................... 0.25
7% discount rate..................................... 0.17
------------------------------------------------------------------------
Cumulative Emissions Reduction (Total FFC Emissions)
------------------------------------------------------------------------
CO2 (million metric tons)............................ 0.77
SO2 (thousand tons).................................. 0.76
NOx (thousand tons).................................. 1.1
Hg (tons)............................................ 0.0023
CH4 (thousand tons).................................. 2.7
CH4 (thousand tons CO2eq) *.......................... 76
N2O (thousand tons).................................. 0.0088
N2O (thousand tons CO2eq) *.......................... 2.3
------------------------------------------------------------------------
Value of Emissions Reduction (Total FFC Emissions)
------------------------------------------------------------------------
CO2 2013$ million **................................. 7 to 90
NOX--3% discount rate 2013$ million.................. 2.2
NOX--7% discount rate 2013$ million.................. 1.6
------------------------------------------------------------------------
* CO2eq is the quantity of CO2 that would have the same GWP.
** Range of the economic value of CO2 reductions is based on estimates
of the global benefit of reduced CO2 emissions.
Table VII.61--Summary of Analytical Results for IRL: Manufacturer and
Consumer Impacts
------------------------------------------------------------------------
Category TSL 1
------------------------------------------------------------------------
Manufacturer Impacts
------------------------------------------------------------------------
Change in Industry NPV (2013$ million) * (Base Case (52.5)-(56.2)
Industry NPV of $145.4).............................
Change in Industry NPV (%) *......................... (36.1)-(38.6)
------------------------------------------------------------------------
Consumer Mean LCC Savings * 2013$
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V........ 3.09
[[Page 4145]]
Consumer Mean PBP * years
------------------------------------------------------------------------
Standard spectrum; >2.5 inch diameter; <125 V........ 5.3
Consumers with Net Cost %............................ 0.0
Consumers with Net Benefit %......................... 100.0
Consumers with No Impact %........................... 0.0
------------------------------------------------------------------------
* Values in parentheses are negative values.
DOE considered TSL 1, which would save an estimated total of 0.0102
quads of energy, an amount DOE considers significant. TSL 1 has an
estimated NPV of consumer benefit of $0.17 billion using a 7-percent
discount rate, and $0.25 billion using a 3-percent discount rate.
The cumulative emissions reductions at TSL 1 are 0.77 million
metric tons of CO2, 1.1 thousand tons of NOX,
0.76 thousand tons of SO2, 0.0023 tons of Hg, 2.7 thousand
tons of CH4, and 0.0088 thousand tons of N2O. The
estimated monetary value of the CO2 emissions reductions at
TSL 1 ranges from $7 million to $90 million.
At TSL 1, the weighted average LCC savings for the standard
spectrum, >2.5 inch diameter, <125 V product class is $3.09. The LCC
savings were positive for both representative lamp units in each
sector.
At TSL 1, DOE estimates industry would need to invest approximately
$72.6 million in conversion costs. At TSL 1, the projected change in
INPV ranges from a decrease of $52.5 million to a decrease of $56.2
million. If the larger decrease is realized, TSL 1 could result in a
net loss of up to 38.6 percent in INPV to manufacturers of covered
IRLs.
At TSL 1, given the size of the investment, DOE believes there is
uncertainty as to whether manufacturers would spend the capital
required to produce more efficient, longer lifetime products at the
volume needed to satisfy the market demand. Manufacturers could instead
choose to forego the significant investment and produce exempt products
or exit the market entirely. DOE is also aware that to meet higher
efficacy levels, manufacturers can choose to produce lamps with a
shorter lifetime and did so in response to the July 2012 standards by
introducing IRLs with shorter lifetimes. DOE conducted a sensitivity
analysis to assess the impacts of manufacturers shortening the lifetime
of covered IRLs to meet TSL 1. DOE determined that if manufacturers
shorten the lifetime of IRLs, consumers would experience negative LCC
savings in both the residential and commercial sectors.
After considering the analysis and weighing the benefits and the
burdens, DOE concluded that, at TSL 1 for IRLs, the benefits of energy
savings, positive NPV of consumer benefits, positive impacts on
consumers (as indicated by positive average LCC savings), emission
reductions and the estimated monetary value of the emissions reductions
would be outweighed by the potential reduction in industry value and
the potential negative costs to consumers in the scenario that
manufacturers shortened the lifetime of covered IRLs. Consequently, DOE
has concluded that TSL 1 is not economically justified.
Based on the above considerations, DOE is not amending energy
conservation standards for IRLs.
VIII. Procedural Issues and Regulatory Review
A. Review Under Executive Orders 12866 and 13563
Section 1(b)(1) of Executive Order 12866, ``Regulatory Planning and
Review,'' 58 FR 51735 (Oct. 4, 1993), requires each agency to identify
the problem that it intends to address, including, where applicable,
the failures of private markets or public institutions that warrant new
agency action, as well as to assess the significance of that problem.
The problems that these standards address are as follows:
(1) There is limited relevant consumer information in the lighting
market, and the high costs of gathering and analyzing relevant
information leads some consumers to miss opportunities to make cost-
effective investments in energy efficiency.
(2) In some cases the benefits of more efficient products are not
realized due to misaligned incentives between purchasers and users. An
example of such a case is when the product purchase decision is made by
a building contractor or building owner who does not pay the energy
costs.
(3) There are external benefits resulting from improved energy
efficiency of GSFLs and IRLs that are not captured by the users of such
products. These benefits include externalities related to public
health, environmental protection and national security that are not
reflected in energy prices, such as reduced emissions of air pollutants
and greenhouse gases that impact human health and global warming.
In addition, DOE has determined that this regulatory action is a
``significant regulatory action'' under Executive Order 12866. DOE
presented to OIRA in the OMB for review the draft rule and other
documents prepared for this rulemaking, including a regulatory impact
analysis (RIA), and has included these documents in the rulemaking
record. The assessments prepared pursuant to Executive Order 12866 can
be found in the technical support document for this rulemaking.
DOE has also reviewed this regulation pursuant to Executive Order
13563. (76 FR 3281, Jan. 21, 2011) EO 13563 is supplemental to and
explicitly reaffirms the principles, structures, and definitions
governing regulatory review established in Executive Order 12866. To
the extent permitted by law, agencies are required by Executive Order
13563 to: (1) Propose or adopt a regulation only upon a reasoned
determination that its benefits justify its costs (recognizing that
some benefits and costs are difficult to quantify); (2) tailor
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations; (3) select, in choosing among alternative regulatory
approaches, those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts; and equity); (4) to the extent
feasible, specify performance objectives, rather than specifying the
behavior or manner of compliance that regulated entities must adopt;
and (5) identify and assess available alternatives to direct
regulation, including providing economic incentives to encourage the
desired behavior, such as user fees or
[[Page 4146]]
marketable permits, or providing information upon which choices can be
made by the public.
DOE emphasizes as well that Executive Order 13563 requires agencies
to use the best available techniques to quantify anticipated present
and future benefits and costs as accurately as possible. In its
guidance, OIRA has emphasized that such techniques may include
identifying changing future compliance costs that might result from
technological innovation or anticipated behavioral changes. For this
final rule, DOE has utilized the latest market and technology
assessments, product information, and prices available at the time of
this analysis and developed shipment projections based on historical
data and key market drivers to determine national energy savings and
net present value of potential standards. Further, in anticipation of
future trends DOE has also considered various alternative scenarios
including increases in rare earth phosphor and xenon prices. Therefore,
DOE believes that this rule is consistent with these principles,
including the requirement that, to the extent permitted by law,
benefits justify costs and that net benefits are maximized.
For future regulatory efforts regarding this product category, DOE
will utilize the latest market and technology assessments, product
information, and prices available at the time of the analysis and
develop shipment projections based on historical data and key market
drivers. Additionally, the agency will restrospectively evaluate the
consumer choice model and related shipments trends that project that
consumers will switch from purchasing one type of product class to
another as a result of the revised energy efficiency standards. DOE's
evaluation will verify the assumptions and revise as appropriate the
consumer choice model for the next rulemaking iteration.
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, and a final
regulatory flexibility analysis (FRFA) for any such rule that an agency
adopts as a final rule, unless the agency certifies that the rule, if
promulgated, will not have a significant economic impact on a
substantial number of small entities. As required by Executive Order
13272, ``Proper Consideration of Small Entities in Agency Rulemaking,''
67 FR 53461 (August 16, 2002), DOE published procedures and policies on
February 19, 2003, to ensure that the potential impacts of its rules on
small entities are properly considered during the rulemaking process.
68 FR 7990. DOE has made its procedures and policies available on the
Office of the General Counsel's Web site (http://energy.gov/gc/office-general-counsel). DOE reviewed the April 2014 NOPR (79 FR 24068) and
this rule under the provisions of the Regulatory Flexibility Act and
the procedures and policies published on February 19, 2003.
As a result of this review, DOE has prepared a FRFA for GSFLs, but
not for IRLs since DOE is not setting amended energy conservation
standards for IRLs as part of this rule. As presented and discussed in
the following section, the GSFL FRFA describes impacts on GSFL
manufacturers and discusses alternatives that could minimize these
impacts. A statement of the reasons for establishing the standards in
this rule, and the objectives of, and legal basis for these standards,
are set forth elsewhere in the preamble and not repeated here. Chapter
13 of this final rule TSD contains more information about the impact of
this rulemaking on manufacturers.
1. Description and Estimated Number of Small Entities Regulated
a. Methodology for Estimating the Number of Small Entities
For manufacturers of GSFLs, the Small Business Administration (SBA)
has set a size threshold, which defines those entities classified as
``small businesses'' for the purposes of the statute. DOE used the
SBA's small business size standards to determine whether any small
entities would be subject to the requirements of the rule. 65 FR 30836,
30848 (May 15, 2000), as amended at 65 FR 53533, 53544 (Sept. 5, 2000)
and codified at 13 CFR part 121.The size standards are listed by North
American Industry Classification System (NAICS) code and industry
description and are available at http://www.sba.gov/content/table-small-business-size-standards. GSFL manufacturing is classified under
NAICS code 335110, ``Electric Lamp Bulb and Part Manufacturing.'' The
SBA sets a threshold of 1,000 employees or less for an entity to be
considered as a small business for this category.
To estimate the number of companies that could be small business
manufacturers of GSFLs covered by this rulemaking, DOE conducted a
market survey using publicly available information. DOE's research
involved industry trade association membership directories (including
NEMA), information from previous rulemakings, individual company Web
sites, SBA's database, and market research tools (e.g., Hoover's
reports). DOE also asked stakeholders and industry representatives if
they were aware of any small manufacturers during manufacturer
interviews and DOE public meetings. DOE used information from these
sources to create a list of companies that potentially manufacture or
sell GSFLs and would be impacted by this rulemaking. As necessary, DOE
contacted companies to determine whether they met the SBA's definition
of a small business manufacturer of GSFLs. DOE screened out companies
that do not offer products covered by this rulemaking, do not meet the
definition of a ``small business,'' or are completely foreign owned and
operated.
For GSFLs, DOE initially identified a total of 47 potential
companies that sell GSFLs in the United States. After reviewing
publicly available information on these potential GSFL manufacturers,
DOE determined that 26 were either large manufacturers, manufacturers
that were completely foreign owned and operated, or did not sell GSFLs
covered by this rulemaking. DOE then contacted the remaining 21 GSFL
companies to determine whether they met SBA's definition of a small
business and whether they manufactured or sold GSFLs that would be
affected by these standards. Based on these efforts, DOE estimated that
there are 21 small businesses that either manufacture or sell covered
GSFLs in the United States.
b. Manufacturer Participation
DOE contacted all 21 identified GSFL small businesses to invite
them to take part in a small business MIA interview. Of the GSFL
manufacturers DOE contacted, eight responded to DOE's email and phone
communications and 13 did not. DOE was able to reach and discuss
potential standards with two of the eight GSFL small business
manufacturers that responded. The remaining six declined DOE's request
to be interviewed for this rulemaking. DOE also obtained information
about small business manufacturers and potential impacts on small
businesses while interviewing large manufacturers.
c. GSFL Industry Structure and Nature of Competition
Three major manufacturers supply approximately 90 percent of the
GSFL market. None of these three major GSFL manufacturers are small
businesses. DOE estimates that the remaining 10 percent of the GSFL
market is served by either small businesses or
[[Page 4147]]
manufacturers that are completely foreign owned and operated. No small
business has more than a three percent market share in the GSFL
industry. Small businesses that sell covered GSFLs tend to be companies
that outsource the manufacturing to overseas companies who produce the
lamps specified by the small businesses. These small businesses provide
the specifications for these lamps as well as the testing and
certification to comply with any U.S. energy conservation standards.
d. Comparison Between Large and Small Entities
For GSFLs, small businesses differ from large manufacturers in
several ways that directly affect the extent to which a company would
be impacted by energy conservation standards. The main differences
between small and large entities for this rulemaking are that small
manufacturers of GSFLs have lower sales volumes and are frequently not
the original manufacturers of GSFLs. Therefore, these small businesses
would not have any capital conversion costs to comply with amended
standards, since the machinery used to produce GSFLs is owned and
operated by overseas manufacturers. The small businesses would most
likely experience higher per-unit costs for the products if the
conversion costs experienced by the overseas manufacturers are passed
through to the small businesses, potentially reducing those small
business' manufacturer markups and profits.
Small businesses would also have product conversion costs
associated with testing and certifying any lamps that would need to be
redesigned due to standards. Typically the testing and certification
costs are proportional to the number of products offered by a company
and not the volume of sales. Some small businesses stated they could
offer up to 75 percent of the number of covered products that large
manufacturers offer; however, the volume of sales for each single
product offered by a small business would be significantly smaller than
that of a larger manufacturer. Consequently, the revenue associated
with a single product is much smaller for small businesses than for
large manufacturers. Therefore, these small businesses could have
product conversion costs in the same range as large manufacturers,
since product conversion costs scale to number of products offered,
even though the total revenue is significantly lower for small
businesses compared to large manufacturers.
Lower sales volumes are the biggest disadvantage for most small
businesses. A lower-volume business' product conversion costs are
spread over fewer units than a larger competitor. Thus, unless the
small business can differentiate its product in some way that earns a
price premium, the small business experiences a reduction in profit
per-unit relative to the large manufacturer. Most small GSFL businesses
operate in the same lighting markets as large manufacturers and do not
operate in niche GSFL markets. Much of the same manufacturing equipment
would need to be purchased by both large manufacturers and small
businesses to produce GSFLs at higher efficacy levels. If the small
business is not the original lamp manufacturer, the manufacturer that
sells to the small business would have to purchase this manufacturing
equipment. Therefore, undifferentiated small businesses would face a
greater per-unit cost penalty because they must spread the conversion
costs over fewer units. While small businesses may not be directly
paying these capital conversion costs, they are still responsible for
selling certified products made by the original lamp manufacturers. The
costs incurred by contracted manufacturers are passed on to small
businesses that must maintain profit margins by either increasing
product prices or decreasing profitability.
2. Description and Estimate of Compliance Requirements
Small GSFL businesses will be affected differently by the amended
energy conservation standards compared to large manufacturers. One of
the key differences between large manufacturers and the small
businesses identified by DOE for this rulemaking is that small GSFL
businesses typically outsource the manufacturing of the lamps they sell
to original product manufacturers abroad. This, in addition to the
small volume of sales typical of small businesses, results in small
GSFL businesses having different types and amounts of conversion costs
compared to large manufacturers.
As a result of these standards, small GSFL businesses will incur
product conversion costs because products that no longer meet the
efficacy levels of these standards will most likely need to be
redesigned, retested, and recertified. Since small businesses have
significantly less revenue and annual R&D budgets than large
manufacturers, the product conversion costs necessary to comply with
amended standards represent a significant portion of a small business'
annual revenue. However, unlike large manufacturers, small businesses
will most likely not incur any capital conversion costs due to amended
standards because small businesses usually do not own and operate the
machinery used to manufacture the covered GSFLs. The capital conversion
costs incurred by original product manufacturers will instead be passed
along indirectly to the domestic small businesses.
In the GSFL market, DOE identified 21 small GSFL businesses with
covered products affected by this rulemaking. It is unlikely that small
GSFL businesses will incur any capital conversion costs because small
businesses usually do not own and operate the machinery used to
manufacture the covered GSFLs; however, they will likely face
significant product conversion costs to cover R&D, certification, and
testing of products that need to be redesigned to meet the efficacy
levels set in this standard. DOE estimates that approximately 61
percent of the covered products offered by small GSFL manufacturers
meet the efficacy levels established by this rule, TSL 4. As a result,
an average of approximately 39 percent of products would need to be
redesigned to meet these efficacy levels, resulting in small GSFL
businesses incurring more than $1.08 million on average in product
conversion costs or nearly five times as much as typical annual GSFL
R&D expenses. GSFL sales account for approximately 25 percent of a
typical small business' annual revenue, so redesigning up to 39 percent
of those offerings could have a significant impact on their business.
Redesigning a large majority of product offerings that represent a
significant revenue stream will be more difficult for small businesses,
compared to large businesses, as they have less R&D and revenue.
[[Page 4148]]
Table VIII.1--Estimated GSFL Product Conversion Costs as a Percentage of Annual GSFL R&D Expense
----------------------------------------------------------------------------------------------------------------
Product conversion cost Total conversion cost
as a percentage of as a percentage of
annual R&D expense annual revenue
(percent) (percent)
----------------------------------------------------------------------------------------------------------------
Typical Large Manufacturer.................................... 3 1
Typical Small Manufacturer.................................... 471 21
----------------------------------------------------------------------------------------------------------------
Small businesses in the GSFL industry expressed concern that
possible manufacturing downtime, discontinuation of product lines, and
high direct and indirect conversion costs resulting from amended GSFL
energy conservation standards could have a significant impact on their
revenue and could affect domestic employment decisions. Domestic
employment impacts could be especially prevalent, since GSFL revenue
accounts for approximately 25 percent of a typical small business'
revenue. Domestic employment impacts would be seen in small business'
sales forces and warehouse staff that could be potentially downsized as
a result of the GSFL standards established in this rule.
3. Duplication, Overlap, and Conflict With Other Rules and Regulations
DOE is not aware of any rules or regulations that duplicate,
overlap, or conflict with the final rule established.
4. Significant Alternatives to the Rule
The discussion in the previous section analyzes impacts on GSFL
small businesses that would result from DOE's final rule. In addition
to the other TSLs being considered, the final rule TSD includes a RIA.
For GSFLs, the RIA discusses the following policy alternatives: (1) No
change in standard; (2) consumer rebates; (3) consumer tax credits; (4)
manufacturer tax credits; (5) voluntary energy efficiency targets; and
(6) bulk government purchases. While these alternatives may mitigate to
some varying extent the economic impacts on small entities compared to
the adopted standards, DOE did not consider these alternatives further
because they are expected to result in energy savings that are much
smaller than those that will be achieved by the adopted standard levels
in this final rule (for 4-foot MBP the energy savings ranged from 51
percent to 98 percent less primary energy savings; for 4-foot T5 MiniBP
SO the energy savings ranged from 84 percent to 98 percent less primary
energy savings). In reviewing alternatives, DOE also examined energy
conservation standards set at lower efficacy levels. DOE notes that it
did not consider an alternative compliance date for the entire industry
affected by this rulemaking. DOE is constrained by the three-year lead
time required by statute (42 U.S.C. 6295(i)(5)). However, certain
compliance date alternatives may be available to individual
manufacturers, as discussed below. Accordingly, DOE is declining to
adopt any of these alternatives and is adopting the standards set forth
in this rulemaking. See chapter 18 of the final rule TSD for further
detail on the policy alternatives that DOE considered.
Additional compliance flexibilities may be available through other
means. For example, individual manufacturers may petition for a waiver
of the applicable test procedure. Further, EPCA provides that a
manufacturer whose annual gross revenue from all of its operations does
not exceed $8,000,000 may apply for an exemption from all or part of an
energy conservation standard for a period not longer than 24 months
after the effective date of a final rule establishing the standard.
Additionally, Section 504 of the Department of Energy Organization Act,
42 U.S.C. 7194, provides authority for the Secretary to adjust a rule
issued under EPCA in order to prevent ``special hardship, inequity, or
unfair distribution of burdens'' that may be imposed on that
manufacturer as a result of such rule. Manufacturers should refer to 10
CFR part 430, subpart E, and part 1003 for additional details.
C. Review Under the Paperwork Reduction Act
Manufacturers of GSFLs must certify to DOE that their products
comply with any applicable energy conservation standards. In certifying
compliance, manufacturers must test their products according to the DOE
test procedures for GSFLs, including any amendments adopted for those
test procedures. DOE has established regulations for the certification
and recordkeeping requirements for all covered consumer products and
commercial equipment, including GSFLs. 76 FR 12422 (March 7, 2011). The
collection-of-information requirement for the certification and
recordkeeping is subject to review and approval by OMB under the
Paperwork Reduction Act (PRA). This requirement has been approved by
OMB under OMB Control Number 1910-1400. Public reporting burden for the
certification is estimated to average 30 hours per response, including
the time for reviewing instructions, searching existing data sources,
gathering and maintaining the data needed, and completing and reviewing
the collection of information.
Notwithstanding any other provision of the law, no person is
required to respond to, nor shall any person be subject to a penalty
for failure to comply with, a collection of information subject to the
requirements of the PRA, unless that collection of information displays
a currently valid OMB Control Number.
D. Review Under the National Environmental Policy Act of 1969
Pursuant to the National Environmental Policy Act (NEPA) of 1969,
DOE has determined that the rule fits within the category of actions
included in Categorical Exclusion (CX) B5.1 and otherwise meets the
requirements for application of a CX. See 10 CFR part 1021, App. B,
B5.1(b); 1021.410(b) and Appendix B, B(1)-(5). The rule fits within the
category of actions because it is a rulemaking that establishes energy
conservation standards for consumer products or industrial equipment,
and for which none of the exceptions identified in CX B5.1(b) apply.
Therefore, DOE has made a CX determination for this rulemaking, and DOE
does not need to prepare an Environmental Assessment or Environmental
Impact Statement for this rule. DOE's CX determination for this rule is
available at http://cxnepa.energy.gov/.
E. Review Under Executive Order 13132
Executive Order 13132, ``Federalism.'' 64 FR 43255 (Aug. 10, 1999)
imposes certain requirements on federal agencies formulating and
implementing policies or regulations that preempt state law or that
have Federalism implications. The Executive Order requires agencies to
examine the constitutional and statutory authority supporting any
action that would limit the policymaking discretion of the States and
to carefully assess the necessity for such actions. The
[[Page 4149]]
Executive Order also requires agencies to have an accountable process
to ensure meaningful and timely input by state and local officials in
the development of regulatory policies that have Federalism
implications. On March 14, 2000, DOE published a statement of policy
describing the intergovernmental consultation process it will follow in
the development of such regulations. 65 FR 13735. EPCA governs and
prescribes federal preemption of state regulations as to energy
conservation for the products that are the subject of this rule. States
can petition DOE for exemption from such preemption to the extent, and
based on criteria, set forth in EPCA. (42 U.S.C. 6297) No further
action is required by Executive Order 13132.
F. Review Under Executive Order 12988
With respect to the review of existing regulations and the
promulgation of new regulations, section 3(a) of Executive Order 12988,
``Civil Justice Reform,'' imposes on federal agencies the general duty
to adhere to the following requirements: (1) Eliminate drafting errors
and ambiguity; (2) write regulations to minimize litigation; and (3)
provide a clear legal standard for affected conduct rather than a
general standard and promote simplification and burden reduction. 61 FR
4729 (Feb. 7, 1996). Section 3(b) of Executive Order 12988 specifically
requires that Executive agencies make every reasonable effort to ensure
that the regulation: (1) Clearly specifies the preemptive effect, if
any; (2) clearly specifies any effect on existing federal law or
regulation; (3) provides a clear legal standard for affected conduct
while promoting simplification and burden reduction; (4) specifies the
retroactive effect, if any; (5) adequately defines key terms; and (6)
addresses other important issues affecting clarity and general
draftsmanship under any guidelines issued by the Attorney General.
Section 3(c) of Executive Order 12988 requires Executive agencies to
review regulations in light of applicable standards in section 3(a) and
section 3(b) to determine whether they are met or it is unreasonable to
meet one or more of them. DOE has completed the required review and
determined that, to the extent permitted by law, the final 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. Pub. L. 104-4, sec. 201 (codified at 2 U.S.C. 1531).
For an amended 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 ``significant
intergovernmental mandate,'' and requires an agency plan for giving
notice and opportunity for timely input to potentially affected small
governments before establishing any requirements that might
significantly or uniquely affect small governments. On March 18, 1997,
DOE published a statement of policy on its process for
intergovernmental consultation under UMRA. 62 FR 12820. DOE's policy
statement is also available at http://energy.gov/gc/office-general-counsel.
DOE has concluded that the final rule would likely require
expenditures of $100 million or more on the private sector. Such
expenditures may include: (1) Investment in research and development
and in capital expenditures by GSFL manufacturers in the years between
the final rule and the compliance date for the new standards, and (2)
incremental additional expenditures by consumers to purchase higher
efficacy GSFLs, starting at the compliance date for the applicable
standard.
Section 202 of UMRA authorizes a federal agency to respond to the
content requirements of UMRA in any other statement or analysis that
accompanies the final rule. 2 U.S.C. 1532(c). The content requirements
of section 202(b) of UMRA relevant to a private sector mandate
substantially overlap the economic analysis requirements that apply
under section 325(o) of EPCA and Executive Order 12866. The
SUPPLEMENTARY INFORMATION section of this final rule and the
``Regulatory Impact Analysis'' section of the final rule TSD respond to
those requirements.
Under section 205 of UMRA, the Department is obligated to identify
and consider a reasonable number of regulatory alternatives before
promulgating a rule for which a written statement under section 202 is
required. 2 U.S.C. 1535(a). DOE is required to select from those
alternatives the most cost effective and least burdensome alternative
that achieves the objectives of the rule unless DOE publishes an
explanation for doing otherwise, or the selection of such an
alternative is inconsistent with law. As required by 42 U.S.C.
6295(i)(4)-(5), this rule establishes energy conservation standards for
GSFLs that are designed to achieve the maximum improvement in energy
efficiency that DOE has determined to be both technologically feasible
and economically justified. A full discussion of the alternatives
considered by DOE is presented in the ``Regulatory Impact Analysis''
section of the final rule TSD for this rule.
H. Review Under the Treasury and General Government Appropriations Act,
1999
Section 654 of the Treasury and General Government Appropriations
Act, 1999 (Pub. L. 105-277) requires federal agencies to issue a Family
Policymaking Assessment for any rule that may affect family well-being.
This rule would not have any impact on the autonomy or integrity of the
family as an institution. Accordingly, DOE has concluded that it is not
necessary to prepare a Family Policymaking Assessment.
I. Review Under Executive Order 12630
DOE has determined, under Executive Order 12630, ``Governmental
Actions and Interference with Constitutionally Protected Property
Rights'' 53 FR 8859 (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 the Treasury and General Government Appropriations Act,
2001
Section 515 of the Treasury and General Government Appropriations
Act, 2001 (44 U.S.C. 3516, note) provides for federal agencies to
review most disseminations of information to the public under
guidelines established by each agency pursuant to general guidelines
issued by OMB. OMB's guidelines were published at 67 FR 8452 (Feb. 22,
2002), and DOE's guidelines were published at 67 FR 62446 (Oct. 7,
2002). DOE has reviewed this 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,
[[Page 4150]]
Distribution, or Use'' 66 FR 28355 (May 22, 2001), requires federal
agencies to prepare and submit to OIRA at OMB, a Statement of Energy
Effects for any significant energy action. A ``significant energy
action'' is defined as any action by an agency that promulgates or is
expected to lead to promulgation of a final rule, and that: (1) Is a
significant regulatory action under Executive Order 12866, or any
successor order; and (2) is likely to have a significant adverse effect
on the supply, distribution, or use of energy, or (3) is designated by
the Administrator of OIRA as a significant energy action. For any
significant energy action, the agency must give a detailed statement of
any adverse effects on energy supply, distribution, or use should the
proposal be implemented, and of reasonable alternatives to the action
and their expected benefits on energy supply, distribution, and use.
DOE has concluded that this regulatory action, which sets forth
energy conservation standards for GSFLs, is not a significant energy
action because the amended standards are not likely to have a
significant adverse effect on the supply, distribution, or use of
energy, nor has it been designated as such by the Administrator at
OIRA. Accordingly, DOE has not prepared a Statement of Energy Effects
on the final rule.
L. Review Under the Information Quality Bulletin for Peer Review
On December 16, 2004, OMB, in consultation with the Office of
Science and Technology Policy (OSTP), issued its Final Information
Quality Bulletin for Peer Review (the Bulletin). 70 FR 2664 (Jan. 14,
2005). The Bulletin establishes that certain scientific information
shall be peer reviewed by qualified specialists before it is
disseminated by the Federal Government, including influential
scientific information related to agency regulatory actions. The
purpose of the Bulletin is to enhance the quality and credibility of
the Government's scientific information. Under the Bulletin, the energy
conservation standards rulemaking analyses are ``influential scientific
information,'' which the Bulletin defines as scientific information the
agency reasonably can determine will have, or does have, a clear and
substantial impact on important public policies or private sector
decisions. 70 FR 2667.
In response to OMB's Bulletin, DOE conducted formal in-progress
peer reviews of the energy conservation standards development process
and analyses and has prepared a Peer Review Report pertaining to the
energy conservation standards rulemaking analyses. Generation of this
report involved a rigorous, formal, and documented evaluation using
objective criteria and qualified and independent reviewers to make a
judgment as to the technical/scientific/business merit, the actual or
anticipated results, and the productivity and management effectiveness
of programs and/or projects. The ``Energy Conservation Standards
Rulemaking Peer Review Report'' dated February 2007 has been
disseminated and is available at the following Web site:
www1.eere.energy.gov/buildings/appliance_standards/peer_review.html.
M. Congressional Notification
As required by 5 U.S.C. 801, DOE will report to Congress on the
promulgation of this rule prior to its effective date. The report will
state that it has been determined that the rule is a ``major rule'' as
defined by 5 U.S.C. 804(2).
IX. Approval of the Office of the Secretary
The Secretary of Energy has approved publication of today's final
rule.
List of Subjects in 10 CFR Part 430
Administrative practice and procedure, Confidential business
information, Energy conservation, Household appliances, Imports,
Intergovernmental relations, Reporting and recordkeeping requirements,
and Small businesses.
Issued in Washington, DC, on December 30, 2014.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Energy Efficiency and
Renewable Energy.
For the reasons set forth in the preamble, DOE amends part 430 of
chapter II, subchapter D, of title 10 of the Code of Federal
Regulations, as set forth below:
PART 430--ENERGY CONSERVATION PROGRAM FOR CONSUMER PRODUCTS
0
1. The authority citation for part 430 continues to read as follows:
Authority: 42 U.S.C. 6291-6309; 28 U.S.C. 2461 note.
0
2. In Sec. 430.2, add the definitions for ``700 series fluorescent
lamp'', ``Designed and marketed'', ``Fluorescent lamp designed for use
in reprographic equipment,'' ``Impact-resistant fluorescent lamp,''
``Lamps primarily designed to produce radiation in the ultraviolet
region of the spectrum,'' ``Reflectorized or aperture lamp,'' in
alphabetical order, and revise the definition for ``Fluorescent lamp''
to read as follows:
Sec. 430.2 Definitions.
* * * * *
700 series fluorescent lamp means a fluorescent lamp with a color
rendering index (measured according to the test procedures outlined in
Appendix R to subpart B of this part) that is in the range (inclusive)
of 70 to 79.
* * * * *
Designed and marketed means that the intended application of the
lamp is clearly stated in all publicly available documents (e.g.,
product literature, catalogs, and packaging labels). This definition is
applicable to terms related to the following covered lighting products:
Fluorescent lamp ballasts; fluorescent lamps; general service
fluorescent lamps; general service incandescent lamps; general service
lamps; incandescent lamps; incandescent reflector lamps; medium base
compact fluorescent lamps; and specialty application mercury vapor lamp
ballasts.
* * * * *
Fluorescent lamp means a low pressure mercury electric-discharge
source in which a fluorescing coating transforms some of the
ultraviolet energy generated by the mercury discharge into light,
including only the following:
(1) Any straight-shaped lamp (commonly referred to as 4-foot medium
bipin lamps) with medium bipin bases of nominal overall length of 48
inches and rated wattage of 25 or more;
(2) Any U-shaped lamp (commonly referred to as 2-foot U-shaped
lamps) with medium bipin bases of nominal overall length between 22 and
25 inches and rated wattage of 25 or more;
(3) Any rapid start lamp (commonly referred to as 8-foot high
output lamps) with recessed double contact bases of nominal overall
length of 96 inches;
(4) Any instant start lamp (commonly referred to as 8-foot slimline
lamps) with single pin bases of nominal overall length of 96 inches and
rated wattage of 49 or more;
(5) Any straight-shaped lamp (commonly referred to as 4-foot
miniature bipin standard output lamps) with miniature bipin bases of
nominal overall length between 45 and 48 inches and rated wattage of 25
or more; and
(6) Any straight-shaped lamp (commonly referred to 4-foot miniature
bipin high output lamps) with miniature bipin bases of nominal overall
length between 45 and 48 inches and rated wattage of 44 or more.
[[Page 4151]]
Fluorescent lamp designed for use in reprographic equipment means a
fluorescent lamp intended for use in equipment used to reproduce,
reprint, or copy graphic material.
* * * * *
Impact-resistant fluorescent lamp means a lamp that:
(1) Has a coating or equivalent technology that is compliant with
NSF/ANSI 51 (incorporated by reference; see Sec. 430.3) and is
designed to contain the glass if the glass envelope of the lamp is
broken; and
(2) Is designated and marketed for the intended application, with:
(i) The designation on the lamp packaging; and
(ii) Marketing materials that identify the lamp as being impact-
resistant, shatter-resistant, shatter-proof, or shatter-protected.
* * * * *
Lamps primarily designed to produce radiation in the ultraviolet
region of the spectrum means fluorescent lamps that primarily emit
light in the portion of the electromagnetic spectrum where light has a
wavelength between 10 and 400 nanometers.
* * * * *
Reflectorized or aperture lamp means a fluorescent lamp that
contains an inner reflective coating on the bulb to direct light.
* * * * *
0
3. Section 430.32 is amended by revising paragraph (n) to read as
follows:
Sec. 430.32 Energy and water conservation standards and their
effective dates.
* * * * *
(n) General service fluorescent lamps and incandescent reflector
lamps. (1) Except as provided in paragraphs (n)(2), (n)(3), and (n)(4)
of this section, each of the following general service fluorescent
lamps manufactured after the effective dates specified in the table
shall meet or exceed the following lamp efficacy and CRI standards:
----------------------------------------------------------------------------------------------------------------
Minimum average
Lamp type Nominal lamp Minimum CRI lamp efficacy Effective date
wattage lm/W
----------------------------------------------------------------------------------------------------------------
4-foot medium bipin.............. >35 W 69 75.0 Nov. 1, 1995.
<=35 W 45 75.0 Nov. 1, 1995.
2-foot U-shaped.................. >35 W 69 68.0 Nov. 1, 1995.
<= 35 W 45 64.0 Nov. 1, 1995.
8-foot slimline.................. >65 W 69 80.0 May 1, 1994.
<=65 W 45 80.0 May 1, 1994.
8-foot high output............... >100 W 69 80.0 May 1, 1994.
<=100 W 45 80.0 May 1, 1994.
----------------------------------------------------------------------------------------------------------------
(2) The standards described in paragraph (n)(1) of this section do
not apply to:
(i) Any 4-foot medium bipin lamp or 2-foot U-shaped lamp with a
rated wattage less than 28 watts;
(ii) Any 8-foot high output lamp not defined in ANSI C78.81
(incorporated by reference; see Sec. 430.3) or related supplements, or
not 0.800 nominal amperes; or
(iii) Any 8-foot slimline lamp not defined in ANSI C78.3
(incorporated by reference; see Sec. 430.3).
(3) Except as provided in paragraph (n)(4) of this section, each of
the following general service fluorescent lamps manufactured after July
14, 2012, shall meet or exceed the following lamp efficacy standards
shown in the table:
------------------------------------------------------------------------
Minimum average
Lamp type Correlated color lamp efficacy
temperature lm/W
------------------------------------------------------------------------
4-foot medium bipin............. <=4,500K............ 89
>4,500K and <=7,000K 88
2-foot U-shaped................. <=4,500K............ 84
>4,500K and <=7,000K 81
8-foot slimline................. <=4,500K............ 97
>4,500K and <=7,000K 93
8-foot high output.............. <=4,500K............ 92
>4,500K and <=7,000K 88
4-foot miniature bipin standard <=4,500K............ 86
output. >4,500K and <=7,000K 81
4-foot miniature bipin high <=4,500K............ 76
output. >4,500K and <=7,000K 72
------------------------------------------------------------------------
(4) Each of the following general service fluorescent lamps
manufactured on or after January 26, 2018, shall meet or exceed the
following lamp efficacy standards shown in the table:
[[Page 4152]]
------------------------------------------------------------------------
Minimum average
Lamp type Correlated color lamp efficacy
temperature lm/W
------------------------------------------------------------------------
4-foot medium bipin............. <=4,500K............ 92.4
>4,500K and <=7,000K 88.7
2-foot U-shaped................. <=4,500K............ 85.0
>4,500K and <=7,000K 83.3
8-foot slimline................. <=4,500K............ 97.0
>4,500K and <=7,000K 93.0
8-foot high output.............. <=4,500K............ 92.0
>4,500K and <=7,000K 88.0
4-foot miniature bipin standard <=4,500K............ 95.0
output. >4,500K and <=7,000K 89.3
4-foot miniature bipin high <=4,500K............ 82.7
output. >4,500K and <=7,000K 76.9
------------------------------------------------------------------------
(5) Except as provided in paragraph (n)(6) of this section, each of
the following incandescent reflector lamps manufactured after November
1, 1995, shall meet or exceed the lamp efficacy standards shown in the
table:
------------------------------------------------------------------------
Minimum average
Nominal lamp wattage lamp efficacy
lm/W
------------------------------------------------------------------------
40-50................................................. 10.5
51-66................................................. 11.0
67-85................................................. 12.5
86-115................................................ 14.0
116-155............................................... 14.5
156-205............................................... 15.0
------------------------------------------------------------------------
(6) Each of the following incandescent reflector lamps manufactured
after July 14, 2012, shall meet or exceed the lamp efficacy standards
shown in the table:
----------------------------------------------------------------------------------------------------------------
Minimum average
Rated lamp wattage Lamp spectrum Lamp diameter Rated voltage lamp efficacy
inches lm/W
----------------------------------------------------------------------------------------------------------------
40-205........................... Standard Spectrum...... >2.5 >=125 V 6.8*P0.27
<125 V 5.9*P0.27
<=2.5 >=125 V 5.7*P0.27
<125 V 5.0*P0.27
40-205........................... Modified Spectrum...... >2.5 >=125 V 5.8*P0.27
<125 V 5.0*P0.27
<=2.5 >=125 V 4.9*P0.27
<125 V 4.2*P0.27
----------------------------------------------------------------------------------------------------------------
Note 1: P is equal to the rated lamp wattage, in watts.
Note 2: Standard Spectrum means any incandescent reflector lamp that does not meet the definition of modified
spectrum in 430.2.
(7)(i)(A) Subject to the exclusions in paragraph (n)(7)(ii) of this
section, the standards specified in this section shall apply to ER
incandescent reflector lamps, BR incandescent reflector lamps, BPAR
incandescent reflector lamps, and similar bulb shapes on and after
January 1, 2008.
(B) Subject to the exclusions in paragraph (n)(7)(ii) of this
section, the standards specified in this section shall apply to
incandescent reflector lamps with a diameter of more than 2.25 inches,
but not more than 2.75 inches, on and after June 15, 2008.
(ii) The standards specified in this section shall not apply to the
following types of incandescent reflector lamps:
(A) Lamps rated at 50 watts or less that are ER30, BR30, BR40, or
ER40 lamps;
(B) Lamps rated at 65 watts that are BR30, BR40, or ER40 lamps; or
(C) R20 incandescent reflector lamps rated 45 watts or less.
* * * * *
Appendix
[The following letter from the Department of Justice will not appear
in the Code of Federal Regulations.]
U.S. Department of Justice, Antitrust Division, William J. Baer,
Acting Assistant Attorney General, RFK Main Justice Building, 950
Pennsylvania Ave. NW., Washington, DC 20530-0001, (202) 514-2401/
(202) 616-2645 (Fax)
August 25, 2014
Eric J. Fygi, Deputy General Counsel, Department of Energy,
Washington, DC 20585
Dear Deputy General Counsel Fygi: I am responding to your June
11, 2014 letter seeking the views of the Attorney General about the
potential impact on competition of proposed energy conservation
standards for general service fluorescent lamps and certain
incandescent reflector lamps. Your request was submitted under
Section 325(o)(2)(B)(i)(V) of the Energy Policy and Conservation
Act, as amended (ECPA), 42 U.S.C. 6295(o)(2)(B)(i)(V), which
requires the Attorney General to make a determination of the impact
of any lessening of competition that is likely to result from the
imposition of proposed energy conservation standards. The Attorney
General's responsibility for responding to requests from other
departments about the effect of a program on competition has been
delegated to the Assistant Attorney General for the Antitrust
Division in 28 CFR 0.40(g).
In conducting its analysis the Antitrust Division examines
whether a proposed standard may lessen competition, for example, by
substantially limiting consumer choice, by placing certain
manufacturers at an unjustified competitive disadvantage, or by
inducing avoidable inefficiencies in production or distribution of
particular products. A lessening of competition could result in
higher prices to manufacturers and consumers.
We have reviewed the proposed standards contained in the Notice
of Proposed
[[Page 4153]]
Rulemaking (79 FR 24068, April 29, 2014) (NOPR). We have also
reviewed supplementary information submitted to the Attorney General
by the Department of Energy. Based on this review, our conclusion is
that the proposed energy conservation standards for general service
fluorescent lamps and certain incandescent reflector lamps are
unlikely to have a significant adverse impact on competition.
Sincerely,
William J. Baer
Enclosure
[FR Doc. 2015-00317 Filed 1-22-15; 8:45 am]
BILLING CODE 6450-01-P